Written by Megan Chamberlain
20 Jun 2019

Guide to Alabama Medical Waste Regulations

Do you own, run, or work in a healthcare facility in the state of Alabama? If you do, it’s your responsibility to be aware of biohazardous waste disposal practices and compliant waste segregation of medical waste generated by your facility. It doesn’t matter whether you work in a dental office, a pharmacy, a research facility, or a hospital. The rules don’t just apply to administration departments, but to every single employee from management to housekeepers and groundskeepers.

 

Why should you care?

A single employee can make an unintentional or misinformed mistake in the handling and disposal of medical waste that can cost you tens of thousands of dollars a day and up to $70,000 per incident/violation, per day.

That’s why Daniels Health has gone to the trouble of creating basic overviews for medical waste regulations for states around the country. Of course, we can’t cover every topic, but we do lay the groundwork and emphasize the importance of being knowledgeable about and following federal and state regulations in order to avoid fines and penalties associated with noncompliance.

It is the responsibility of the waste generator to take a “cradle-to-grave” approach to healthcare waste management. Even after medical waste leaves your facility, you are responsible for it until its final, proper, and legal disposition. This applies even if you’ve hired a medical waste removal company to deal with it.

Ensure that healthcare waste regulations are followed inside your four walls. It’s also important to know – without a doubt - that the medical waste business you’ve hired to transport your medical waste to incineration or landfills is also following the rules. Where your medical waste ends up is your responsibility. It’s not just about ethics. It’s the law.

 

Alabama’s guidelines: an overview

Alabama’s laws and regulations regarding medical waste fall under the state’s Administrative Code (335-17-1 through 335-17-8). These guidelines are provided by the Alabama Department of Environmental Management Land Division – the medical waste program administrative codes are designed to establish minimum criteria for healthcare waste management in storage, transportation, treatment and disposal of medical waste. Additional guidelines are also found under the Alabama Solid Wastes and Recyclable Materials Management at (1975 code of Alabama).

Those working in healthcare facilities in Alabama who aren’t aware of this administrative code should pay special attention to 335-17-1-.04, titled ‘Penalty for violations’. It clearly states that violations are punishable by not only the state of Alabama, but “other applicable penalties” which may be more stringent, such as those imposed by the Environmental Protection Agency and other federal agencies, especially those that violate the Clean Air or Clean Water acts.

Within these regulations a number of provisions are covered, in addition to specific information for:

  • Medical waste generators (335-17-2-.01)
  • Collection of medical waste (335-17-3)
  • Storage of untreated and treated medical waste (335-17-4-.01 and .02)
  • Transportation of medical waste (untreated and treated – 335-17-5-.01 and .02)
  • Treatment of medical waste – treatment measures (335-17-6-.01)
  • Disposal of medical waste (335-17-7-.01 and .02)

 

Alabama provides thorough and specific documentation regarding waste remediation programs, available from the Alabama Department of Environmental Management. This authority follows federal and state guidelines. Alabama’s land division has jurisdiction over solid and hazardous waste disposal in the state as well as with remediation of any site contamination. Two of the primary programs found here include basics for the hazardous and solid waste disposal.

If you care to browse, other regulations also apply based on these programs, including hazardous waste found under Division 14 of the ADEM administration codes §§22-30-1 through 22-30-24. This division made its latest revisions in their codes in spring 2018.

These guidelines provide general information, definitions, and specifics regarding identification and listing of hazardous waste. These guidelines also include generators of hazardous waste in regard to manifest and transportation requirements, and recording and reporting processes. These guidelines are applicable to the waste generating facility as well as the owners and operators of hazardous waste treatment, storage, and disposal facilities.

 

Wading through the rules

Daniels Health is aware that familiarity with state guidelines, especially those provided by different departments and administrations, can be time-consuming if not confusing. Alabama’s section regarding definitions and terminology in this regard - and for this one section of administration codes (under Division 14) - is over 40 pages long, and the entire document is over 1,000 pages in length!

We understand that the language and structure of these guidelines can also contribute to ambiguity, sometimes confusion, and often, downright frustration. Case in point: rule number 335-14-2-.03 Characteristics of hazardous waste. Section (b) of this rule states:

"Hazardous waste which is identified by a characteristic in 335-14-2-.03 is assigned every EPA Hazardous Waste Number that is applicable as set forth in 335-14-2-.03. This number must be used in complying with the notification requirements of section 3010 of the RCRA and all applicable record-keeping and reporting requirements under 335-14-3 through 335-14-6, 335-14-8 and 335-14-9."

How’s that for confusing? You have to refer to each rule to make sure you’re doing it right, and that’s just one short paragraph. We know that you’re busy, and we also know the challenges of reading, nevertheless memorizing, hundreds of pages of federal, state, and county guidelines applicable to medical waste generators.

In addition to federal guidelines, Alabama stipulates its own requirements for medical waste management. These requirements are applicable to medical waste generators, medical waste transporters, storage of solid waste and its treatment on-site or off-site, as well as disposal facilities. Each entity is mandated to comply with standards for storage, packaging, labeling, transportation and compliant medical waste disposal.

We also know that the rules are constantly adapting. By the time you become familiar with one set of rules, new rules or revisions can muddy the waters when it comes to healthcare waste management.

We’re familiar with ongoing regulations when it comes to healthcare waste segregation and the importance of segregation of waste streams. We stay on top of EPA, DEA and other federal agency regulations. The reason we take the time to provide overviews of statewide regulations is to emphasize the importance of knowledge and compliance.

 

Fines and penalties are no joke

Fines and penalties for noncompliance when it comes to healthcare waste segregation or mismanaged hazardous waste disposal can cost the facility of any type and any size tens of thousands of dollars per violation, per day. Don’t let this happen to you. Daniels Health offers sustainable, efficient, and cost-effective solutions for healthcare facilities that ensure compliance, and safety of employees, the public, and the environment.

Let us help you and your facility wade through the seemingly endless regulations applicable in Alabama as well as propose methods to optimize waste segregation and healthcare waste solutions that will save you money. Who doesn’t want that? Call Daniels Health today.

For more information on how Daniels Health can help your facility stay on top of ever-changing guidelines and regulations, contact us today.  Alternatively find out more about our Alabama operations and service capabilities on our Alabama service page here.

 

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Megan Chamberlain

Megan Chamberlain

Compliance and Digital Solutions Specialist

With a little bit of knowledge about a lot of things and a quick wit, Megan was the recipient of the Daniels Pun-Master Award 2017 and is the go-to girl for all things compliance.