Guide to California Medical Waste Regulations

Ah California—the golden state. Land of sea, sunshine, and surfing. It would be a shame if all that natural beauty was contaminated by medical waste. It’s up to you, if you work in any healthcare environment in the state of California, to make sure it doesn’t.

Your familiarity with federal and state guidelines for medical waste management is necessary for your safety and career. California’s medical waste regulations are extensive, often complicated and difficult to understand, especially in dealing with multiple waste streams. Daniels Health is always here to assist medical waste generators navigate those regulations.

Addressing every one of California’s medical waste regulations in their entirety is beyond the scope of this article, but this blog provides a basic background of them as well as resources that offer greater detail for proper medical waste stream segregation, transportation, and disposal. Before diving in to any federal or state regulations, knowing the terminology used in any state’s guidelines is necessary. Defining the difference between regulated medical waste and nonregulated medical waste is also important to ensure proper waste segregation.

Medical waste in California is defined as “any biohazardous, pathological, pharmaceutical, or trace chemotherapy waste not regulated by the federal Resource Conservation and Recovery Act (RCRA) of 1976.” This definition has also grown to include a number of additional amendments in regard to sharps, chemotherapy waste, and autopsy or necropsy wastes, and wastes created through testing or production of microbiological materials. It also includes sharps or laboratory wastes that pose a risk of infection to humans, including home-generated sharps. It’s easy to see how all the intricacies can become confusing, right?

California’s definition of an infectious agent specifies that any microorganism, bacteria, mold, parasite, or virus - including but not limited to organisms - managed by biosafety level II, III, or IV by the federal Centers for Disease Control and Prevention (CDC) that can contribute to a risk of increased morbidity or mortality of a human being. I don’t know about you but I am not a fan of increased morbidity risks.

California’s Medical Waste Management Act (§117600 through §118360) offers specific definitions of terms found in state legislature.

Who’s involved in regulated medical waste disposal?

Regulated medical waste (RMW), is also considered as biohazard waste or infectious waste – basically defined as waste that carries the risk of potential contamination by infectious materials, bodily fluids, or blood that poses a risk of transmitting infection, illness, or disease to others.

Medical waste disposal experts must follow primary federal guidelines such as those of the Environmental Protection Agency (EPA) and RCRA standards. In addition, every state mandates their own medical waste regulations, most of which are founded on federal guidelines and standards. Nevertheless, state-by-state standards vary. In addition to the federal government, other agencies are also involved in hazardous waste disposal, healthcare waste segregation, and overall healthcare waste management. Regulated Medical Waste handling is a (mostly) a human generated problem, that if not taken care of properly, impacts many — therefore many people are involved in created regulations to keep us safe. These organizations include:
 

• The Occupational Safety and Health Administration (OSHA) - this agency regulates any aspect of healthcare waste management that involves worker safety. For example, sharps management (including approved sharps container storage), how medical waste bags or containers are labeled, the requirements for storage of any medical waste, as well as standards in place that protect workers from exposure to blood-borne pathogens.
   
• The Department of Transportation (DoT) - regulates specific guidelines for how biohazard waste is transported within state borders. While transportation companies are familiar with these regulations, healthcare facilities and managers should also be aware of the guidelines to reduce risks of liability as well as regulations regarding transportation of a waste generator’s shipments off-site.  It is your responsibility to make sure anyone packaging/transporting waste inside your facility or signing manifests have completed their DOT: RMW training. Daniels Health provides this in our Compliance Portal package.
   
• The Centers for Disease Control and Prevention (CDC) also issues a number of guidelines for infection control measures.

Ensure compliance and reduce the risk to healthcare workers

The regulated medical waste state locator for California offers in-depth details such as guidelines for segregation and storage, management plans, and registration guidelines for small or large-quantity generators.

Medical waste regulations based on California’s Medical Waste Management Act also define the differences and requirements for registration of small or large quantity generators (Chapter 4 and 5 respectively) as well as regulations regarding consolidation (117904), and off-site treatment (117905) and specific requirements of each. Your generator size can determine how you dispose of your waste and how often you are legally required to.

California’s guidelines regarding treatment methods are found in Chapter 8 and include:

• approved methods of treatment (118215)
• treatment of anatomical parts (118220)
• wastes that require specified methods (118222)
• incineration guidelines (118230)

Specific guidelines regarding containment and storage are found in Chapter 9 of the act and cover such topics as:

• medical waste segregation and storage (118275)
• containment and storage (118280)
• sharps waste (118285)
• compactors or grinders (118320)

The Medical Waste Management Act of California’s Health & Safety Code is a 59-page document covering standards and guidelines for California’s medical waste management program. Additional governing regulations are also mandated by California’s Health & Safety Codes 117600 to 118320, as well as regulations under the California Code of Regulations (CCR) Title 22, Division 4.5. For example:

• Hazardous Waste Management System: General (Chapter 10, §66250 - §66260.210)
• Identification and Listing of Hazardous Waste (Chapter 11, §66261.1 - §66260.210)
• Hazardous Waste Transporters (Chapter 13, §66263.10 - §66263.50)

Each medical waste stream incurs specific instructions. For example, guidelines for medical waste management applicable to specific medical waste streams are described in the state’s Health and Safety Codes such as:

• Division 104. Environmental Health [106500 through 119406]
• Division 104 Part 14. Medical Waste [117600 through 118360]

Transportation requirements, shipping and tracking documents and transfer and treatment facilities are also included in California’s Health & Safety Code as well as California’s numerous medical waste regulations codes. Again, it is extremely important the correct staff members have current DOT: RMW training with certificates of completion.

In addition to the above-mentioned organizations, California’s Department of Public Health also regulates handling, storage, treatment and disposal of medical waste based on the California Department of Public Health’s medical waste management program, which oversees implementation of compliance of the Medical Waste Management Act.

Smaller and lesser-known details regarding identification of medical waste can be found in the Department of Public Health documents. For example, in California, acupuncture needles are deemed medical waste. Practitioners at such clinics are also subject to requirements found under the Medical Waste Management Act (Chapter 4), as well as the Health & Safety Code sections 117915 through 117946. These guidelines also specify that acupuncture needles may not be disposed of in solid waste or transported by the generator to any household hazardous waste facility, but rather picked up by registered medical waste haulers.

It’s easy to understand how regulations from difference agencies promotes confusion that may lead to accidental non-compliance. Daniels Health is here to help you—we’re a team.

Managing healthcare waste is our expertise

For over a decade, Daniels Health has provided reliable support to healthcare generators in the segregation, transportation, and treatment of healthcare waste that maintains complete compliance within state borders. Maintaining compliance is essential for reducing risk of federal and state fines and penalties. More money saved from potential fines means more funds to make patient experiences better. We stay on top of ever-changing guidelines and regulations when it comes to medical waste management and provide sustainable and safe solutions for proper medical waste segregation and disposal.

If you would like further help navigating California’s medical waste regulations, call one of our clinical experts today! Alternatively find out more about our California operations and service capabilities on our California service page here. 

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