Written by Amy Piser
04 Jun 2021

What Are Med Spas and What Regulations Apply?

Medical Spa

Med Spas have grown in popularity. These facilities often offer specialty specific services such as chemical peels or laser hair removal, while others provide a range of cosmetic services such as Botox, lip fillers, permanent makeup or laser treatments. According to the American Med Spa Association, a medical spa is defined as a hybrid of sorts between the traditional “day spa” and an aesthetic medical center.

The term “med spa” defines services that involve non-invasive or non-surgical aesthetic services and procedures that must be performed under the supervision of a licensed physician, plastic surgeon, dermatologist, and/or aesthetician. All procedures are to be performed under qualified, trained, and hopefully experienced practitioners and staff. On-site supervision by a licensed healthcare professional is mandatory.

Does your facility provide med spa treatments such as Cool Sculpting®, Botox®, or cosmetic procedures such as dermabrasion, dermaplaning, and derma fillers? Laser hair removal and hair replacement services are considered aesthetic medical procedures, as is liposuction to sclerotherapy to a ‘vampire facelift’. If yes, you are a healthcare waste generator - we're here to support you with education on safe disposal and management.



1 / Medical Waste Considerations

2 / Sharps Waste Management

3 / Pharma Waste Management

4 / Where to Find the Rules for Compliant Med Spa Waste Regulations

5 / What Rules You Need to Know

6 / How Daniels Health Can Support You

Medical Waste Considerations 

All such procedures as listed above produce medical waste. Is your facility compliant when it comes to medical waste considerations and disposal processes? Do your employees know how to identify which tools or equipment used in the procedures are deemed ‘regular’ or potentially ‘hazardous’ medical waste? Do they know how to properly dispose of sharps? Do you freeze fat cells?

Do you perform laser hair removal or offer Botox injections to remove wrinkles? Any services that are considered a medical procedure, such as those performed at a med spa, identifies your business as a medical facility. Your facility will generate medical waste. Therefore, segregating, packaging, labeling, and disposal of that medical waste must be compliant under state and federal guidelines in regard to healthcare waste management.


In many Med Spa scenarios, two primary types of waste are common: 

  • Sharps Waste - Needles and related sharps used for patient care 
  • Pharmaceutical Waste - Vials containing more than 3% drug volume or expired/partially used medications  


Let's dive in a little more.... 



About Sharps Waste Generated by Med Spas

The majority of Med Spas use sharps, which are considered to be anything that can poke, slash, pierce, or cut skin. When it comes to sharps in this business, sharps are most often applicable to needles, syringes, and potentially broken vials that contained chemicals or fillers. Do you know what to do with your needles and the proper process for sharps disposal? According to state and federal laws, sharps:

  • Must be disposed of in a compliant sharps container
  • Compliant sharps containers are leak-proof, puncture-proof, and resistant to crumbling or crushing during installation and transport, and have appropriate safety lids to reduce the risk of needlestick injuries
  • Must be emptied before they are full, typically when they are three-fourths full. The lids must remain closed, have a lid, and in some cases, must be locked
  • Proper location of sharps containers is a must – and definitely not in high traffic areas

According to the CDC (Stop Sticks Campaign), compliant sharps containers should be placed in an upright position in a visible location, within horizontal reach, but slightly below eye level. They are not to be placed near doors, near a light switch, under a sink, and so forth. It is also important that healthcare providers can easily view warning labels as well as determination of the container’s fill status.

Explore Daniels Health's reusable sharps container, the Sharpsmart, that excels above and beyond standard safety measures.


About Pharmaceutical Waste Generated by Med Spas


Med Spas have gained popularity due to their non-surgical cosmetic procedures that include Botox injections, laser vein therapy, laser hair removal, medical grade skin peels, skin rejuvenation, and so forth.

Any injectable such as those used at such facilities can be considered pharmaceutical waste. Such waste must be compliantly and properly disposed of according to state and federal regulations. That includes disposal of vials, bottles, or containers as well as sharps that can contain traces of injectable or fillers. They are not to be disposed of in a recycling bin or in the treatment room’s trashcan!

Medical waste involved in such procedures can include anything from syringes and needles to vials containing a number of chemicals, protective equipment, and tools used during the procedure. Such discarded healthcare products are classified as potentially hazardous waste.

It is a responsibility of the provider to determine identification of hazardous as opposed to non-hazardous waste pharmaceuticals. According to the EPA (40 CFR part 261 – Management Standards for Hazardous Waste Pharmaceuticals) a number of challenges in making such determination are present, including the fact that some active pharmaceutical ingredients might be listed as an acute hazardous waste, which are regulated in even small amounts. The rule implies that “it is the responsibility of the generator of a solid waste to determine if the waste is hazardous; this includes solid wastes that are pharmaceuticals… The generator must manage it in accordance with all applicable federal, state, and/or local environmental regulations.”


Where Can I Find the Rules for Compliant Med Spa Medical Waste Disposal?

Refer to the Resource Conservation and Recovery Act (RCRA) laws and regulations when it comes to compliant management of solid waste, including hazardous and non-hazardous waste. The website provides a wealth of information regarding regulations as well as policies and guidance documents for the identification and segregation of hazardous and non-hazardous waste.

An additional and invaluable resource for regulations regarding the generation, classification, management processes, and disposal of any potentially hazardous waste is found under the Code of Federal Regulations (CFR) Title 40 - Protection of the environment, which contains all regulations governing the programs of the Environmental Protection Agency. 


Know the Rules

Any employee working in a Med Spa must take responsibility for proper identification and segregation of any medical waste generated at the facility. That includes anything from sharps to medications to chemicals, personal protective equipment, and proper sterilization of tools and equipment. Guidelines of numerous federal agencies are applicable in such scenarios, including those of the:

  • Centers for Disease Control and Prevention (CDC)
  • Federal Drug Administration (FDA)
  • Occupational Safety and Health Administration (OSHA)
  • State-by-state regulations

Every employee of a Med Spa, like other facilities that provide medical services, should be able to identify the difference between healthcare waste streams. Such knowledge reduces the risks of fines and penalties associated with non-compliant medical waste disposal. Medical waste is defined into a handful of categories that include:

Each of these medical waste streams have guidelines for their identification, collection, transportation, and disposal based on state as well as federal guidelines. Refer to your state governmental agencies to determine your state’s rules for Med Spa medical waste. Keep in mind that state and federal laws must be followed. In some cases, state laws are more stringent than federal regulations and must be followed to the letter.

Turn to Daniels Health for Guidance

Daniels Health provides resources, education, products, and knowledge of state-by-state procedures for compliant and secure disposal of Med Spa medical waste that meet state and federal guidelines. We’re dedicated to reducing needlestick injuries through compliant sharps disposal, as well as reducing the volume of medical waste that is sent to landfills. Save money and ensure compliance by following the regulations. For more information on our services and products, visit our dedicated med spa waste disposal page or call Daniels Health today.

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Amy Piser

Amy Piser

Clinical Waste Educator

With 26 years experience working in healthcare, Amy has implemented sustainability initiatives for over 100 hospitals across the United States and brings unique practice and compliance expertise to healthcare waste management.