Sticking to the rules isn’t always easy, especially when it comes to healthcare waste management. Medical waste management involves healthcare waste segregation and knowing the difference between one waste stream and another, and waste audit procedures.

In addition to federal guidelines covering medical waste disposal are state guidelines. Every state has regulations regarding how medical waste is to be disposed of. In the state of Michigan, medical waste regulations are under the purview of the Department of Environmental Quality (DEQ). Some states don’t have many regulatory guidelines, although they do follow guidelines provided by the Environmental Protection Agency (EPA).

Michigan is very specific about how medical waste is to be disposed of, and a number of administrative rules are applicable. So too is the basic foundation of the Medical Waste Regulatory Act.

Daniels Health has covered guidelines to a number of states in regard to medical waste regulations, and Michigan is among the first we’ve come across that provides a “pocket reference” brochure published by the Michigan Department of Environmental Quality Waste Management and Radiological Protection Division. The pocket reference covers regulations found under Part 138 of the Public Health Code, Public Act 368 of 1978. Of course, they do caution that the pocket reference doesn’t replace “the need for owners and operators of medical waste producing facilities to understand the law.”

Understanding rules and regulations is the responsibility of the waste generator. There are no excuses applicable to these regulations such as “I didn’t understand” or “I wasn’t aware of that”.

Michigan also prevalently makes available its guidelines and regulations when it comes to medical waste. Governing laws and regulations can be found in the following sources:

• Medical waste: Medical Waste Regulatory Act (MWRA)
• Michigan Compiled Laws and Regulations(MCL) 333.13801 to 333.13831
• Michigan Administrative Code (MAC)r. 325.1541 to 325.1549

Michigan’s medical waste laws cover a variety of topics and even provide regulations for the development of a medical waste management plan (MCL 333.13817 to 8.13819). Again, no excuses! They also cover topics involved in the containment of medical waste.

But wait, there’s more. They also cover specifics in regard to transportation such as

• Handling
• Segregation
• Packaging

The importance of training is not to be ignored, nor are questions most often asked by a number of healthcare facilities such as veterinary facilities, pharmacies, hospitals, trauma cleanup companies, and tattoo parlors. The document, clarifying medical waste statutes and rules interpretations was created by the Waste Management-Medical Waste Regulatory Program and is provided by the Michigan Department of Environmental Quality (DEQ) from their Michigan.gov website.

A number of important and commonly asked questions are found in this document, such as whether a facility that generates a very small amount of medical waste is required to register as a medical waste producing facility? In Michigan, the answer is yes. No exemptions are allowed in waving responsibilities and registration for any facility that produces any amount of medical waste. This also includes businesses that lease space or suites in an office building owned by a separate business entity, such as a large hospital system. Such businesses are required to obtain separate registrations for each facility that generates any amount of medical waste.

In Michigan, tattoo parlors or any business that utilizes disposable sharps, blood saturated gauze, and so forth must also maintain compliance and register as a medical waste producing facility. In addition, body art facilities are also subject to 2007 PA 149, with requirements for permits also falling under guidelines of the Blood-borne Infectious Disease Standard.

Medical waste management in Michigan

Michigan’s Department of Environmental Quality also provides a free template for a medical waste management plan that ensures compliance with the Medical Waste Regulatory Act (MWRA) that aids facilities in defining types of medical waste as well as segregation, packaging, labeling, and collection procedures used for each type of medical waste generated by facility.

For example, regulations stipulate that sharps are to be disposed of in a compliant (leak-proof, puncture-resistant, rigid) and appropriately labeled sharps container before they’re stored or removed by a medical waste disposal service. Sharps containers are not to be stored for longer than 90 days at any facility, with the start date applicable to the day container is first used.

Any solidified bloodied item or an item that is saturated with blood or other infectious materials are to be placed in biohazard bags prior to removal.

Topics regarding on-site medical waste management is also covered. For example, Michigan stipulates that medical waste generated at a waste generating facility must be incinerated by a medical waste disposal company. However, on-site autoclaving decontamination of medical waste generated at a facility is acceptable, as long as such methods are compliant with federal and state regulations before transportation by a biomedical waste business, and the same applies to incineration.

When it comes to incineration, Michigan also provides access for resources for governing laws and New Source Performance Standards (NSPS) for incinerators, found in the federal code starting at 40 CFR 60.50 (applicability and designation of affected facility) through 60.55. (Medical waste plan).

Standards are applicable for national emission standards for hazardous air pollutants, general requirements, as well as emissions guidelines for medical waste incineration, manifests, hazardous waste transporters, and pharmaceutical hazardous waste.

The state of Michigan currently approves several alternative treatment technologies in addition to autoclave and incineration such as chemically treated medical waste, thermal inactivation, dry heat, and autoclave maceration, shredder, and microwave shredder technologies.

Medical waste generators must be familiar with medical waste categories as defined by the state of Michigan which include:

• Cultures and stocks
• Pathological waste
• Liquid human and animal waste
• Sharps
• Contaminated animal waste

The devil is in the details and the rules are detailed! For example, Rule 325.1543 specifies treatment of medical waste. Blood and blood products as well as solidified body fluids that have not been decontaminated must be packaged and disposed of as medical waste. We remind you to refer to the Public Health Code, Public Act 368 of 1978 (as amended).

Know your state regulations

Daniels Health knows that reading through pages and pages of regulations can be mind-numbing, but each and every law must be followed to maintain compliance.

Daniels Health provides long-term, sustainable, and effective solutions when it comes to healthcare waste management and healthcare waste disposal that keep you and your facility compliant in the state of Michigan. Ask how we can help you with your medical waste, segregation, or waste audit procedures. Call us today.

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