Three Biggest Medical Waste Compliance Risks Hospitals Face

Improper waste disposal has led to millions in fines for hospitals in recent years. Every hospital is at risk of non-compliant medical waste disposal given the volume and complexity of medical waste streams and the number of staff responsible for properly separating, handling, and disposing of waste. While there are upwards of 30 different waste streams at a hospital, these three are by far the greatest medical waste compliance risk facing hospitals today.

Improper Disposal of Regulated Medical Waste

Regulated medical waste includes any item saturated with blood or other potentially infectious material, sharps, trace chemo, and other unique kinds of pathological and pharmaceutical waste. Waste meeting this definition is generated in various volumes and forms from unit to unit within a hospital. While this waste stream only accounts for ~7% of the total volume of waste generated at a hospital, it must be the primary (but not the only) focus of medical waste separation training. Many hospitals have adopted best practices to reduce general trash from being disposed as regulated medical waste, such as smaller containers or red bag transport programs. However, in the heat of a clinical procedure while medical professionals are focused on providing adequate care, it only takes a quick second for this material to be disposed improperly in general trash containers if policies, equipment, programs, procedures, and training are not maintained. An interdepartmental effort is required to work with each unit of a hospital to identify common items that must be disposed of as regulated medical waste and ensure appropriate systems are in place.

Improper Disposal of Hazardous Waste

Hazardous waste is generated in various forms at a hospital including but not limited to hazardous pharmaceuticals, laboratory chemicals, batteries, and disinfectants and sanitizers. The guidelines for hazardous waste disposal can vary from state to state and can depend on the nature of item’s intended use. Many items considered hazardous for disposal are rather obvious, but in certain states, such as California, even some unused personal care products, like aluminum deodorant, that are given to a patient but only partially used, may need to be disposed as hazardous waste. Safety Officers at each hospital must maintain an accurate inventory of hazardous waste generated on-site to ensure that all waste profiles, signage, training records, manifests, and other required documentation is kept up to date. In addition, the Safety Department must work closely with other departments to maintain policies, procedures, and training to ensure proper identification, usage, and disposal of hazardous materials once on-site. This responsibility is becoming increasingly difficult as new medications, products, and devices are constantly being developed for and purchased by hospitals.

Improper Disposal of Confidential Information

The shift to digital medical records has reduced the total volume of confidential paper at hospitals, but the volume of paper and other items containing sensitive patient information still remains very high. Every hospital is required to have policies and training around the protection of patient information, but it’s non-paper items such as patient wristbands, patient labels on medications, and thermal printer ribbons along with non-clinical paper like dietary and central supply slips that can present the greatest compliance risks for improper disposal. Similar to Safety Officers with hazardous waste management, a hospital’s Compliance Office must engage in an ongoing, interdepartmental effort to ensure policies, procedures, equipment, training, and documentation are maintained. Even patients or visitors can dispose of sensitive information while on-site, so it’s important for Compliance Offices to consider the flow of all sensitive information when developing and maintaining their management systems.