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The University of Oklahoma Health Sciences Center EHSO Manual 2018-2019

9 - Biomedical Waste

 
A. Definitions
Biomedical wastes refers to any solid waste that is generated in the diagnosis, treatment, or immunization of human beings or animals, in research pertaining thereto, or in the production or testing of biologicals that is listed in the following paragraphs of this definition.
Biohazard waste, also known as, biomedical waste, biological waste, bio-waste, medical waste, controlled medical waste, regulated medical waste (RMV), physically dangerous medical or biological waste, potentially infectious biomedical waste, infectious waste, hospital/medical/infectious waste (HMI waste), etc.
• Cultures and stocks of infectious agents and associated biologicals, including: cultures from medical and pathological laboratories, cultures and stocks of infectious agents from research and industrial laboratories, wastes from the production of biologicals, discarded live and attenuated vaccines, and culture dishes and devices used to transfer, inoculate, and mix cultures.
• Human pathological waste, including tissues, organs, and body part and body fluids that are removed during surgery or autopsy, or other medical procedures, and specimens of body fluids and their containers.
• Human blood and blood products including:
1. liquid waste human blood;
2. products of blood;
3. items saturated and/or dripping with human blood; or 
4. items that were saturated and/or dripping with human blood that are now caked with dried human blood; including serum, plasma, and other blood components, and their containers, which were used or intended for use in either patient care, testing and laboratory analysis, or the development of pharmaceuticals. Intravenous bags are also included in this category.
• Sharps that have been used in animal or human patient care or treatment or in medical, research, or industrial laboratories, including hypodermic needles, syringes (with or without the attached needle), Pasteur pipettes, scalpel blades, blood vials, needles with attached tubing, and culture dishes (regardless of presence of infectious agents). Also included are other types of broken or unbroken glassware that were in contact with infectious agents, such as used slides and cover slips.
• Animal waste including contaminated animal carcasses, body parts, and bedding of animals that were known to have been exposed to infectious agents during research (including research in veterinary hospitals), production of biologicals or testing of pharmaceuticals.
• Isolation wastes including biological waste and discarded materials contaminated with blood, excretions, exudates, or secretions from humans who are isolated to protect others from certain highly communicable diseases, or isolated animals known to be infected with highly communicable diseases. 
• Unused sharps including the following unused, discarded sharps: hypodermic needles, suture needles, syringes, and scalpel blades.
• Examples of biomedical waste include:
1. cultures and stocks of infectious agents or live vaccines, and culture dishes, devices, paper, and cloth that have come into contact with such cultures, stocks, or live vaccines;
2. biological tissues;
3. plasmids, cultures, tissues, or other molecules containing recombinant or synthetic nucleic acid molecules;
4. human blood, blood products and human body fluids, except urine or feces;
5. pathological wastes consisting of human tissues, organs, and body parts removed during surgery, autopsy, biopsy, and other medical procedures;
6. contaminated sharps including hypodermic needles, syringes, (with or without the attached needle), Pasteur pipettes, scalpel blades, suture needles, and needles with attached tubing and other types of broken or unbroken glassware that have come in contact with infectious agents (such as used slides and cover slips); 
7. untreated sharps;
8. used blood collection bags, tubes, and vials;
9. animal carcasses and body parts, and contaminated bedding;
10. items contaminated with blood or other human body fluids which drip freely or would release such materials in a liquid or semi-liquid state if compressed or are caked with dried blood or body fluids and are capable of releasing these materials;
11. isolation wastes, unless determined to be non-infectious by the infection control  committee at the health care facility;
12. HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.
13. all disposable materials that have come in contact with cytotoxic or antineoplastic agents or other hazardous drugs during the preparation, handling, and administration of such agents. Such wastes include, but are not limited to masks, gloves, gowns, empty IV tubing and bags, vials, and other contaminated materials; and 
14. any other material or contaminated equipment which, in the determination of the facility infection control staff or Institutional Biosafety Committee, presents a significant danger of infection because it is contaminated with, or may reasonably be expected to be contaminated with, etiologic agents.
 
B. Treatment Methods
Untreated biomedical waste should not be disposed of in the municipal waste stream. All biomedical waste, excluding sharps and syringes must be treated by steam sterilization or chemical disinfection before disposal in the municipal waste stream.
• Off-Site Treatment/Incineration
1. Red biohazard bags or sharps containers should be placed in a cardboard box labeled with the biohazard symbol for shipment through an appropriate biomedical waste disposal vendor for off-site treatment or incineration. The box must be obtained from the vendor. Contact the EHSO to verify that Stericycle is the current vendor.
2. Boxes containing biomedical waste that should be incinerated rather than other treatment methods should be labeled with “incinerate only” on both sides of the container. Such labels are available from the vendor or the EHSO.
3. Packaging, labeling, and manifesting this waste must follow the procedures in this Section labeled “Regulated Medical Waste Shipping Procedures.” 
 
• Steam Sterilization 
1. Biomedical waste that is to be steam sterilized should be collected in biohazard bags and transported to the sterilization site in a durable, leak-proof container which is closed for transport from the laboratory.
2. Sterilization should be validated using methods described in this Section labeled, “Autoclave Sterilization Validation.”
3. After sterilization, but before disposal in the municipal waste stream, all treated biomedical wastes should be enclosed in an unmarked out bag or box that is not red or labeled with the biohazard symbol. Any biomedical waste that has been treated as described above and packaged such that it is clearly evident that the waste had been effectively treated is not subject to regulation as biomedical waste and may be collected, transported, and disposed of as municipal waste.
 
• Chemical Disinfection                                                                                                   Chemical or liquid disinfectants may be used for treatment of biomedical waste, however several considerations should be made when contemplating the use of chemical disinfectant for the contamination of liquid wastes in the laboratory. 
1. The concentration of disinfectant must be the one manufacturer recommends.
2. The amount of organic matter that is present in the liquid. The nutrients and waste materials, as well as the increased numbers or organisms, all contribute to the effectiveness of the chemical disinfectant.
3. The time required to inactivate the organisms in the waste liquid.
4. Chemical disinfectants are hazardous chemicals and consideration of the method of disposal of the decontaminated material must be made.
5. Importantly, consideration for demonstrating the efficacy of the disinfection process for the contaminated item(s).       
6. Biomedical waste that has been effectively treated can be disposed of into the regular solid waste receptacle unless the material qualifies as “sharp”, in which case the material should be placed in a puncture-proof container (not labeled with the biohazard symbol) prior to disposal.
7. Certain chemical disinfectants, such as bleach and alcohol, can be poured down the sink after being used for treatment. Other disinfectants, such as phenol and glutaraldehyde, require management as a hazardous waste (see procedures in Section V). The management after use should be considered when selecting chemical or liquid disinfectants.
a. If chemical disinfectants are used, they must have been shown to be effective against the organism present. Important considerations include:
1) temperature;
2) time of contact;
3) pH;
4) concentration;
5) penetrability; and 
6) reactivity of organic material at the site of application (for example, for blood or media containing significant organic material, autoclaving should be considered instead).
b. Chemical disinfection may not be used for: Chemical disinfection may not be used for:
1) porous material;
2) material embedded with infectious agents, such as agar plates;
3) mixed waste, such as material that is both biomedical and radioactive waste;
4) hazardous drug waste;
5) pharmaceutical waste; or
6) contaminated sharps collected in a sharps container.
c. Use manufacturer’s specifications and procedures when using chemical disinfectants.
 
C. Guidelines for Disposal
• Ethidium bromide, antineoplastic/cytotoxic agents, controlled substances, hazardous drugs, and associated solid wastes require special disposal by incineration. See Section V., “Hazardous Waste”.
• If any infectious waste is also a chemical waste, call the EHSO for assistance with disposal after disinfection.
• Biomedical wastes that are also radioactive should be treated according to requirements for both biomedical and radioactive wastes. Contact the OU Radiation Safety Office (RSO) at 405-271-6121 for appropriate procedures.
• Prior to any treatment, all biomedical wastes, including those to be incinerated, should be enclosed in a puncture-resistant, red biohazard bag that is color coded or labeled with the biological hazard symbol.
• All sharps intended for disposal, whether contaminated or not, must be enclosed in a specially designed sharps container. 
1. Needles should not be clipped or recapped before being placed in a sharps container.
2. The sharps container should be:
a. puncture-resistant,
b. leak-proof on the sides and bottom,
c. color-coded or labeled with the biohazard symbol, and 
d. only filled to 2/3 full, do not fill sharps container above recommended fill line,
e. should be selected with consideration of appropriate safety features, such as lids that lock tight for safe disposal.
• Contaminated sharp containers and glassware should be sent for incineration. Place sharp containers inside a Stericycle biomedical waste box, then contact the vendor for pick-up. Be sure to contact the EHSO to verify biomedical waste disposal vendor.
• Untreated biomedical waste is not to be disposed of in the municipal waste stream. All biomedical waste, including sharps and syringes must be treated by incineration, steam sterilization, or chemical disinfection before disposal in the municipal waste stream. 
1. Off-Site Treatment/Incineration
a. Red biohazard bags or sharps containers should be placed in a cardboard box labeled with the biohazard symbol for shipment through an appropriate biomedical waste disposal vendor for off-site treatment or incineration. The box must be obtained from the vendor. Contact the EHSO to verify that Stericycle is the current vendor.
b. Boxes containing biomedical waste that should be incinerated rather than other treatment methods should be labeled with “incinerate only” on both sides of the container. Such labels are available from the vendor or the EHSO.
c. Packaging, labeling, and manifesting this waste must follow the procedures in this Section labeled “Regulated Medical Waste Shipping Procedures.” 
2. Steam Sterilization 
a. Biomedical waste that is to be steam sterilized should be collected in biohazard bags and transported to the sterilization site in a durable, leak-proof container which is closed for transport from the laboratory.
b. Sterilization should be validated using methods described in this Section labeled, “Autoclave Sterilization Validation.”
c. After sterilization, but before disposal in the municipal waste stream, all treated biomedical wastes should be enclosed in an unmarked out bag or box that is not red or labeled with the biohazard symbol. Any biomedical waste that has been treated as described above and packaged such that it is clearly evident that the waste had been effectively treated is not subject to regulation as biomedical waste and may be collected, transported, and disposed of as municipal waste.
3. Chemical Disinfection                                                                                
a. Chemical or liquid disinfectants may be used for treatment of biomedical waste where contact time, concentration, and quantity of the chemical disinfectant are sufficient to achieve microbial inactivation of the waste.
b. Chemical disinfection may not be used for:
1) porous material;
2) material embedded with infectious agents, such as agar plates;
3) mixed waste, such as material that is both biomedical and radioactive waste;
4) hazardous drug waste;
5) pharmaceutical waste; or
6) contaminated sharps collected in a sharps container.
c. If chemical disinfectants are used, they must have been shown to be effective against the organisms present. Important considerations include: 
1) temperature;
2) time of contact;
3) pH;
4) concentration;
5) penetrability; and 
6) reactivity of organic material at the site of application (for example, for blood or media containing significant organic material, autoclaving should be considered instead).
d. Use manufacturer’s specifications and procedures when using chemical disinfectants.
1) Biomedical waste that has been effectively treated can be disposed of into the regular solid waste receptacle unless the material qualifies as “sharp”, in which case the material should be placed in a puncture-proof container (not labeled with the biohazard symbol) prior to disposal.
2) Certain chemical disinfectants, such as bleach and alcohol, can be poured down the sink after being used for treatment. Other disinfectants, such as phenol and glutaraldehyde, require management as a hazardous waste (see procedures in Section V). Management after use should be considered when selecting what chemical or liquid disinfectants.
Sources: Oklahoma Department of Environmental Quality Solid Waste Management Rules, OAC 252:515 Subchapter 23                     Department of the Army Biological Defense Safety Policy and Procedures (32 CFR 627.33)
D. Autoclave Procedures
• Select appropriate container/bags for autoclaving
• For biohazardous dry materials:
1. Use polypropylene (clear) bags or reusable autoclavable (Nalgene) containers. Make sure your plastic bag or container is suitable, since not all plastics can be autoclaved (i.e. polyethylene or HDPE). They can melt and ruin the autoclave chamber.
2. Ensure that contaminated materials are free of sharp objects that may puncture the bags. Autoclave bags are tear resistant, but can be punctured or burst in the autoclave.
3. Fill bags only 2/3 full. Add one cup of water to each bag of solid waste. Ensure adequate steam penetration by closing bags loosely, leaving a small opening and closing with autoclave indicator tape.
4. Do not autoclave sharps containers. Contact Stericycle for pick-up or EHSO for vendor contact information.
• For biohazardous liquids (or non-biohazardous liquids):
1. Fill liquid containers only ½ full. Loosen caps or use vented closures.
2. Never put sealed containers in an autoclave! They can explode. Large bottles with narrow necks may also explode if filled too full of liquid.
• For non-biohazardous glassware/labware:
1. Cap Pyrex bottles loosely whether empty or filled to prevent explosions due to expansion.
2. Cover bottles that are not made of safety glass (e.g. not Pyrex) with aluminum foil.
• Place all items in a secondary container (plastic or stainless steel bin) before autoclaving.
1. Make sure your plastic, secondary container is suitable for autoclaving. Not all plastics can be autoclaved (i.e. polyethylene or HDPE). Polypropylene or polycarbonate tubs are typically used for secondary containment.
2. Select a container with the lowest sides and widest diameter possible for the autoclave. This will promote penetration of steam and will collect any leakage or overflow of liquids.
3. Do not overfill the tubs. Nothing should hang over the edges or be tall enough to touch the top or sides of the autoclave. Overloading may lead to the center of the load not getting sterilized properly.
4. Place tubs in the center of the autoclave. Leave space between items/bags to allow steam circulation. Add a quarter to a half-inch of water to a tub of empty bottles that are to be autoclaved. This will allow the bottles to heat more evenly.
• Select the correct autoclave cycle for your materials
1. Know the contents of the bags in order to know which cycle to use, then use the proper cycle. Do not use a gravity cycle for liquids nor a liquid cycle for solids. Use of the wrong cycle can cause improper sterilization or spillage.
2. Do not adjust the temperature or run time. Increasing the temperature can melt trays or containers. Decreasing the temperature or run time can impair the sterilization process. Most pre-set programs can accomplish what you need without adjusting the time or temperature.
• Check the drain screen and close the autoclave door properly
1. Check the drain screen at the bottom of the chamber before using the autoclave. For efficient heat transfer, steam must flush the air out of the autoclave chamber. If the drain screen is blocked with debris, a layer of air may form at the bottom of the autoclave and prevent proper operation. Clean out any debris.
2. Make sure the door of the autoclave is properly closed before starting the cycle.
• Fill out the autoclave book
1. Each unit used to decontaminate must have an autoclave log where the operator records the date, name, cycle time, and monthly biological indicator results.
• Follow these precautions when the autoclave cycle is finished
1. Never open an autoclave until the cycle is complete. Superheated liquids can boil over and damage the autoclave and injure the operator.
2. Do not override the autoclave’s built-in safety control features under any circumstance (contact Site Support for assistance).
3. Wait a full 5-10 minutes before removing items after the completion of a run.
4. Wear personal protective equipment (PPE)
a) Lab coat or apron
b) Eye protection
c) Closed-toed shoes
d) Heat-resistant gloves to remove items, especially hot glassware
5. Open the door cautiously. Stand behind the door and slowly open it. Allow all steam to escape before reaching inside.
6. Let liquids stand another 10-20 minutes after the autoclave is opened to avoid any movement that could cause them to boil, or boil over.
7. Close the autoclave door after each use.
• Properly dispose of autoclaved waste
• Biomedical
1. Biomedical waste that has been autoclaved may be disposed as regular trash. Place the autoclave bag into an opaque or black trash bag and leave it for housekeeping to pick-up.
• Perform sterilization validation test monthly
1. The 3M Attest 1262 Biological Indicator (brown cap) is designed for monitoring steam sterilization validation processes. This product contains Geobacillus stearothermophilus spores and must be used at least once a month to monitor the efficiency of sterilizer performance.
2. Place the spore strips or package in a full load in the most challenging area for the sterilant to reach. This is generally on the bottom shelf, near the door, and over the drain.
3. Place autoclave tape on several items in the load (e.g. bottles, tubes, flasks, pipette tip boxes).
4. If the processed spore strips indicate microbiological growth, contact the person in charge of the autoclave.
5. Process the load as usual, selecting typical cycles and times (gravity cycle for biohazardous waste).
6. Open the door for a minimum of 10 minutes prior to removing the biological indicator to allow for a brief cooling period. Warning: Crushing or excessive handling of the biological indicator before cooling may cause the glass ampule to burst which may result in personal injury from flying debris. Use safety glasses and appropriate gloves (heat-resistant and puncture-resistant) when removing or intentionally crushing biological indicator.
7. Incubate the biological indicator within 2 hours or as recommended by the manufacturer. Use a negative control during incubation which can be a fresh biological indicator from storage.
8. Examine the biological indicator at regular intervals during incubation (e.g., 8, 12, 18, 24, and 48 hours) for any color change. For example, most biological indicator will change color from pink to yellow (a positive read). Yellow usually represents bacterial growth whereas no color change (pink) indicates a negative read and adequate sterilization process.
9. Observe and document results of the run to determine if the sterilization process parameters successfully produced negative biological indicators and chemical indicators with complete end point color changes.
10. Record data on a separate test log including biological indicator lot number and expiration date, incubation conditions, observations, and results.
11. Notify your supervisor and person in charge of the autoclave of any positive test results as soon as the first evidence of growth is noted.
12. If changes are made to the autoclave (repair/inspection), the first load run in the autoclave should be tested with a biological indicator to insure proper functioning of the autoclave
• An autoclave will only work if it is used properly and safely. There are potential physical and biological hazards associated with improper use, as well as the potential for contamination of the research being performed and damage of the equipment. Follow these procedures to minimize these hazards.
1. If the autoclave has an Autoclave Use Log, complete it before every use of the autoclave.
2. If the autoclave is dirty, contact the previous user to clean the machine. DO NOT USE the autoclave until it is cleaned. Clean the drain strainer before loading the autoclave.
3. Place all items in a tub before autoclaving. Never place glassware of bags directly on the bottom or floor of the autoclave. Place items inside a heat-resistant plastic tub that will sit on a shelf or rack. Ensure tubs are not cracked.
4. Do not overfill the tubs. Nothing should hang over the edges or be tall enough to touch the top or sides of the autoclave. Overloading may lead to the center of the load not getting sterilized properly.
5. Place tubs in the center of the autoclave. It is important to allow the steam to circulate freely throughout the chamber.
6. Never autoclave a sealed container of liquids. Before loading containers of liquids into the autoclave, the caps must be loosened to ensure proper sterilization and to avoid having the bottles shatter during pressurization or when the container is opened.
7. Add a quarter- to a half-inch of water to a tub of empty bottles that are to be autoclaved. This will allow the bottles to heat more evenly.
8. For solid waste, do not pack the bags too full; bags packed to capacity with biohazardous waste will not be properly decontaminated.
9. Add 1 cup of water to each bag of solid waste and keep the bags open. Polypropylene biohazard bangs are impervious to steam.
10. Do not load non-autoclavable plastic materials into the autoclave. They will melt and cause damage to the autoclave.
11. Make sure the door of the autoclave is properly closed before starting the cycle.
12. Know the contents of the bags being placed in the autoclave in order to know which cycle to use, then use the proper cycle. Do not use a gravity cycle for liquids nor a liquid cycle for solids. Use of the wrong cycle can cause improper sterilization or spillage.
13. Be sure you know what you are doing if you want to adjust the temperature or run time. Increasing the temperature can melt trays or containers. Decreasing the temperature or run time can impair the sterilization procedure. Most pre-set programs can accomplish what you need without adjusting the time or temperature.
14. Do not override an autoclave’s built-in safety control feature under any circumstance!
15. Do not abort a run just because you are in a hurry and want the cycle to finish faster. Aborting of cycles can cause the sterilizer to jam, if it happens often, requiring a service call to get the autoclave running again.
16. Wait a full 5 – 10 minutes before removing items after the completion of a run. If the autoclave load contains dry glassware wait 5 minutes and if the load contains liquids, wait 10 minutes.
17. Wear heat-resistant gloves when first opening the door after a run. When removing items from the autoclave, wear a rubber apron in addition to rubber sleeve protectors, heat-resistant mitts, and a face shield.
18. Let glassware cool for 15 minutes before touching it with ungloved hands.
19. Let liquid loads stand in an out-of-the-way location for a full hour before touching with ungloved hands. With liquid loads, be alert for a bottle still bubbling.
20. Close the autoclave door after each use.
 
E. Autoclave Sterilization Validation
Sterilization failure can result from a number of factors including improper loading, insufficient time and/or temperature, or equipment failure. Therefore, it is important to ensure that complete sterilization of biomedical waste has occurred prior to disposal. The use of a biological indicator is the most reliable method for this determination.
• It is recommended that spore strips inoculated with Geobacillus stearothermophilus, Bacillus atrophaeus or other suitable and reliable biological indicators be used at least once per week to monitor the adequacy of sterilizer performance. Some commercial spore strips have a color change indicator. This color change does not indicate that sterility was achieved, only that minimal process parameters were attained. Do not rely on this color change to ensure sterilization.
• Place the spore strips in the middle or most inaccessible portion of the autoclave load, preferably inside a filled biohazardous waste bag. One way to be able to safely remove the strip from the load after autoclaving is to place a fresh spore strip inside a glass screw cap tube. Tie a string around the neck of the tube. Bury the tube in the center of the load as you build it. Thread the string out of the top of the bag. After the cycle is completed, you can pull on the string to retrieve the spore strip for incubation.
• Process and incubate the spore strips according to manufacturer or vendor procedures.
• If the processed spore strips indicate microbiological growth, first try increasing the run time or verifying the waste is properly loaded. If growth still occurs with run times of 45 minutes or more, the autoclave may need maintenance or repair. Notify the Physical Plant or department technician as soon as possible and do not use the autoclave until it has been repaired. Maintenance and/or repair may need to be completed by a manufacturer’s technician if University personnel cannot fix the problem. Notify others who may use the equipment as well.
• Record all spore strip results in a permanent location. 
Sources: Principles and Methods of Sterilization, “Sterilizer Controls, Sterilization Indicators, and Culture Tests” AMSCO Product Literature
F. Regulated Medical Waste Shipping Procedures
If the biomedical waste is to be shipped for disposal through a qualified biomedical waste disposal company, the Department of Transportation (DOT) requires additional training on the following information for these persons packing, shipping, or signing the documentation for such shipments.
• Definitions
1. Regulated Medical Waste (RMW) is “a waste or reusable material medical treatment of an animal or human, which includes diagnosis and immunization, or from biomedical research, which includes the production or testing of biological products.” Regulated medical waste may not include laboratory cultures of Class A organisms (see the University of Oklahoma Shipping Biological Materials Manual or contact the EHSO for a description and list of Class A organisms).
2. Sharps are “any object contaminated with a pathogen or that may become contaminated with a pathogen through handling or during transportation and also capable of cutting or penetrating skin or packaging material. Containers must be properly closed and lidded prior to transport. Sharps include; needles, syringes, scalpels, broken glass, culture slides, culture dishes, broken capillary tubes, broken ridged plastic, wood shaft cotton swabs, and exposed ends of dental wires.” Sharps (including syringes, even if the needle has been removed) must be placed in sharps containers prior to shipment for disposal.
 
• Packaging Procedures
DOT requires that RMW be packaged properly for shipment as follows.
1. It is the responsibility of the generator to make sure that biomedical/regulated medical waste bags are closed properly by one of the following three methods. These methods will seal the bag closed such that no fluid or other material may escape when the bag is turned upside down.
a. Twist the open end and tied the end into one knot. (Do not tie alternate corners into knots. This will not appropriately close the bag.)
b. Twist the open end and fold it over into a gooseneck. Tape the folded end shut with duct tape.
c. Use a twist tie that is of sufficient length and strength which will effectively close the bag.
2. The closed bag or sharps container must then be placed in an appropriate outer (secondary) container for shipment. Containers (boxes/tubes) provided by the current vendor will meet the requirements. Do not try to use containers/boxes not supplied by the current vendor. The requirements for the container are that it must:
a. be made of rigid material (plastic or cardboard),
b. be impervious to outside moisture,
c. be able to prevent tearing or bursting under normal use,
d. be puncture-resistant for loose sharps,
e. have no visible leaking or external contamination,
f. not be ruptured or damaged in any way,
g. not have objects protruding from the container, and 
h. not be overfilled.    
3. If liquids are present in the waste, the container lids must be tightly lidded or stoppered and the secondary container must contain sufficient absorbent material that is enough to handle 150% of the fluid amount inside the container.
4. The outer packaging is required to have the following markings:
a. Regulated Medical Waste
b. UN 3291
c. The word “BIOHAZARD” and a black biohazard symbol
5. The maximum material weight limit of any single red bag is 22 pounds. A 28 gallon container (tub) must not weigh more than 60 pounds.
 
• Shipping Documents/Manifests
DOT requires that all hazardous materials be accompanied by shipping documents, also known as manifests. The main purpose of these is to provide clear communication in the event of an emergency when the hazardous material is in transit. It is very important that they are complete, correct, and have the following information:
1. Proper shipping name: “Regulated Medical Waste, n.o.s.” (not otherwise specified)
2. Hazard Class: “6.2”
3. Identification #: UN 3291
4. Packaging Group: PG II
5. Quantity of material shipped – weight or volume
6. Emergency response number (must be attended at all times during the shipment)
7. Shipper’s certification (generator signature)
a. Only persons knowledgeable about the package and trained in the DOT shipping requirements for RMW should sign the manifests (it is a violation of DOT regulations to have an untrained person sign the manifest).
b. Copies of the manifest must be retained and be easily retrievable for a DOT inspector for two years.
 
• Hazardous Materials/RMW Security
Many materials that are classified as hazardous materials are essential products to research and industry, but potential deadly weapons in the hands of a terrorist. In the wake of increased concerns over terrorist threats and attacks, shippers and carriers who offer transport or store hazardous materials have an increased responsibility to safeguard personnel, facilities, and the hazardous materials themselves. Lost, stolen, or unprotected hazardous materials may be used for malicious acts that can cause harm, destruction, or other illegal activities. There is additional concern that during a biological event, such as an outbreak of pandemic flu, SARS, smallpox, etc., a potential terrorist strategy could be the theft of potentially infectious waste resulting from the care of such patients. Many potential terrorists do not fit a preconceived picture of a criminal. Many have been known to live and work within the community for years before carrying out an actual attack. Disgruntled employees or patients may also be persons who may carry out acts of violence. For this reason, security of hazardous materials, including RMW, constitutes an essential component in protecting employees, students, the public, and the environment. These procedures should be followed. 
1. Packages containing hazardous materials should be properly identified and accounted for at all times. Hazardous materials must never be left unsecured. Materials are considered secure if they are in the possession of a trained employee or secured within a controlled, locked area. Control measures include:
a. Don’t prop open doors to areas where hazardous materials are stored or used.
b. Account for and secure keys and access codes. Don’t leave them unattended or give to unauthorized persons.
c. Report lost keys.
d. Be aware of unfamiliar persons or visitors.
e. Report tampering with doors, locks, etc.
f. Avoid discussions with strangers about the storage location and shipment dates of hazardous materials.
g. Report any missing hazardous materials to OU Police immediately.
2. Recognition of dubious actions ranks as a primary guard in keeping hazardous materials secure. Immediately report suspicious activities to OU Police. Examples of suspicious activities include:
a. Observing a person monitoring or casing buildings or operations. The person may be taking pictures or notes, using binoculars, drawing maps, or collecting information by other means.
b. People in buildings or areas who do not appear to be conducting legitimate business (loitering, etc.).
c. Unauthorized personnel in restricted, sensitive, or private areas.
d. Repeatedly seeing an unknown vehicle in a sensitive area without an explanation.
e. Noticing repetitive suspicious activities by the same person or vehicle.
f. Break-ins or noticing signs of attempted break-ins to sensitive areas.
 
 
 
 
 

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