Have the procedures for disinfecting the biological waste at your facility been reviewed and approved as required by the State Sanitary Code?
105 CMR 480, Minimum Requirements for the Management of Medical or Biological Waste (State Sanitary Code Chapter VIII), promulgates requirements for the storage, treatment, disposal, and transportation of medical or biological waste. There are numerous stipulations in the Sanitary Code, including the four disinfection methods approved for rendering medical or biological waste noninfectious. Not only are there specific methods approved for disinfection, but there are validation and recordkeeping requirements established for the approved methods. Many facilities generating biological waste are required to have their Institutional Biosafety Committee review the public health and environmental risks associated with biotechnology-by-product effluents generated at their facility. It is important to properly document the discussions held at IBC meetings regarding the waste treatment procedures. Remember, if it is not documented, there is no way to show a regulatory authority that it happened!
Although approved disinfection methods are established in the Sanitary Code, it is the responsibility of the organization to establish institutional policies appropriate for the waste generated, and comply with them. Compliance not only includes following the disinfection methods, but also complying with the recordkeeping requirements. Training all generators of biological waste on the established institutional policies is critical, as well as explaining why EHS personnel have to be notified of any proposed changes to the disinfection procedures. Employees preparing biological waste for off-site treatment and disposal should attend additional training.