San-i-pak - Articles & Issues

Background:The National Institute for Occupational Safety and Health (NIOSH) conducted an evaluation of the Stericycle, Inc. medical waste processing facility in Morton, WA in response to an outbreak of tuberculosis (TB) among employees at Stericycle. The follow up report, “Health Hazard Evaluation Report” (HHE) was published in October 1998 and identified several factors present in the Stericycle facility that could contribute to employee exposures to pathogens potentially present in the medical waste. The report concluded, “Stericycle should require laboratory facilities to decontaminate infectious cultures prior to disposal”.

Tuberculosis: In 1997, OSHA published its proposed standard to regulate occupational exposure to tuberculosis. After the NIOSH investigation of the Stericycle plant and the follow up HHE, OSHA reopened the rulemaking record to specifically address the potential for significant occupational exposure to TB at medical waste treatment facilities (Docket H-371, June 17, 1999).

Comments: In response to the reopening of the rulemaking record on occupational exposure to TB, several written comments were received.

NIOSH commented as follows: “A more appropriate and efficient prevention method would be to require facilities, such as laboratories or clinics, to decontaminate materials potentially contaminated with viable TB bacteria (e.g., cultures, stocks, or tissues) at the site where they are processed prior to sending them offsite for disposal”.

The Medical Waste Institute who represents private and public companies that treat, handle, dispose of medical waste, including Stericycle, Inc. commented: “cultures and stocks of Mycobacterium tuberculosis and other active cultures should be decontaminated at the point of generation”.

Centers for Disease Control: The 4th Edition of “Biosafety in Microbiological and Biomedical Laboratories” published by the CDC in 1999 states “Infectious waste from BSL-3 laboratories should be decontaminated before removal for off-site disposal”.

Department of Transportation (DOT): Regulated Medical Waste is considered a Hazardous Material by the DOT, and generators are required to comply with hazardous materials regulations for off-site transportation and abide by stringent packaging, labeling and manifesting requirements. Additionally, the DOT has imposed stricter packaging and transportation standards for waste cultures and stocks of infectious substances. Specifically, waste cultures and stocks must be transported by contract carriers in containers that meet DOT’s UN Packaging Group II requirements. Alternatively, treatment of these materials on-site prior to transportation and disposal would eliminate the need to comply with these complex DOT standards.

Conclusion: It is clear that as a matter of compliance as well as concern for worker and public health, laboratory wastes that may contain infectious substances should be treated in the laboratory or hospital prior to shipment off-site for disposal.