Documenting medical waste disposal is a key practice in any healthcare waste disposal program. This documentation serves as confirmation that you’ve properly segregated, stored, and handed off the waste to a responsible party. Furthermore, it organizes data on your waste generation, compliance training, and corrective actions, signifying your dedication to maintaining a compliant medical waste disposal program. Let’s review what you need to include in your medical waste disposal documentation.
Regulatory Requirements for Waste Disposal Records
Maintaining compliance with the various governmental agencies that oversee the proper disposal of medical waste is no easy task. These agencies set forth guidance for every step of the hazardous waste disposal process, including documentation and maintaining an audit trail for medical waste.
If you haven’t already, review the regulatory requirements put forth by federal and state departments.
Who is Responsible for Documenting Medical Waste Disposal?
Within your organization, all staff are responsible for participating in the safe and compliant disposal of all non-hazardous and hazardous medical waste. However, the staff person responsible for signing the medical waste disposal manifest carries the responsibility of appropriately documenting all waste processes.
If you’re not sure who the responsible party in your organization is, be sure to reach out and discuss it with your management team.
Legal Requirements for Waste Documentation
The legal repercussions of failure to properly document medical waste disposal are steep. They include fines that can quickly add up into the millions, prison time, and loss of licenses.
For more detailed information on the legal ramifications of non-compliant healthcare waste disposal, check out this handbook.
Documenting Medical Waste Disposal
Your non-hazardous and hazardous waste disposal program should include adherence to best practices for waste documentation and record management. Let’s take a look at what you need to document, tracking documents, and how long to maintain your files.
What Medical Waste Information to Track and Document
Each healthcare facility waste tracking system will include information required by regulatory agencies and the organization itself. Document information such as:
- Audit outcomes
- Staff training
- Waste management policies and procedures
- Medical waste removal schedules
- Waste generation streams
- Type and volume of waste generated
- Copies of any relevant permits and licenses
- Contact information for your medical waste disposal company
- Copies of Medical Waste Manifests
- Certificates of Destruction
Be sure to keep all your records in a central, secure location and update them regularly.
Tracking Documents
A medical waste tracking document, also known as a medical waste manifest, is a document (electronic or paper) used to track medical waste from its origin until it is properly treated. Utilization of this document meets the “cradle to grave” tracking standard established by The Resource Conservation and Recovery Act (RCRA) of 1976.
When receiving medical waste, the waste transporter should provide you (the medical waste generator) with a copy of this tracking document. The original copy of the document will follow along with the waste until its treatment.
The tracking document shall include, but not be limited to, all of the following information:
- The name, address, telephone number, and registration number of the transporter.
- The type of medical waste transported and the quantity or aggregate weight of the medical waste transported.
- The name, address, and telephone number of the generator.
- The name, address, telephone number, permit number, and the signature of an authorized representative of the permitted facility receiving the medical waste.
- The date the medical waste is collected or removed from the generator’s facility.
- The date the medical waste is received by the transfer station, the registered large quantity generator, or the consolidation point, if applicable.
- The date that the medical waste is received by the treatment facility.
The medical waste transporter responsible for transporting medical waste in a vehicle shall maintain the tracking document in his or her possession while transporting the medical waste. The transporter must present the tracking document to any enforcement agency personnel or officer upon demand. When transferring custody of the waste, the medical waste transporter should provide the facility receiving the medical waste with the original tracking document.
Check out this sample of a Medical Waste Tracking Document.
How Long to Maintain Medical Waste Documentation Files
Federal, state, and local governmental departments regulate record keeping for waste management. You’ll need to maintain your files for a length of time that satisfies the longest of all the requirements. Many state that three years is sufficient, but you must confirm with your regulatory agencies before destroying any records.
- The EPA’s Federal Regulation 262.11 Hazardous Waste Determination and Recordkeeping states that “records must be maintained for at least three years from the date that the waste was last sent to on-site or off-site treatment, storage, or disposal.
- The state of California’s regulatory code states that records must be maintained for at least three years and during the course of any enforcement action.
Ensure accountability and compliance in medical waste management by following the best practices for documenting medical waste disposal. For more information on developing a compliant and effective medical waste disposal program, check out these resources.
We are MedWaste Management – California’s medical waste disposal experts!
Established in 2008, MedWaste Management fills a need for compliant and safe medical waste disposal in the healthcare industry and the general public alike. We publish this blog to share valuable and practical information to help you stay safe, informed, and healthy!
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Tammy McKinney, RN, is a healthcare writer and seasoned registered nurse. With experience in acute care, long-term care, rehabilitation, drug & alcohol, and hospice & palliative care, she combines her medical understanding with her love for writing to educate and inform the public on various health-related topics. You can view a snippet of her portfolio here or contact her directly on LinkedIn!
