Guidance For Healthcare Facilities On Managing COVID-19 Waste
COVID-19 is a virus (more specifically, a coronavirus) that has been identified as the cause of a respiratory illness first detected in Wuhan, China. Transmission of human coronaviruses typically occurs via respiratory droplets, such as coughing, sneezing, and aerosolization of respiratory secretion. Objects contaminated with bodily fluids (such as respiratory secretions) might also serve as sources of infection (e.g., if a person touches an object that an infected person sneezed on and then touches their face). Similar to influenza, respiratory transmission (primary droplets) is likely the main route of transmission.
Important Information for Healthcare Facilities Delivering COVID-19 Patient Care
Infection Control Precautions
Healthcare facilities delivering COVID-19 patient care and those engaged in the handling of Regulated Medical Waste (RMW) that will be generated in a healthcare setting should:
- Follow the Center for Disease Control (CDC) guidance applicable to healthcare professionals, and communities, schools, and businesses (leaving DEC website),
- Follow the guidance on the safe handling of RMW on the Occupational Safety and Health Administration website (leaving DEC website),
- Manage wastes generated from the healthcare of COVID-19 patients as a Category B infectious waste,
- Manage discarded materials from healthcare of COVID-19 patients as RMW.
Waste Exposed to COVID-19
- Worker protection from exposure to COVID-19 is necessary when work tasks involve handling, transport, treatment, and disposal of potentially contaminated RMW.
- The most practical approach to RMW management is to identify wastes that represent a potential risk of causing infection during handling and disposal.
- Title 6 NYCRR Parts 360, 365, and Title 10 NYCRR Part 70 of the New York State regulations specify the categories of RMW that are subject to regulation.
- Although any item that has had a contact with blood, exudates, or secretions may be potentially infective, treating all waste (e.g., objects or materials such as unsoiled disposable gloves, gowns, face shields) as infective is neither practical nor necessary.
- As always, waste handlers should maintain proper use of Personal Protective Equipment (PPE).
- Reusable work gloves and clothing should be washed or laundered prior to reuse to reduce potential contamination.
- Waste handlers should regularly inspect their PPE, and clean, replace, or discard excessively dirty or worn out items.
Regulation of COVID-19 Waste in New York State
The following regulations are applicable to the packaging, labeling, and handling requirements and the transport, treatment, and disposal of COVID-19 waste:
- Title 49 of the Code of Federal Regulations (US Department of Transportation - Transportation of Hazardous Materials)
- Title 6 NYCRR Part 364 (Waste Transporters)
- Title 6 NYCRR Part 365 (Regulated Medical Waste and Other Infectious Wastes)
- Title 10 Part 70 (NYS Department of Health - Regulated Medical Waste)
Note: Permitted RMW transporters or treatment and disposal facilities may have a self-imposed specific notification and acceptance criteria or additional packaging, labeling, transport, treatment, and disposal requirements that exceed the regulations noted above. It is recommended that waste acceptance criteria be investigated as early in the healthcare process as possible.
Additionally, caution must be undertaken with the use of reusable waste containers for this waste stream.
Reusable waste containers used in clinical laboratories and isolation units should be lined with plastic bags and closed before movement.
Management of RMW Generated from COVID-19 Patients Care in a Healthcare Facility
- RMW generated from COVID-19 patient care in a healthcare facility must be treated before it can be disposed.
- Treatment can occur either at New York State Department of Health (NYSDOH) approved healthcare facilities where it is generated or at an off-site treatement facility permitted by the New York State Department of Environmental Conservation (NYSDEC).
- If RMW will be transported off-site for treatment, waste disposal agreements must be in place between the generators, transporters, treatment, and disposal facilities prior to any RMW being sent for off-site management.
Treatment of COVID-19 RMW at the Healthcare Facility
- Treated COVID-19 RMW can be disposal at a facility approved by NYSDEC for this type of solid waste.
- The treated COVID-19 RMW must be accompanied by a certificate of treatment form.
- All sharps must be destroyed, as well as treated.
- Treatment of the COVID-19 RMW at an off-site facility in NYS requires a RMW treatment facility permit from NYSDEC.
- Exposure of materials considered to be RMW to approved antimicrobial products used for routine cleaning and disinfection is not a form of treatment for RMW.
- Part 365 sets forth detailed requirements concerning the handling and treatment of RMW and Other Infectious Wastes.
Transportation of COVID-19 RMW
- A transporter that will be transporting treated COVID-19 RMW from either a healthcare facility or other RMW treatment facility also required a Part 364 permit to transport non-hazardous industrial-commercial waste.
- A transporter that will be transporting untreated COVID-19 RMW or Other Infectious Waste associated with the provision of healthcare, response, or cleanup activities of a contaminated area is subject to both the United States Department of Transportation (USDOT) and NYSDEC regulations.
USDOT Requirements
- USDOT regulates how the waste must be packaged and otherwise managed during transport.
- Requirements for packaging, marking, and transport of the waste are subject to change as circumstances change.
DMM, Bureau of Solid Waste Management
625 Broadway
Albany, NY 12233