Breaking news: Regulated medical waste to be managed

In an interesting update, our friends from Chicago have updated the requirements for managing trash (heretofore identified as: The hospital has procedures for the proper routine storage and prompt disposal of trash) to widen the scope a wee bit to requiring hospitals to have procedures for the proper routine storage and prompt disposal of trash—and regulated medical waste!

This “new” requirement is effective July 1, 2024, so it may be an opportune time to look over your existing procedures to make sure that things are in place, and, perhaps most importantly, whether the “letter” of those procedures are being followed in the field. Sometimes, elements required by policy/procedure get lost in the translation into operational considerations. While there is a clear expectation that folks will adhere to existing policies/procedures, one of the most difficult types of findings to reverse (OK, probably the most difficult) are findings relating to a failure to adhere to internal requirements.

That said, I would be hard-pressed to identify any organization with whom I have worked over the past 20 years or so that did not have procedures for both “regular” waste and medical waste, so I’m presuming that this is another one of those nuanced aspects of aligning with the CMS Conditions of Participation and not something for which folks would have a particular vulnerability. Though I suppose this does give surveyors a clear spot in which to cite issues relating to the management of regulated medical waste as a function of the folks charged with signing manifests, and, having the appropriate department of transportation education documented in a fashion that can be provided to surveyor(s) upon request. This can become tricky if: you have a fair amount of turnover amongst the cadre of folks who might sign a manifest; your waste hauler tends to do their pick-ups on off-shifts, weekends, etc. when fewer folks are around. Or (and this is by no means a completely inclusive list), the process for collection, transport, and disposal of regulated medical waste in your outpatient settings doesn’t provide for specific folks to sign-off on manifests and then you have a confluence of turnover, scheduling, etc. which can complicate matters.

Given the givens, I suspect that any true vulnerability in this regard resides (as is so often the case) in the outpatient settings—they can really be a challenge, particularly from the perspective of a standardized approach. As we have seen from time to time over the years, you get more credit for being consistently wrong than inconsistently right. So, as we approach the first of July, it might be useful to focus on the management of medical waste in your outpatient locations to ensure consistency and appropriate education. There is a tendency in the regulatory survey process to highlight things that have changed, and this might be one of the hot topics for the last half of survey year 2024.


About the Author: Steve MacArthur is a safety consultant with Chartis Clinical Quality Solutions (formerly known as The Greeley Company) in Danvers, Mass. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is contributing editor for Healthcare Safety Leader. Contact Steve at