Navigating the New Normal in Waste ComplianceNavigating the New Normal in Waste Compliance
May 21, 2020
Waste360 recently partnered with Stericycle on a webinar on “COVID-19: Compliance for Waste Generators,” which featured a timely presentation from Selin Hoboy, vice president of government affairs at Stericycle, Inc., a global leader in waste solutions and compliance training.
Hoboy started off by acknowledging that, in today’s environment, it can be difficult for businesses to stay up on the latest waste regulations coming from local and federal authorities as well as waste haulers themselves. This is partly because conditions and rules are often changing in real time.
It can also be hard to sift through the array of well-meaning advice from agencies such as the CDC and OSHA, to understand what applies to a particular business and whether it is best-practices guidance versus enforceable regulation.
For instance, the CDC is recommending the following for when businesses reopen:
Daily hazard assessments for each of their workplaces
Daily health checks of workers
Encourage employees to wear face coverings and implement social distancing
Improve ventilation systems or install barriers
Hoboy notes that this is great guidance but not technically enforceable. That said, “not following these types of recommendations could open your business up for liability if you are not following them.” And, keep in mind that some of the current guidance can and may become regulation.
Where regulations do apply, Hoboy advises “keeping documentation of the efforts that you took to comply with the regulations to the best of your ability, and showing the steps you took to maintain compliance—or come back into compliance if you saw there was an issue.”
Also, if your business has been granted any regulatory relief during this pandemic, for things that would otherwise be seen as violations—such as not renewing workers’ drivers licenses, or extended storage of hazardous waste—it is prudent to keep a close eye on when these exceptions might expire.
Hoboy also discussed how businesses across many sectors might have new questions and concerns about waste disposal in this new environment. As for healthcare facilities, the CDC continues to maintain that medical waste coming from facilities treating COVID-19 patients is no different from waste coming from facilities without COVID-19 patients, meaning it does not require additional disinfection. But Hoboy advises that facilities stay tuned for any further local or state guidance in this area.
For businesses less familiar with medical waste, complications can arise when classifications and definitions of various types of waste vary state to state. For instance, does personal protective equipment (PPE) get categorized as regulated medical waste or solid waste? It depends, so check with your local officials.
And, if you have a business that is generating medical waste for the first time. Hoboy offered a few pointers on what to look for in a medical-waste provider. A reputable hauler should:
Research all current information and regulations, and provide regular updates/communication to you, the client
Have a business continuity plan in place
Have established protocols and procedures, and provide training for their own staff and yours — with adjustments to meet changing environments
Have internal staffing available to support your needs
Hoboy also emphasized that proper packaging is the first line of defense when it comes to medical waste. Some key reminders include:
Red bags need to be used to line containers
Be mindful of container weight
If there are free liquids use solidifier/absorbent and/or double bag
Leaking/wet containers will not be accepted
Red bags need to be tied
“As a generator, you need to be aware of not just your state regulations but also federal regulations as well. And, proper packaging of your waste—both regulated medical waste and solid waste—plays an important role in protecting all of us in the waste management arena, and your workers,” said Hoboy.
As you may be planning for a re-opening of your business, now is the time to identify what types of operations you will be resuming—and, consequently, what type of waste will you be generating, in what type of settings? Find out if this waste meets your state’s definition of regulated medical waste. And check for any further guidance issued by your state or waste vendor regarding cleaning chemicals or anything else that could create a new concern in your waste streams.
Hoboy’s main takeaway is to, “Keep yourself informed; stay current; check the CDC website again and again; and be in touch with your local and state health departments for the latest.”