4126_OzoneWasteSolution_container question_DIN28713_20170626

1
Chao, Ming-tai
From:Chao, Ming-tai
Sent:Monday, June 26, 2017 8:38 AM
To:Sheila Gambardella
Cc:Patrakis, William; Patrone, John
Subject:Re: RMW container question
Dear Ms. Gambardella:

The "red-color" container or bag for a RMW is not necessary and not required by the NC Solid Waste
Management Rules. However, if RMW will be shipped to an out-of-state facility for treatment, you will have
to follow other states' or OSHA requirements as well. Should you have any other questions please contact Bill
Patrakis at [phone], email: [e-mail], who is the medical waste specialist for the
Solid Waste Section.

According to the Medical Waste Guidance and Interpretation which can be located at the
web page https://deq.nc.gov/medical-waste-guidance-and-interpretation , "

Packaging Regulated Medical Waste for Off-Site Treatment
Regulated Medical Waste must be packaged in a plastic bag in a rigid fiberboard box or drum in a manner that
prevents leakage of the contents. The outer surface must be labeled with a biohazard symbol; the words
"INFECTIOUS WASTE" or "MEDICAL WASTE"; the date of shipment; and the name, address and phone
number of the generator, transporter, storage facility and treatment facility. The medical waste management
rules do not require a biohazard label on the plastic bag or use of red bags. However, generators should
be aware that OSHA rules may require labeling of bags containing some types of medical waste.
(.1204(a)(4))."

Different Labeling Requirements
Generators must be familiar with both sets of requirements. OSHA may require a red bag or biohazard-labeled
bag for some waste that can be safely disposed in the landfill without treatment. That could include properly
containerized sharps, used gloves, bloody gauze and dressings, and properly containerized blood and body
fluids in volumes of 20 mL or less. State waste disposal regulations require the words "INFECTIOUS WASTE"
or "MEDICAL WASTE" on packages of regulated medical waste that are taken off site for treatment and
disposal. State medical waste disposal regulations no longer require the use of red bags since the red dyes
may contribute heavy metals, such as lead and cadmium, to incinerator ash disposed in landfills. State
solid waste goals include reducing the toxicity of landfilled waste. Users of red bags should check with their
vendors to ensure they are using bags that do not create toxic residues after incineration. Disposal of Red Bags
That Contain Only Medical Waste Not Classified as Regulated Medical Waste by the State Medical
Waste Management Definition
Bags that contain only non-regulated medical waste in accordance with state rules and are labeled as bio-
hazardous in the workplace, are "over-labeled" for disposal purposes. Such labels were previously reserved to
designate waste that was banned from the landfill and must be treated. Red bags and biohazard-labeled bags that
contain only non-regulated medical waste may be disposed with general solid waste, provided no local rules
prohibit it.

The Solid Waste Section has alerted North Carolina landfills to expect increased disposal of non-regulated
medical waste in red bags or biohazard-labeled bags as the OSHA rules are implemented. In some counties,
landfill operators initially may not accept such bags, even though they had previously accepted the same waste
2
in plain, unlabeled bags. In most cases, this can be worked out through local discussions and better
communications with the landfill. Landfill operation is regulated by the Solid Waste Section, and local waste
management specialists are available to provide assistance, guidance, and education for landfill operators.

As described in paragraphs (g)(1)(i)(B),(C),(D), and (E) of the OSHA standards, the OSHA labeling
requirements can be satisfied by the use of either red bags or bags with a biohazard label. Facilities sending
waste to the landfill may find plain bags with the appropriate biohazard label an easy solution.
NC DEQ: Medical Waste Guidance and Interpretation
deq.nc.gov
INTRODUCTION. This document is provided to help you understand the North Carolina medical waste
management rules. If you would like further information, please ...

Ming Chao
Ming-Tai Chao, P.E.
Environmental Engineer
Permitting Branch, Solid Waste Section
NCDEQ, Division of Waste Management
(Mailing Address)
1646 Mail Service Center
Raleigh, NC 27699-1646

(Street Address)
Green Square, 217 West Jones Street
Raleigh, NC 27603
Tel. [phone]
[e-mail]
http://portal.ncdenr.org/web/wm/sw

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.

From: Sheila Gambardella <[e-mail]>
Sent: Friday, June 23, 2017 3:38 PM
To: Chao, Ming-tai
Subject: RMW container question

Good afternoon Mr. Chao.

I have been researching container requirements for RMW.
3

We have a couple of customers inquiring about using 96 gallon waste toters.

The only requirements I find are the labeling and container requirements listed below.

I thought maybe you could help me with whether or not the container, itself has to be "red" or can it be any
color as long as it complies with the following regulation:

15A NCAC 13B .1204 REQUIREMENTS FOR GENERATORS OF REGULATED MEDICAL WASTE
(a) A person who ships regulated medical waste from the generating facility for off-site treatment shall meet
the following requirements:

(1) Regulated medical waste shall be packaged in a minimum of one plastic bag placed in a rigid fiberboard
box, rigid drum, or other rigid container constructed in a manner that prevents leakage of the contents. The
plastic bag shall be impervious to moisture and have a strength sufficient to preclude ripping, tearing or
bursting the waste-filled bag under normal conditions of usage and handling. Each bag shall be constructed of
material of sufficient single thickness strength to pass the 165-gram dropped dart impact resistance test as
prescribed by Standard D 1709-91 of the American Society for Testing and Materials, which is incorporated by
reference including subsequent amendments and editions, and certified by the bag manufacturer. A copy is
available for inspection at the Department of Environment, Health, and Natural Resources, Division of Solid
Waste Management, 401 Oberlin Road, Raleigh, North Carolina. Copies may be requested by mail at American
Society for Testing and Materials, 1916 Race Street, Philadelphia, P.A. 19103 or by calling [phone] for a
cost of twelve dollars ($12.00) plus one dollar and fifty cents ($1.50) for shipping and handling unless prepaid,
then the fee is twelve dollars ($12.00).

(2) Regulated medical waste shall be stored in a manner that maintains the integrity of the packaging at all
times.

(3) Each package of regulated medical waste shall be labeled with a water-resistant universal biohazard
symbol.

(4) Each package of regulated medical waste shall be marked on the outer surface with the following
information:
(A) the generator's name, address, and telephone number;
(B) the transporter's name, address, and telephone number;
(C) storage facility name, address, and telephone number, when applicable;
(D) treatment facility name, address and telephone number;
(E) date of shipment; and
(F) "INFECTIOUS WASTE" or "MEDICAL WASTE".

(b) Records of regulated medical waste shall be maintained for each shipment and shall include the
information listed in this Paragraph. This information shall be maintained at the generating facility for no less
than three years.
(1) amount of waste by number of packages (piece count);
(2) date shipped off-site;
(3) name of transporter;
(4) name of storage or treatment facility.

4
The requirements of this Paragraph shall not apply to persons who generate less than 50 pounds of regulated
medical waste per month.

(c) A plan to ensure proper management of regulated medical waste shall be prepared and maintained at the
generating facility.

History Note: Authority G.S. 130A-309.26; Eff. October 1, 1990; Amended Eff. October 1, 1992; December 1,
1991; March 1, 1991.

Any assistance you can give me on this matter will be greatly appreciated.

Regards,
Sheila

Right-click or tap and hold here to download pictures. To help protect your privacy, Outlook prevented automatic download of this picture from the Internet.phdlogo
Sheila Gambardella
Office Manager
[e-mail]
office: 336-550-4037
fax: [phone]
www.OzoneWasteSolutions.com