Small quantity generators don’t always have to abide by the same medical waste laws. Here’s what you need to know.

All medical waste generators are required to handle infectious or hazardous waste in accordance with all local and federal laws.  In many states, however, medical waste generators are usually classified by the volume of waste they produce.  Typically, generators are either small quantity generators, large quantity generators, or extra-large quantity generators.  For small quantity generators, rules can be different, but best practices will always remain the same.  If you’re a small quantity medical waste generator, here are tips to keep you compliant and safe.

Check Your State’s Registration Laws

Depending on which state you operate in, you may be required to register for a permit depending on your medical waste volume.  For example, in California, registration is required if you generate less than 200 pounds of medical waste per month, whereas in Texas, generators that produce 50 pounds or less of medical waste per month are not required by the state to obtain a permit, registration, notification, or other authorization to store medical waste on site.

Keeping Manifests

Medical waste manifests for small quantity generators must be kept for three years, according to the EPA’s Understanding the Small Quantity Generator Hazardous Waste Rules: A Handbook for Small Business. Some states have additional requirements, so it is always best to check with your state department of environmental quality.

Be Sure to Check Shipping Restrictions

One major difference between generator volume is how often you legally need to ship your waste from your facility.  Small quantity generators are 180 days or less. Failure to comply with shipping times could result in an EPA fine.

Separating Medical Waste

Small quantity medical waste generators must segregate infectious waste from other waste at the point of generation, assure proper packaging and labeling of waste to be transported offsite, store waste properly, and manage infectious waste in a manner which prevents exposure to the public. For example, acupuncture needles are considered medical waste, therefore acupuncturists, which are small quantity generators, must employ the use of an approved sharps container to dispose of used needles and not throw needles in the regular trash.

However, Don’t Overclassify! (It Can Cost You More Money)

Each state may define sharps or biohazardous waste differently.  Review the definition of sharps and medical waste for your state to see how clearly the state defines each category.  For small quantity generators, this can mean paying medical waste disposal rates for waste that could be discarded in the regular trash.

Are you a small quantity generator that is unsure of the local and federal laws and how they apply to your business? Red Bags services all types of small quantity generators, from private practices, to tattoo parlors, medical spas, and more.

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