How to Manage COVID-19 Waste

Margaret Anne Hill, Frank L. Tamulonis III, and Stephen C. Zumbrun

The surge in COVID-19 patients has led to a sharp rise in medical waste that could carry the novel coronavirus. One common question raised by the COVID-19 outbreak is how to properly manage and dispose of COVID-19-contaminated waste. The short answer is that COVID-19 waste is not treated any differently than other standard regulated medical waste (“RMW”).

The Occupational Safety and Health Administration (“OSHA”), Centers for Disease Control (“CDC”), and World Health Organization (“WHO”) have all stated that waste from COVID-19 patients should be handled as RMW and should be managed in accordance with routine procedures. OSHA recently issued guidance stating that medical waste with potential or known COVID-19 contamination is not a Category A infectious substance, which is a type of waste capable of causing permanent disability or life-threatening or fatal disease. (See osha.gov/SLTC/covid-19/controlprevention.html#solidwaste.) Rather, COVID-19 waste is a Category B infectious substance (does not cause life-threatening or fatal disease) which is discarded as regular RMW. OSHA advises as follows:

Use typical engineering and administrative controls, safe work practices, and PPE, such as puncture-resistant gloves and face and eye protection, to prevent worker exposure to the waste streams (or types of wastes), including any contaminants in the materials, they manage. Such measures can help protect workers from sharps and other items that can cause injuries or exposures to infectious materials. Continue reading “How to Manage COVID-19 Waste”

Coronavirus: OSHA’s and EPA’s Response

Margaret Anne Hill, Frank L. Tamulonis III, and Stephen C. Zumbrun

As the world’s attention turns increasingly (and almost exclusively) to the spread of COVID-19 (the coronavirus), we want to take this opportunity to highlight two important federal agency responses from the U.S. Occupational Safety and Health Administration (“OSHA”) and the U.S. Environmental Protection Agency (“EPA”). The responses from the Center for Disease Control (“CDC”) and World Health Organization (“WHO”) have received the bulk of public attention to date, and for good reason. Just this week, the WHO declared the outbreak a pandemic with nearly 125,000 cases reported across 118 countries and territories. WHO has shipped supplies and protective equipment to 57 countries and is preparing to ship to another 28 countries. WHO has published an R&D roadmap and comprehensive technical guidance. WHO has also pledged more than $440 million (U.S.) to WHO’s Strategic Preparedness and Response Plan.

Here at home, the CDC has likewise been operating in overdrive to reduce the spread and impact of the virus. The CDC has issued multiple clinical guidance documents for healthcare professionals in addition to travel guidance related to COVID-19. The CDC established a COVID-19 Incident Management System on January 7, 2020, and activated its Emergency Operations Center on January 21. Multidisciplinary teams have been deployed to support state and local health departments. CDC also developed diagnostic testing to track and confirm COVID-19 cases and testing kits from commercial labs are expected soon. The CDC has also issued well-publicized recommendations for the public to follow.

In addition to these sweeping responses from the WHO and CDC, OSHA and EPA have been busy preparing and executing their response to this pandemic. While some employers may be able to provide significant flexibility to employees, allowing them to work from home, other employers will need to keep employees onsite, and will need to ensure the safety of their workforce. Other employers, which may manage medical wastes, will need to exercise additional precautions in ensuring that infectious wastes potentially contaminated with COVID-19 are managed in accordance with relevant state and EPA medical waste requirements. Below are the highlights from each agency. Continue reading “Coronavirus: OSHA’s and EPA’s Response”