Would you like to know if your vendor...

Knows the Regulations? .............................................. Page 2-3

Is Compliant? .......................................................................... 3
Can help you to remain Compliant?......................................... 3
Outsources treatment and disposal?........................................ 5
Offer Compliance Audits and Training? .................................... 6
Offer Waste segregation training and minimization?............ 7-8
Has the ability to provide reports? ........................................... 8
Provides disaster and Emergency Preparedness? ..................... 9
Flexible services? ..................................................................... 9
March 2008 Provides a checklist of areas to evaluate? ........................ 10-11
BEST PRACTICES IN SELECTING A CONTRACTED
REGULATED MEDICAL WASTE DISPOSAL PROVIDER
Most healthcare facilities use a contracted waste disposal vendor to manage disposal
of their regulated medical waste1 (RMW). There are significant liabilities associated with the
disposal of RMW because a legal precedent places the direct responsibility for liability on
the facility generating the waste material. However, this risk can be minimized by
carefully selecting a qualified waste disposal service that can assure regulatory compliance.
This article outlines the key considerations when selecting a RMW provider:

1. Identify RMW vendors who know the regulations and stay current as the regulations change.
2. Understand how RMW vendors can proactively help your facility remain compliant.
3. Identify and understand the key services your RMW vendor should provide.

Does the RMW vendor know the regulations?

Knowing and adhering to the regulations surrounding
disposal of RMW is vital for healthcare facilities to avoid
fines, loss of licenses, and avoid negative publicity. In addition
to complying with the federal, state and local regulations, many
hospitals receive their accreditation from Joint Commission
(formerly JCAHO) and follow the Joint Commission standards
for patient environment of care (EOC). For more information
on these regulatory and accrediting authorities, see Sidebar #1.
Understand and ask how your RMW Vendor ensures
compliance with these authorities.
The myriad of regulations can make it difficult for hospital
personnel to stay on top of the requirements. Kirsi Aryan-
Edwardson, Director of Environmental and Nutrition Services
at Littleton Adventist Hospital in Colorado says, There are so
many regulatory issues and few of us have time to be up on
these issues. We look to our RMW vendor to be the expert in
RMW regulations and take their advice on staying compliant.
If you look to your RMW
vendor to provide expertise
on regulations, how can you
be certain that they have
knowledge of this area?
First, ask if they have staff
dedicated to regulatory and
environmental regulations.
Second, ask them for a
listing of all the regulations
that impact your facility and
impact their ability to service
your facility. Expect the list
to cover federal, state and
local regulations.
Although there are additional regulations depending on the
location, the following are a few of the mandatory elements:
Federal Motor Carrier Safety (ensures safety of highways and
drivers through roadside inspections, truck and driver monitoring),
OSHA blood borne pathogen training on an annual basis for
your employees, and DOT training for all employees handling
hazardous materials including regulated medical waste.
Refer to callout in green on next page for additional
types of regulations.
Check for evidence that your regulated medical waste vendor
knows the regulations, including their drivers. Ask the driver
who services your account what waste stream they are
transporting and what safety protocols they have on the truck
to contain any spill (i.e. spill control kits). Chances are that if
they cannot answer basic questions concerning the waste they
are handling, then they are not properly trained to service
your facility.
Be wary of vendors who don’t emphasize the regulations
regarding training. Often, when facilities are inspected, the
easiest way for a regulator to evaluate compliance at a facility
is to ask them for their training records. Without full knowledge
and understanding of often- changing regulations, many
facilities find themselves out of compliance. Don’t let your
vendor put you in this vulnerable position.
According to Rhett Belser, Safety Specialist at Shawnee
Mission Medical Center in Kansas, You can’t think
of RMW as out of the door and out of mind because
the hospital has a cradle-to-grave responsibility.
That’s why you want a vendor you have confidence in.
A compliance problem at the landfill is still
your responsibility.

Stericycle, Inc. RMW WHITE PAPER 2 www.stericycle.com

REGULATORY AND ACCREDITING AUTHORITIES.
Ask how your RMW Vendor ensures compliance with these authorities.

Joint Commission - (formerly JCAHO) sets standards for State and Local level Environmental
patient environment of care (EOC) and quality improvement and Health Departments.
in hospitals. These minimum standards are set by the
• May require additional training for healthcare
Centers of Medicare and Medicaid Services (CMS). The Joint and RMW workers.
Commission provides accreditation and certification of
• May require additional security plans.
hospitals through an extensive auditing process.
• May have restrictions on the holding time for
OSHA - The U.S. Department of Labor Occupational Safety & regulated medical waste and proper storage
Health Administration or an OSHA state program requirements.
regulates several aspects of medical waste, including • May have additional requirements for document
management of sharps, requirements for containers that retention.
store medical waste, labeling of medical waste containers, • May require state or local registration or have
and training of employees. These standards are designed permitting requirements.
to protect healthcare workers from the risk of exposure to • May have additional specific regulations for
blood borne pathogens. OSHA regulates both on a federal on-site treatment of waste.
and state level and:
Nuclear Regulatory Commission (NRC) - regulations on
• Requires that all employers, who have employees
medical wastes containing radioactive isotopes or materials.
dealing with infectious substances, have a blood
borne pathogen program in place, including
US EPA – The Environmental Protection Agency under the
pre- and post-exposure protocols.
Resource Conservation and Recovery Act (RCRA) regulates
• Requires that all employers, who have a workplace, hazardous waste which many healthcare institutions
provide a generally safe work environment for generate in addition to RMW.
all employees.
CDC - The Centers for Disease Control also issues guidelines
DOT - The Department of Transportation regulates medical for infection control (IC) that can pertain to RMW.
waste transport under the Pipeline & Hazardous Materials
Safety Administration (PHMSA) regulations. Hospitals need
to be familiar with these regulations because their RMW
is transported off-site. The department conducts periodic
inspections of trucks and hospitals to ensure proper
packaging of medical waste containers. The DOT:
• Requires generators to package all waste in accordance
with the federal regulations.
• Requires generators to label all packages appropriately
according to federal regulations.
• Requires generators to sign off on shipping documents
that all the regulated medical waste is packaged in
accordance to these federal regulations.
• Requires all employees who deal with or manage
RMW, including the individual who signed the shipping
document, to be properly trained in four areas of DOT.
• Requires that all shipping documents must be
maintained for a minimum of two years for generators.

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 Does your vendor stay current with the regulations
and assure a trained compliance-focused workforce?
Does your regulated medical waste disposal vendor have Environmental
Health and Safety (EHS) staff dedicated to regulations? Not just the sales
person, but a team of regulatory experts studying the laws at local, state
nd national levels and who anticipate emerging changes that could impact
your facility? It’s important to know the current regulations, and be prepared
to anticipate and comply to changes as they emerge. The regulations are
confusing, continually changing, they differ by state, and in many cases,
require the generator (the hospital) to have responsibility for the waste they
generate until it is treated and is finally disposed of at a landfill. Generators
often have questions about how to properly manage their waste. While it
may be the hospital staff producing the waste, it may be another party
or entity within the hospital that has to manage the waste and maintain
compliance. It is important to partner with a waste disposal company
which will provide the right tools at all the right levels to help manage
the varying aspects of medical waste disposal, including training.
In addition to having staff dedicated to understanding regulations and
anticipating changes as they emerge, a waste vendor should have staff
with industry and regulatory relationships. Leveraging these relationships
can provide a voice from your facility to the ears of the regulators.

Does your RMW vendor help your facility remain compliant?

Partnering with a RMW vendor who helps you stay on track with training requirements will help keep the regulators
satisfied and most importantly decrease your employee risk.
Does your waste vendor have the capability to provide training programs such as OSHA blood borne pathogen training?
Do they provide training for waste packaging, proper labeling on containers, proper shipping documents, and proper
closure of containers? Look for regulated medical waste vendors that provide compliance audits, waste segregation training,
waste packaging training, and a variety of posters to their clients to assist in the educational efforts to stay compliant.
Training pays off and keeps hospitals in compliance. Aryan-
Edwardson, Director of Environmental and Nutrition Services
at Littleton Adventist in Colorado says that keeping compliant CASE STUDY—
is more important than ever with the increased focus that
regulators have. She says, Regulatory agencies are focusing An example of a success story,
more on healthcare. The benefit is that hospitals are learning Best Demonstrated Practices
to be more compliant.
Ridgeview Medical Center in Waconia, MN participated
Everyone can agree that staying compliant is the best course in a waste audit led by their medical waste vendor in
of action for hospitals. Healthcare organizations are better 2006. The vendor identified the need for training and
served by focusing on patient care than by focusing their conducted training within four months. Ridgeview was
efforts on corrective action required to address noncompliance. awarded a 2007 H2E Environmental Leadership Award
Non-compliance is more than just a waste of hospital effort; based for their overall performance. They experienced
it also can bring citations, fines, and negative publicity. a 22.9% reductions in RMW in 2006 and a 24.6%
On a monthly basis, the DOT posts enforcement actions.
reduction in RMW in 2007 based upon their benchmark
Recently the DOT fined a healthcare facility $5,600 for
of 1.18 per adjusted patient day. Ridgeview is also
RMW containers which were not properly closed. Another
institution received a fine of $5,950 for RMW containers recognized for having fully operational environmental
that were not secure and leak proof. See the following programs in a variety of other areas as well.
website for enforcement actions from the DOT,
http://hazmat.dot.gov/enforce/hmenforce.htm.

Stericycle, Inc. RMW WHITE PAPER 4 www.stericycle.com

How much does your RMW vendor outsource Proper disposal of Regulated Medical Waste
waste treatment and/or disposal?
Because the responsibility for RMW remains with the facility
even after the vendor hauls it away, it’s important for the
vendor to be compliant through the entire process of pickup,
transportation, treatment and final disposal of the regulated
medical waste. Healthcare facilities need to feel secure that
the RMW vendor they chose is handling the entire waste process
and is fully integrated. Some small waste companies are merely
waste haulers who subcontract waste treatment and disposal.
When you increase the number of companies who handle the
waste, you increase the risk and it becomes more difficult to
determine the responsibility. At the end of the day, you need to
know where your waste is going. When you sign your name on
a shipping document the DOT specifically holds you, the generator,
responsible for identifying, classifying and packaging the waste.
If your RMW transporter does not own the disposal facility, make
sure the transporter has done a thorough job of due diligence, an
agreement and a good working relationship with the disposal
facility are important. Do not let a problem between the disposal
facility and transporter become your problem.
Besides outsourcing part of your regulated medical waste,
some RMW companies may lack the insurance required by your
healthcare institution. Hospitals should require proof of general
liability insurance, workers compensation, transportation permits
and financial assurance documents from their RMW providers.
Many small companies don’t have the knowledge or the
financial ability to carry such insurance.
In addition to fines and the tarnished scorecard with regulators,
the hospitals have been left with a public relations disaster as
they struggle to keep noncompliance off the front-page news. Where your Regulated Medical Waste
Current and prospective patients wonder about the quality of should not end up
hospital care when their healthcare organization (or the
hospital’s waste vendor) is found to be non-compliant.
Healthcare facilities need to audit their waste disposal company
from collection to transportation, treatment and final disposal.
For tips on what to look for in an audit, see audit (see callout in
green on next page). Healthcare facilities need to ask if their waste
company outsource any of the waste processing to another vendor, and
they should make sure that all companies touching their waste
are properly licensed and insured. Additionally, ask how long
they have been in business and ask for references to ensure
that your selected vendor is experienced in working with
healthcare institutions of your size.
It is key that your provider does a thorough job of due diligence
to assure that your vendor is compliant.

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 RMW SERVICE PATH —
What to look for during an audit of your RMW treatment facility
• RMW is picked up and brought to the local treatment facility.
• The waste is taken off of the truck and should be scanned. The information recorded should include the
total weight if using a disposable container and the tare weight if you are using a reusable container (see next bullet).
Additionally the date, time, customer information and operator name should also recorded. If the waste is incineration
waste such as, trace pharmaceutical, pathology or trace-chemotherapy waste, it should be segregated at the plant
and placed on a refrigerated truck where it is transported to the incinerator.
– The tare weight is the actual weight of the contents inside the reusable container (only the waste).
Gross weight is the total weight of the contents PLUS the weight of the container. Tare is the true weight
generated by the customer. Also ask if your treatment facility has a maintenance contract with a scale
company to check calibration and verify operation of scales.
• The RMW container should be scanned for radioactive waste and then treated.
• After treatment, the waste should be compacted and placed into environmentally approved containers
for shipment to landfills.
• The reusable containers for medical waste should be washed before being returned to the hospital.
• Ask to speak to a representative of the treatment and disposal facility to inquire about their operating
record and any documented inspections/violations.
• Obtain copies of the treatment and disposal facility’s permits.

Does your regulated medical waste disposal
service offer compliance audits and training?
How do you know if your healthcare facility has gaps in Joint
Commission’s EOC standards, Joint Commission’s performance
improvement requirements, OSHA, EPA, DOT, and state/local
regulations? Ask if your regulated medical waste vendor
provides on-going consulting and compliance audits to
customers. Do they have dedicated consultants to provide
these audits?
A healthcare compliance specialist, not the sales representative
should perform a compliance or waste survey and audit report.
Does your auditor have a PDA/laptop, a camera, and years of
knowledge, compliance training and certification? The auditor
should observe current practices, identify safety issues and
identify best demonstrated practices as well as gaps from best-
demonstrated practices. Not all compliance audits are created
equal. Seek vendors who have the ability to go the extra mile
with the technical expertise and proven, documented results.
After identifying top deficiencies and potential violations, the
compliance audit identifies corrective action such as training
and changes in processes like ensuring the right containers are
in the right locations. Your RMW provider should be able to
provide training materials and coach departments through
needed changes in the way they do their jobs. Recognizing
the audit is simply a snapshot of that day; these changes
need to be monitored time and time again.
Does the regulated medical waste company have the ability
to provide educational in-services and training materials on
various subjects? Training should be considered for nurses,
clinical staff and housekeeping employees who are responsible
for RMW disposal. Training might also be available to the lab.
Extensive training is usually provided with environmental
services staff who package the RMW. Ask if your vendor offers
certified US DOT Hazardous Material training as well as blood
born pathogen OSHA training for your personnel. Ask if your
vendor has the capability to provide this training for personnel
every three years, a requirement of the DOT. The DOT requires
the training to be facilitated by an instructor, requires attendees
to pass a certifying test and requires attendees to receive
certificates. All of these requirements should be available
through the RMW disposal vendor for the employees that
handle the regulated medical waste at the healthcare facility.
Aryan-Edwardson, Director of Environmental and Nutrition
Services at Littleton Adventist Hospital comments on her RMW
reps, They are patient and non-judgmental. They evaluate our
processes and advise us what needs to get done, but leave
the follow through up to us, as we prioritize our next steps.
This approach works well to engage us without making us feel
defensive. Education is necessary at the management level
as well. Rhett Belser, Safety Specialist at Shawnee Mission
Medical Center in Kansas, remembers being new in his position
and being thrown into the regulations. Our waste vendor
helped me by providing education on EPA and DOT. That was
really useful when we had a surprise EPA inspection recently.

Stericycle, Inc. RMW WHITE PAPER 6 www.stericycle.com

Healthcare Compliance Specialist
PDA utilized to perform Healthcare Compliance
Surveys and Waste Segregation Audits
CASE STUDIES—
Examples of success stories, Best Demonstrated Practices
(Case study #1)
Between 2003 and 2007, St Mary's Hospital in Green
Bay, Wisconsin reduced their medical waste poundage
by 39%. They had participated in a 2003 waste
minimization survey provided by their regulated
medical waste vendor which identified opportunities
with formalin recycling, removal of all chemotherapy
waste in excess of 3% solution from waste stream,
removal of all empty medication vials from the waste
stream, removal of all expired medications from the
waste stream, and removing general trash and paper
from the waste stream. Their regulated medical waste
vendor helped St Mary’s with labeling for bio-handling
areas, assisted in providing better container options,
www.stericycle.com
Does your RMW vendor provide
training on waste stream segregation
and departmental tracking of
RMW generated?
Does your RMW vendor have the depth to provide
departmental tracking which identifies the specific
amount hospital departments generate? Does your
waste vendor identify which departments need
training on waste stream segregation? Your vendor
should be targeting their training and educational
in-services to the departments which are in need.
Hospitals should take advantage of all the training
that’s offered by their vendors whether it is posters,
in-services, etc. Additionally, hospitals should make
sure to train all the shifts.
and trained 22 of hospital’s employees on DOT criteria.
St. Mary's Hospital has been inducted as a member
of H2E's Leadership Circle.
(Case study #2)
During 2005, three of ThedaCare Health System's four
hospitals in the Appleton, WI area, participated in a
waste survey conducted by their medical waste vendor.
As a result, the vendor identified the need and provided
training on segregation practices. The resulting
improved segregation provided about a 10% reduction
in RMW. ThedaCare has recently been introduced to
the H2E Leadership Circle.
7 (rev 03/08)
Does your RMW vendor provide consultation
on waste stream minimization?
Properly segregating waste is the first step in an overall program to minimize RMW.
Hospitals for a Healthy Environment2 (H2E) have set a goal to reduce RMW to 15%
of the total hospital waste stream. Does your vendor offer consulting services and
on-going reporting to help hospitals reduce total waste? Does your vendor offer
other options which provide incentive for the facility to reduce waste and costs?
On the surface, it might appear like a conflict of interest to entrust RMW minimization
to the RMW vendor. However, it is in the vendor’s best interest to have optimally
packaged, heavier containers that are truly RMW, which result in fewer hauls, more
efficient use of space on the trucks, and less costs to treat the waste. Reducing the
amount of red bag waste is good for the hospital and more efficient for the vendor.
Kathy Lockamy in IC at Cape Fear Valley Hospital System agrees, Our RMW rep is
helpful and supportive in reducing our RMW. She has helped us to get control and
reduce the waste stream. She saw where containers were located and made some
recommendations to make the tubs less available in certain areas of the hospital
to cut down on the non-RMW in the biohazard containers.

Does your RMW vendor provide reports that you really use?
Does your vendor periodically report on the amount of RMW collected, the billings, and the key issues with the hospital’s
waste program? Does the report trace waste back to the individual generating department? This would enable the facility
to have the option to charge the department back for their service utilization. This also helps the hospital target departments
where additional training or efforts may be needed.
Does your vendor offer reports? Are the reports available on-line? Do the reports track regulated medical waste from collection
through documented disposal? Not only should you be able to see which departments are generating what amounts and types
of waste, but you should be able to benchmark your total waste streams against H2E goals. See Figure 1 for an example.
For hospitals that are focusing on environmental, Green Team efforts and possibly winning the coveted H2E award,
on-going reporting is an invaluable feedback tool.

Waste Overview
Your RMW vendor should
provide reports, which analyze
the waste stream, show the
breakdown of the types of waste
collected, and the associated
costs. Some facilities use their
waste stream reports as a basis
for periodic review meetings be-
tween the RMW disposal
company and key hospital
H2E Leadership Criteria stakeholders. These meetings
are an ideal forum to discuss
waste education, training and ef-
forts to meet the hospital’s ongo-
ing RMW goals. Some
hospitals use their waste
reduction goal as part of their
Joint Commission performance
improvement initiatives.

Figure 1: Sample of Tracking and Analysis

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Does your RMW vendor provide shipping documents or manifests?
Are these documents available on-line?
What do you show the regulator who asks to see the paper trail on your RMW shipments? RMW disposal companies should
provide hospitals with on-line manifests, eliminating the need to keep big ring binders of shipping documents. Federal DOT
requires documents be kept by the shipper for two years. State requirements can sometimes be even longer. Having on-line
documents helps the hospital provide the required documentation for any regulator request without burdening staff with reams
of paper. This archive system
makes life easier for EVS
personnel and reduces labor
costs while ensuring a proper
electronic paper trail.

Sample of a Customer
Container Summary by
Waste Type and Price

Does your RMW vendor provide disaster
and emergency preparedness?
In the light of Katrina and other emergencies and natural
disasters many hospitals are requiring that their RMW vendors
have disaster recovery and contingency plans. Many purchasing
departments are requiring vendors to have back-up plans for
inclement weather and other emergencies. They need to know
the waste vendor’s back-up location will service their account
to ensure that waste doesn’t pile up at the hospital. Healthcare
facilities need to know that additional trucks can be diverted to
pick up waste. Ask your waste vendor if they own their back-up
facility. If not, ask if there is a contractual relationship requiring
the back-up to accept their waste. Healthcare facilities need
proof that the back-up will provide service during an emergency.
These contingency plans need to be determined between the
hospital and the vendor in advance of the emergency.
During a crisis is not the time to negotiate back-up plans
with your RMW vendor.
Healthcare facilities should list their vendors on the Disaster &
Emergency Plan so they will be permitted on-site if needed.
The solid waste vendor, the hazardous waste vendor and the
RMW vendor should all be listed.
Does your RMW vendor offer full
and flexible services?
RMW vendors should be able to be flexible to changing
hospital needs. For example, ask the vendor what happens
if you want to switch the day of pick up or add an additional
pick up during the week. Hospitals need vendors with the
bandwidth to accommodate such changes so they can be
responsive to changing patient loads.
According to Kathy Lockamy, IC Director at Cape Fear
Valley Hospital in NC, Expertise and cost and reliability
are the most important attributes of a good vendor.
We don’t have any problems with our vendor because
they carry their end of responsibilities.
RMW vendors should provide compliant containers and tubs
to hospitals in shapes and sizes that best meet their needs.
Containers should be strategically placed and appropriately
labeled for solid waste, infectious waste, hazardous waste,
recycling and universal waste. The vendor may also provide
transport carts to move the waste to the hospital storage areas.
A full service vendor offers one stop shopping for regulated
medical waste

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 RMW VENDOR CHECKLIST:
Does the vendor provide:
1. Evidence of expertise in RMW? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

2. Provide references from other healthcare facilities? . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

3. Evidence that they can meet the facility’s daily pick-up and . . . . . . . . . . . . . . . . . . . . ! YES ! NO

4. Evidence of expertise in environmental and regulatory compliance (Joint

Commission Environment of Care, DOT, state & local agencies, EPA) . . . . . . . . . . . . . ! YES ! NO

5. Proof of their own compliance record? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

6. Demonstrated knowledge of employee safety and health (OSHA) . . . . . . . . . . . . . . . ! YES ! NO

7. Multiple facilities and transportation resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

8. Ability to audit the primary facilities and transportation resources, satisfaction

with the results? (See Sidebar #2 for items to look for in an audit) . . . . . . . . . . . . . ! YES ! NO

9. Copies of permits for:

a) Incinerator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
b) Autoclave or other waste technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
c) Transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

10. Evidence of Emergency Preparedness such as back-up plans for

their treatment facilities & transportation in the event of disaster. . . . . . . . . . . . . . . . ! YES ! NO

11. Evidence of capital improvements. Are their facilities properly maintained? . . . . . . . . ! YES ! NO

12. Waste tracking and analysis capabilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

a) Scan and track waste capabilities during the entire process . . . . . . . . . . . . . . . . . ! YES ! NO
b) Waste tracking to the department level . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
c) Ability to identify departments and behaviors that sub-optimally
impact your costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
d) On-going reports to monitor your waste minimization efforts . . . . . . . . . . . . . . . . ! YES ! NO
e) On-line manifest archive system to help you manage documentation
(manifest is a detailed report of the medical waste containers that
were picked up and delivered to your facility) . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

13. Specialists who are able to provide training and education for your staff . . . . . . . . . . ! YES ! NO

14. Compliance services and waste minimization consulting services . . . . . . . . . . . . . . . . ! YES ! NO

a) Audits and provide training to close gaps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
b) Worker training programs and training materials, such as posters and signs . . . . ! YES ! NO
c) Plans for waste segregation and minimization . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
d) Reports to track progress on your successes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
e) Identifies and suggests ideas to maintain consistency in RMW (Can they
help you maintain and raise the bar on your waste performance?) . . . . . . . . . . . . ! YES ! NO

15. Referral to local non-RCRA waste vendors if needed . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

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 RMW VENDOR CHECKLIST (CONTINUED):
Does the vendor provide:
16. Waste minimization references – can the vendor prove a track
record of waste minimization at other facilities? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

17. A Full service integrated offering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

If the vendor outsource part of the waste service, did you audit,
obtain permits and evaluate the back-up plans for each service:
a) RMW collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
b) Transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
c) Treatment and disposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

18. Proof of insurance for:

a) Certificates of Insurance and Additional Insured . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
b) Workers Compensation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
c) General Liability ($5MM minimum including an MCS-90 endorsement
for cleanup costs of accidental spills and/or accidents) . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
d) Event insurance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

19. Evidence of testing and certification for their employees (an accident with
their driver that creates a spill on the highway could be your problem):
a) Criminal background checks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
b) Drug testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
c) DOT Hazardous Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
d) OSHA blood borne pathogen training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO
e) Ongoing medical surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

20. Containers to meet your needs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

21. Accurate scales to measure waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

a) Tare weights excluding the weight of the reusable containers . . . . . . . . . . . . . . . ! YES ! NO
b) Regular monitoring of the scales to validate accuracy . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

22. Radiation monitoring of the waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ! YES ! NO

Footnotes
1. Medical waste consists of any solid waste generated in the
diagnosis, treatment, or immunization of human beings or
animals. Regulated Medical Waste (RMW) is also known
as biohazardous waste or infectious waste. This is a specific
type of waste which is contaminated by blood, body fluids
or other potentially infectious materials. This includes
infectious agents such as human pathological wastes,
human blood and blood products, used or unused sharps
(syringes, needles, and blades), certain animal waste, and
certain isolation waste.
2. Practice Greenhealth, formerly known as Hospitals for a
Healthy Environment (H2E), is an organization promoting
environmental sustainability in health care. Practice
Greenhealth embraces safer building products, clean air,
energy and water safety, safe working practices, and a
commitment to public health demonstrated through
waste volume and toxicity reduction.

www.stericycle.com 11 (rev 03/08)

SUMMARY
In today’s competitive, cost-driven, environmentally-focused economy, hospitals
deserve value for the regulated medical waste services they are purchasing.
This means not only efficient RMW removal, but also exemplary service that
smoothly integrates with the rest of the hospital operations.

RMW disposal vendors should offer:

• Full service from waste collection to treatment
to final documented disposal.

• Training and support in regulatory and

environmental compliance.

• Consulting focusing on waste minimization

and compliance audits.

• Consulting to segregate and minimize the

RMW streams.

• On-line reporting and manifests that track waste

from the generating department through shipment
to treatment facilities and to final disposal.

• Departmental barcoding capability

• Disaster planning and emergency preparedness

through redundancy of services and facilities.

The risk of utilizing a low cost/pound RMW vendor can put your healthcare facility
at risk due to cutting corners or simply lacking regulatory awareness. Identifying
a high-value RMW vendor requires due diligence on the part of the facility.

The following checklist and issues have been explored in this paper and are good
tools for any healthcare facility exploring contracted regulated medical waste
disposal services.

STC_RMWWHPAP_0308