Bemis Quick Drain-HF

Maybe you had your gallbladder taken out, or you came to the emergency room from a traffic accident and a lot of your blood ended up on the floor, or you had liposuction to remove that 5 pounds of belly fat. Yuck! Where does all of that stuff go when it leaves you?

Welcome to the Land of Medical Waste. It’s not a no-man’s-land. Lots of folks are waiting there for you, eager to help with this sticky problem. Some are vendors with products designed just for you; some are federal, state, and local agencies that regulate how medical waste and associated risks should be handled.

Regulations are myriad. We’ll touch on regulations from the Occupational Health and Safety and Health Administration (OSHA) and the federal Department of Transportation (DOT), plus some guidelines from the Environmental Protection Agency (EPA). Medical facilities are obligated to observe the rules, so it’s important to understand how each agency defines medical waste. Each agency has its own agenda, so they each approach dealing with infectious waste from a different viewpoint: OSHA rules protect employees from workplace hazards; DOT rules protect the public and transportation workers; EPA guidelines protect the environment.

OSHA’s take on medical waste
OSHA is all about eliminating or minimizing employee exposure to hazards. The best way to minimize the risk of occupational exposure to infectious waste is to contain it properly and not to overfill containers, because they could break open. Torn, damaged, or leaking containers must be packed inside a second container. Never open a sealed container.

Bloodborne pathogens standard
Accidents will happen, and OSHA demands you be prepared. The Bloodborne Pathogens Standard (29 CFR 1910.1030) mandates that employers must have an exposure control plan (ECP), and it must be accessible to employees. The ECP addresses matters such as identifying job positions and procedures that place workers at risk of exposure to bloodborne pathogens; proper engineering and work-practice controls that reduce the likelihood of exposure; personal protective equipment; and employee training, among other things. Section (c)(1)(iv) in the Standard notes that, because technology is constantly advancing, healthcare facilities are required to examine, update, and document the practices and processes they use to control risk of bloodborne-pathogen hazards annually at the very least.

OSHA defines regulated waste as
• Liquid or semi-liquid blood or other potentially infectious materials
• Contaminated items that would release blood or other potentially infectious materials in a liquid or semi-liquid state if compressed
• Items that are caked with dried blood or other potentially infectious materials and are capable of releasing these materials during handling
• Contaminated sharps; and pathological and microbiological wastes containing blood or other potentially infectious materials

Paragraph (d)(4)(iii)(B)(1) of the Standard states: "Regulated waste shall be placed in containers which are (1) closable; (2) constructed to contain all contents and prevent leakage of fluids during handling, storage, transport, or shipping; (3) labeled or color-coded in accordance with paragraph (g)(1)(i) of this Standard; and (4) closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping." If state, territorial, or local agencies have imposed stricter requirements, OSHA mandates compliance with them as well (d][4][iii][C].

Rumor has it that OSHA is really cracking down on violators of the Bloodborne Pathogens Standard. "They’re starting to enforce it more; they’re out in full force making sure hospitals are compliant," observed Nancy Steinpreis, Associate Product Manager, Bemis Health Care, Sheboygan Falls, WI. There’s no time like the present to bring your facility into compliance.

EPA’s position on medical waste
Medical waste, defined by the EPA, is "any solid waste that is generated in the diagnosis, treatment, or immunization of human beings or animals, in research pertaining thereto, or in the production or testing of biological materials, including but not limited to":

Cardinal Health's SAF-T Pump

• Soiled or blood-soaked bandages
• Culture dishes and other glassware
• Surgical gloves discarded after surgery
• Discarded surgical instruments—scalpels
• Needles used to give shots or draw blood
• Cultures, stocks, swabs used to inoculate cultures
• Removed body organs: tonsils, appendices, limbs, etc
• Lancets used to prick fingers for blood

The EPA also notes that paper and plastic products that would release blood or body fluids if they were compressed must be red-bagged, along with items that have dried blood or body fluids on them, such as contaminated sharps. Again, state and local standards may be more stringent.

DOT’s role
It’s not a good idea to cart red-bagged waste around a facility any more than is necessary or to let it sit in storage indefinitely. The DOT gets in on the act because red-bag waste must be transported to a proper disposal facility such as a landfill. DOT has strict requirements for packaging medical waste that will be transported over public highways. Packages must be rigid, leak-resistant, impervious to moisture, strong enough to prevent tearing or bursting, sealed to prevent leakage, puncture-resistant, break-resistant, and tightly lidded for fluids in quantities greater than 20 cm3. Of note, the cost for such packaging can add up to 20% to the cost of disposal of infectious waste.

The DOT succinctly defines infectious substances as "materials known to contain or suspected to contain a pathogen with the potential to cause disease upon exposure." The DOT has adopted the World Health Organization’s classification system, which categorizes infectious materials into four risk groups, based on pathogenicity, mode and ease of transmission, degree of risk to individuals and communities, and reversibility of the disease through known and effective preventative agents and treatments. The system delineates and differentiates risks associated with specific pathogens and assesses the degree to which specific pathogens should be regulated, based on potential risk to transportation workers and the general public.

State and local regulations
Yep, on top of federal regulations there can be state and local regulations. "Federal regulations are pretty straightforward," stated Steinpreis, "but state and local regulations are just crazy. Just because the federal agencies say a certain practice is OK doesn’t mean that state and local rules will agree." State and local regulations not only vary widely from state to state, they are more stringent than federal rules.

Nevertheless, compliance is mandatory, so it’s imperative that state and local rules be figured into facilities’ waste-management policies and procedures. Finding these regulations can be a difficult road to navigate. Here’s a page on the EPA web site, recommended by Stephanie Lipp, Director of Marketing for the Surgical Business, Cardinal Health, McGaw park, IL, that may be useful in identifying your state’s requirements: http://www.epa.gov/epaoswer/osw/stateweb.htm.

A threat to public health?
Some of the products used for disposing of medical waste send infectious fluids down a hopper or directly into a sanitary sewer system, where it’s treated along with other biological wastes. Initially that might sound like a threat to public health, but the EPA takes the position that the risk is not so great compared with the main sources of pathogenic microbes in sewage: bacteria and viruses that live in feces. Since there is no wealth of epidemiological evidence demonstrating that medical waste presents a public health risk, extreme control measures don’t appear to be in order.

When Cardinal Health was developing the SAF-T Pump system, they consulted with city waste-management teams about the advisability of disposing of infectious liquids into a sanitary sewer system. Stephanie Lipp, Director of Marketing for the Surgical Business, Cardinal Health, McGaw Park, IL, related their experience: "During the design and development process, we talked to the waste-management team in several major municipalities. They told us they prefer that hospitals just dispose of the waste as is; they deal with the bioburden when it reaches the wastewater treatment facility. There are a couple of things that are really important when treating infectious liquid: One is the quantity of liquid and the quantity of disinfectant that you marry together; two, the dwell time is crucial." Since it’s difficult to determine how much disinfectant to use and how much time the chemical needs to do its job, it’s a responsibility best left in the hands of the wastewater treatment facility.

Minimizing costly red-bag waste
An alternative to emptying canisters of potentially infectious fluids into a sanitary sewer is that containers of blood and body fluids could capped and placed in red bags for disposal; however, if the facility generates a few tons of medical waste per month, red-bag charges can take a serious bite out of a facility’s budget. Considering that the average charge for red-bag waste is about 25 cents per pound and that a 3-liter suction canister weighs approximately 7.5 pounds when full (cost and weight can be higher if a product is added to solidify the liquid), some facilities could spend thousands of dollars each month just on disposing of full canisters.

Minimizing the amount of waste that goes into red bags is an economical must. A real plus is that it has a positive impact on the environment. Try to choose products that generate less waste or that can be reused. Dispose of infectious waste, non-infectious (white) trash, and recyclables in clearly marked, separate containers. Place the containers as close as possible to the spot where it’s generated to eliminate the need for separating later, which could be hazardous and costly. Educate employees on the costs of red-bag waste and enlist their help in identifying ways to reduce it.

Help you can use: Products that reduce red-bag waste
Bemis Manufacturing’s product is named Quick Drain for a reason. Steinpreis explained: "The system uses our high-flow suction canisters. It confines the waste and drains it directly into a sanitary sewer system. The unit mounts to the wall and can be placed wherever you want, as long as it can hook up to plumbing. Fit the canister into the unit, pull the handle, tip it over, and the contents drain out the top and directly into the sanitary sewer system. (Go to www.bemismfg.com to view a video of how the Quick Drain System works.) No one has to come into contact with liquid, and there is no chance for aerosolization of infectious liquid. It’s simple to use; it drains canisters quickly, at rate of 500 cc per second; it has low maintenance needs; it’s low cost to operate; and it has a rinse feature that customers really like. The best thing is that you don’t need any disposables to use it—no dip tube or drain tube, disposables that cost money."

Steinpreis told HPN about a cost comparison that Bemis Health Care conducted for a 10-hospital integrated delivery network: "Some were pouring, some were solidifying. We were able to save that system almost $200,000 per year. Payback on the units was 3 months. The cost savings is significant for hospitals that use solidifiers. Red-bag waste is very expensive, so it’s also important to consider any requirements for disposable components and how the canister is disposed of once it’s emptied when looking at a disposal system."

Cardinal Health’s SAF-T Pump System also delivers potentially infectious liquid waste directly into the sanitary sewer system. Lipp explained: "When used in conjunction with a suction canister manufactured by Cardinal Health, it is a closed disposal system. Some competitors’ systems are not closed, allowing potentially infectious aerosol particles to escape into the air. The SAF-T Pump is safe for HCWs, simple to operate, and economical for the hospital to install and use. It has a very small footprint, is powered by water, has no internal moving parts, and does not require an electrical hook-up. Virtually nothing can break or stop working. The suction canister can be disposed of via red-bag or white-bag trash, as specified by the local waste management and municipality."

Lipp told HPN the product came about by customer request. "Cardinal developed the SAF-T Pump System because our customers asked us to identify alternative ways to dispose of liquid medical waste. We conducted extensive research with end-users and key influencers. The product was tested in 10 beta-site environments before it was officially launched in September 2003."

Here’s how the system works: "The SAF-T Pump System works in tandem with Cardinal’s suction canister. It’s comprised of a pump, a dip tube that’s inserted inside the suction canister, and a pump tube that facilitates the connection between the SAF-T Pump and the suction canister. It’s very simple: all you have to do is turn it on, and the infectious liquid is pumped directly into a sanitary sewer system. Most often it is plumbed directly into the hospital’s sewer line. It totally bypasses the hopper, but we recommend that most customers install it adjacent to the hopper, because there’s a water line and a sanitary-sewer connection there. The SAF-T Pump System is compliant with guidelines established by the EPA, OSHA, the Centers for Disease Control and Prevention, and the Association of Operating Room Nurses requirements."

The SAF-T Pump System can significantly save costs. Lipp notes, "Customers who are disposing of capped, full suction canisters in red-bag waste will see a cost savings. The cost to dispose of medical waste is determined by weight. A full canister weighs maybe 8 pounds; an empty canister weighs about 2 pounds. Customers who currently are using a solidification agent also will see a cost savings because the solidification agent is no longer needed." Cardinal has a nifty cost-analysis tool for implementing the SAF-T Pump System; obtain it by contacting Rita Hayes at rita.hayes@cardinal.com. This contact also can be used to request information on Cardinal’s new CEU program on liquid medical waste, disposal techniques, and employee safety, expected to be available early in 2005.

Lipp highlighted Cardinal’s goals: "It is essential that we respond to our customers needs, offering products and solutions that are cost-effective and efficient. The SAF-T Pump meets that need. It does seem that some hospitals are more interested in saving money, while some are more concerned about patient safety, but clearly the SAF-T Pump addresses both of those needs." HPN

Sources:
Occupational Safety and Health Administration. Bloodborne Pathogens Standard (29CFR) 1910.1030. www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=1005.
Environmental Protection Agency. Medical waste. www.epa.gov/epaoswer/other/medical.
Department of Transportation. Hazardous materials: revision to standards for infectious substances; final rule 49 CFR Part 171 et al. Washington, DC; 2002. http://search.bts.gov/ntl/query.html?qt=infectious+substances&qp=&col=dotbot&SearchGoButton.x=31&SearchGoButton.y=24
Reinhardt PA, Gordon JG, Alvarado CJ. Medical waste management. In: Mayhall CG. 1st ed. Hospital Epidemiology and Infection Control. Baltimore, MD: Williams & Wilkins; 1996: 1099-1108.
Barlow RD. Proper liquid waste disposal mines solid gold bottom line. Healthcare Purchasing News 2004;28:60-64.

Other useful Web sites:
American Biological Association; www.absa.org/riskgroups/index.html.
Centers for Disease Control and Prevention; www.cdc.gov/od/ohs/biosfty/biosfty.htm.
World Health Organization. Medical waste. www.who.int/topics/medical_waste/en.