Mwm oct dec '14 final revised2

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Bu

ye 20 rs 14 Iss ’ G ue uid e

OCT-DeC 2014

VOL. X NO. 4

Attention Readers !

Are you looking for Products, Equipment or Services for your business or healthcare facility? If so, please check out these leading companies advertised in this issue:

Infectious & Non-Infectious Waste Containers & Linen Carts Bomac Carts – pg 6 Rehrig Healthcare Systems – pg 2 Snyder Industries Inc – pg 19 TQ Industries – pg 8 Infectious Waste Sterilizing Systems Clean Waste Systems – pg 24 The Mark-Costello Co – pg 6 Ozonator Industries – pg 23 STI Biosafe – pg 18 Liquid Disposal Systems Bemis Health Care – pg 7 Room Disinfection Systems Xenex – pg 5 Shredders Shred-Tech – pg 19 Vecoplan LLC – pg 20 WEIMA America – pg 8

By Alice P. Jacobsohn

A

significant amount of criticism has been published on the management of Ebola-contaminated waste, yet most of it fails to properly assess the jurisdiction of government agencies, misinterprets regulatory requirements, or sets impractical precedents, and, ultimately, fails to provide a solution.

Transportation

A

number of news articles have sited a conflict between the U.S. Department of Transportation (DOT) and the Centers for Disease Control and Prevention (CDC). For example, on October 14, a Fox News article titled, “Toxic mess: Agencies at odds over Ebola-waste disposal,” quoted Dr. Jeffrey Duchin, chairman of the public health committee for the Infectious Disease Society of America, saying that the CDC considers Ebola-waste safe to be handled by medical waste companies. That article also states that the DOT wants the waste to be “treated” before transport, which the article says is in conflict with the CDC. This article and many others state that medical waste companies cannot accept the waste. A few reference restrictive DOT regulations as the cause. This and similar articles and comments by so-called experts are incorrect. There is not a conflict in requirements between the DOT and CDC. The DOT’s regulations have always allowed for the transport of infectious substances such as Ebola-contaminated materials. The CDC’s assessment that this

type of waste is safe for transport does not in any way define how it should be transported, who is capable of transporting the waste, and where the waste should ultimately be managed for disposal. None of these issues have been addressed by the CDC because they are not within the CDC’s jurisdiction -- the CDC is not a regulatory agency, other agencies have responsibility for these issues, and the CDC’s resources are focused on patient care and disease prevention. The CDC has stepped in to assist hospitals with the management of Ebola-contaminated waste by working with the DOT and healthcare waste companies whose business plans do not include Ebola waste management. When the U.S. Congress enacted the Hazardous Materials Transportation Act in 1975, the DOT was given jurisdiction to create regulations for the management of hazardous materials, which includes infectious substances, in transport. Originally, the DOT based the classification system for managing infectious waste using the CDC’s bio-hazardous waste categories in which infectious materials were placed into four management categories based on the level of risk of the spread of disease. The problem was that the CDC’s definition of risk was based on materials found in laboratories not in hospitals or in transport; thus, the classification system used by the DOT was awkward in practice. Ultimately, as more focus on the Continued on page 3


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