The 2022 US Government guidance on
Managing Solid Waste Contaminated with a Category A Infectious Substance addresses planning for Category A waste management activities, including considerations for developing, evaluating, and revising organizational or jurisdictional plans and protocols. Overarching planning considerations and governmental roles and responsibilities as they relate to Category A waste are also addressed. This document contains information for and describe responsibilities of those who generate, treat or inactivate, transport, and dispose of Category A waste. Also included is a section on worker health and safety discusses protecting employees involved in waste management activities from initial generation to final disposition. The guidance is supplemented by several appendices that provide additional resources, assist with decision making, and address questions and answers about Category A waste.
Key Points
- A Category A infectious substance is a material known or reasonably expected to contain a pathogen that is in a form capable of causing permanent disability or life-threatening or fatal disease in otherwise healthy humans or animals who are exposed to it, consistent with international classification (United Nations [UN] 2814).
- Infectious waste, including materials contaminated with Category A infectious substances, can be managed safely.
- Leadership within healthcare facilities; laboratories; state, local, tribal, and/or territorial (SLTT) governments; waste management companies; and other entities that may or will need to manage Category A waste should ensure their organizations have plans to address the entire waste lifecycle, from initial generation of the infectious waste to final disposition of any treated byproducts (residuals).
- Hospital care of a person infected with certain pathogens classified as a Category A infectious substance, particularly Ebola or another hemorrhagic fever virus (HFV), can result in large volumes of potentially infectious waste, especially for diseases associated with severe illness and lengthy hospital stays.
- Outside of hospitals, people infected with certain pathogens classified as Category A infectious substances, such as Ebola and other HFVs, may contaminate their homes, vehicles in which they travel, and other environments before they are hospitalized. Category A waste may also originate from laboratories (e.g., research, clinical) that work with Category A pathogens, particularly when they intentionally cultivate these pathogens. Housing, care, and post-mortem management of animals infected with certain Category A pathogens also results in Category A waste.
- Every effort should be made to minimize the amount of Category A waste generated. Category A waste should be physically separated, if practical, from other solid waste at the point of origin. Similar considerations should be made for separating Category A waste from other, non-infectious hazardous materials.
- Throughout the waste lifecycle, employers must protect workers from occupational exposure to pathogens, chemicals, other hazardous materials, and other hazards that could cause injury and illness.
- The U.S. Department of Transportation (DOT)/Pipeline and Hazardous Materials Safety Administration (PHMSA) regulates movement and certain other aspects related to management of Category A infectious substances, including waste that is known or suspected to be contaminated with them, through its Hazardous Materials Regulations (HMR). Additional federal and SLTT laws and regulations may apply to various aspects of waste management.
- Typically, the safest and best options for treating Category A waste so that it is no longer infectious—a process known as “inactivation”—are implemented on-site, where the waste is generated. Common inactivation methods include autoclaving and incineration. However, in specific circumstances where those options are not available, alternative treatment methods, including chemical disinfection and alkaline hydrolysis digesters, may also be appropriate.
- When waste cannot be treated on-site, it must be sent off-site to special facilities typically operated by commercial waste management companies. These facilities, regulated and permitted by SLTT authorities, primarily use autoclaves and incinerators to treat waste on a larger scale than what most hospitals, laboratories, and other entities are capable of doing on-site.
- Before offering it for transportation, individuals and entities responsible for generating infectious waste must classify it appropriately, including as Category A waste when required.
- Individuals and entities must classify waste as hazardous waste when required under Resource Conservation and Recovery Act (RCRA) requirements. These are set and enforced by the U.S. Environmental Protection Agency (EPA) or by states/territories authorized to implement the RCRA hazardous waste program in lieu of EPA.
- Category A waste may be safely transported off-site for inactivation in packaging meeting HMR requirements or the alternative packaging requirements of a DOT special permit. The HMR also require that waste transporters comply with certain labeling and paperwork requirements. Properly classifying (i.e., as Category A) and packaging waste begins at its point of origin.
- Management of waste that contains both a Category A infectious substance and certain other materials, such as those that are radioactive, must comply with regulations applicable to all substances in the waste. Such instances would need to be addressed on a case-by-case basis and may require issuance of a special permit to address the unique combination of potentially hazardous materials.
- Waste that has been inactivated through an effective treatment method, along with any materials left over after treatment (i.e., residuals), is no longer infectious, poses no risk of infection, and is not considered to be regulated medical waste (RMW) or a hazardous material (unless other types of regulated hazardous materials are present) under federal or SLTT laws and regulations. Such waste is no longer considered a Category A infectious substance subject to the HMR.
- Residuals, such as incinerator ash, must be evaluated to determine if the residual is still hazardous. Even though materials that have been properly incinerated are no longer infectious, ash may be categorized as hazardous waste due to its ability to concentrate certain toxic substances (e.g., metals) that may have been present in the original waste or in other waste incinerated at the same time.
- Residuals must be transported and disposed of in accordance with SLTT requirements and standard protocols for their disposal. Disposal options may vary depending on whether residuals contain hazardous materials.
- At all stages of waste management, all involved parties should ensure effective communication with one another about the nature and content of the waste to help ensure safe, effective management of waste all the way to ultimate disposal.
SIGNIFICANT CHANGES
This section summarizes significant changes in the June 2022 guidance compared to the August 2019 version. The June 2022 version:
- Includes a Monkeypox Appendix
- Adds references to the U.S. Environmental Protection Agency (EPA)-registered hospital disinfectants with an emerging viral pathogen label claim or any product on List Q with an emerging pathogen label claim, whenever appropriate
For more information, see the full-text version of Managing Solid Waste Contaminated with a Category A Infectious Substance.
