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🗂️ California Regulated Medical Waste (RMW) Disposal Guidelines

Guide to California medical waste rules for LQGs, SQGs & home users—includes storage limits, disposal rules, training & registration steps.

Updated over 3 months ago

Comprehensive Compliance Reference for Large Quantity Generators (LQGs), Small Quantity Generators (SQGs), and Individual Sharps Users

Downloadable Attachment: California Waste ManagementGuidelines.pdf


ℹ️ Definitions

According to the California Medical Waste Management Act (MWMA) [Health & Safety Code (HSC) §117600–118360]:

  • Regulated Medical Waste (RMW): Includes biohazardous waste, sharps waste, trace chemotherapy waste, and other infectious materials generated during medical treatment, research, or diagnostic processes.

  • Small Quantity Generator (SQG): Generates less than 200 lbs of medical waste per month.

  • Large Quantity Generator (LQG): Generates 200 lbs or more of medical waste per month.


🏢 Governing Agencies In California

Agency

Role

California Department of Public Health (CDPH)

Oversees registration and enforcement of the MWMA

Local Enforcement Agencies (LEAs)

Implement CDPH regulations at the county level

California Division of Occupational Safety and Health (Cal/OSHA)

Enforces OSHA standards including Bloodborne Pathogens Standard (29 CFR 1910.1030)

California Department of Resources Recycling and Recovery (CalRecycle)

Regulates household hazardous waste and sharps disposal

United States Postal Service (USPS)

Governs mail-back of medical waste under Pub 52, Section 346


🧾 Requirements for Small Quantity Generators (SQGs)

  • Registration: Must register with CDPH or LEA as a SQG (HSC §117930)

  • Medical Waste Management Plan: Not required to submit but must maintain on-site procedures (HSC §117935)

  • Storage Limits:

    • Biohazardous waste: ≤7 days at >32°F; ≤90 days refrigerated (HSC §118280)

    • Sharps: Dispose when 3/4 full; must be in approved sharps container (HSC §118285)

  • Treatment: May use registered medical waste hauler or approved mail-back system (HSC §118040)

  • Transportation: May self-transport up to 20 lbs to a consolidation point if registered (HSC §118030)

  • Training: OSHA BBP training required annually (29 CFR 1910.1030)


📃 Requirements For Large Quantity Generators (LQGs)

  • Registration: Must register with CDPH or LEA as an LQG (HSC §117950)

  • Medical Waste Management Plan: Required and must be submitted (HSC §117960)

  • Storage Limits:

    • Biohazardous waste: ≤7 days at >32°F; ≤90 days if refrigerated (HSC §118280)

    • Sharps: Dispose when 3/4 full or per facility's plan (HSC §118285)

    • Off-site storage: ≤30 days from receipt date (HSC §118310)

  • Treatment: Must obtain permit to treat on-site (HSC §118130)

  • Transportation: Must use registered medical waste hauler (HSC §118000)

  • Recordkeeping: Maintain logs and manifests for 3 years (HSC §118040(f))

  • Training: OSHA BBP training required annually; keep records (29 CFR 1910.1030)


💉 Requirements For Individual Sharps Users (Home Injection Patients)

  • Sharps Storage: Must use FDA-cleared sharps container. Dispose when 3/4 full. (CalRecycle Guidance)

  • Disposal Methods:

    • Use USPS-compliant mail-back system (USPS Pub 52 Sec. 346)

    • Or take to the collection site, pharmacy, or HHW facility (HSC §118286)

  • Prohibited Disposal: Illegal to place sharps in trash or recycling (HSC §118286)


🏢 Storage Time Limits Summary

Waste Type

Storage Location

Max Duration

Citation

Biohazardous Waste

On-site (>32°F)

≤7 days

HSC §118280(c)

Biohazardous Waste

Refrigerated (<32°F)

≤90 days

HSC §118280(c)

Sharps Waste

On-site

Until 3/4 full or plan limit

HSC §118285(d)

All Waste

Off-site storage facility

≤30 days from receipt

HSC §118310


💡 PureWay Compliance Solutions

  • For SQGs & LQGs:

    • State-compliant sharps and RMW mail-back systems (USPS UN3291-compliant)

    • On-site medical waste pickup and disposal

    • Medical Waste Management Plan templates and documentation tools

    • OSHA-compliant BBP training for staff

  • For Home Users:

    • FDA-cleared sharps containers

    • USPS-compliant mail-back kits with prepaid return


📚 Key Regulatory Sources

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