🗓️ Effective: 1/1/2025
This Waste Acceptance Policy ("Policy") outlines the types of waste accepted by PureWay Compliance, Inc. (“PureWay”) and the proper methods of packaging, segregation, and service designation.
This Policy is binding upon all Clients and is incorporated into all active service agreements.
Its purpose is to ensure regulatory compliance, protect personnel, and limit liability for both PureWay and its Clients.
⚖️ I. Generator Responsibility and Liability
The Generator is solely and fully responsible for the proper identification, classification, characterization, segregation, and packaging of all waste prior to collection or shipment through any PureWay service.
This includes determining whether waste is hazardous, regulated, controlled, or non-conforming under any applicable federal, state, or local regulation.
PureWay does not assume responsibility for:
Generator misclassification or misidentification of waste;
Improper packaging or labeling by the Generator;
Violations arising from the Generator's failure to comply with DOT, EPA, OSHA, DEA, or USPS regulations;
Acceptance or transportation of non-conforming or prohibited waste due to generator error.
PureWay reserves the right to reject, return, or surcharge any waste that does not meet this Policy or regulatory standards.
The Generator retains title and liability for all non-conforming waste at all times, even if discovered after collection or shipment.
✅ II. Acceptable Waste by Service Type
A. Regulated Medical Waste (RMW)
🟩 RMW accepted in:
PureWay RMW mail-back systems
Pickup containers marked with the UN3291 biohazard symbol
🧪 RMW includes:
Sharps (in rigid, puncture-resistant containers)
Blood-soaked materials, soaked gauze, saturated PPE
Culture dishes, petri plates, and devices used to contain infectious agents
IV bags and tubing with blood or OPIM
Isolation waste
Disposable surgical instruments
Dialysis waste
🔴 RMW excludes:
Radioactive, hazardous, or chemical waste. See Section III.
B. Sharps Disposal
🟧 Sharps disposal accepted in:
PureWay Sharps Disposal by Mail containers
📍 Sharps disposal includes:
Needles, syringes with or without residual medication
Lancets, scalpels, pipettes
Broken glass contaminated with blood/OPIM
💡 Important:
All sharps must be placed directly into the sharps container.
Do not overfill containers.
Containers must be securely closed before return.
C. Non-Hazardous Pharmaceutical Waste
🟨 Non-hazardous pharmaceutical waste accepted in:
PureWay Non-Hazardous Pharma Mail-back containers
Designated facility pickup containers
💊 Non-hazardous pharmaceutical waste includes:
Expired or unused non-controlled, non-hazardous medications
Tablets, capsules, or ointments without hazardous or DEA scheduling
🚫 Non-hazardous pharmaceutical waste excludes: Controlled substances and RCRA hazardous drugs.
D. Hazardous Waste & RCRA Pharmaceutical Waste
🟥 Hazardous waste & RCRA pharmaceutical waste accepted in:
PureWay Hazardous Waste services (must be separately contracted)
☣️ Hazardous waste & RCRA pharmaceutical waste includes:
RCRA-listed pharmaceuticals
P-, U-, or D-listed chemicals
Chemotherapy bulk waste
Formaldehyde, glutaraldehyde, solvents
Batteries, mercury devices, aerosol cans
Compressed gas cylinders
📝 Hazardous waste & RCRA pharmaceutical waste labeling: Must use DOT-compliant, UN-rated containers with appropriate hazard labeling.
❌ III. Unacceptable / Prohibited Wastes (All Services)
PureWay does not accept the following wastes under any service:
Category A Infectious Waste: Capable of causing fatal diseases upon exposure (e.g., Ebola)
Human Remains/Fetuses: Includes full torsos, limbs, fetal material
Radioactive Waste: Any item exceeding EPA radiation limits
Controlled Substances: DEA Schedule I-V drugs, unless via DEA-approved collection program
Mercury Dental Waste: Contact or non-contact amalgam, chairside traps, vacuum filters
Loose Liquids or Leaking Containers
Improperly Packaged or Unlabeled Waste
Overfilled or overweight containers (>50 lbs)
📦 IV. Packaging, Labeling & Storage Requirements
Packaging, labeling & storage have the following requirements:
Sharps: Rigid, puncture-resistant, sealed, labeled with biohazard symbol.
RMW Bags: Red biohazard bags; tied when 3/4 full; placed in DOT-approved boxes.
Boxes: Secure bottom with tape, seal top when full. Must be labeled with “UN3291” and biohazard symbol.
Hazardous Waste: Must use black PGII UN-rated containers; clearly labeled per contents.
Storage: Containers must be kept in a secure area until pickup or return shipment.
All packaging must comply with DOT (49 CFR 173.197) and OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030).
🔄 V. Service Alignment Chart
Waste Type | Accepted By | Container Type |
Sharps | Sharps Disposal by Mail | PureWay Sharps mail-back system |
RMW (non-sharps) | RMW Pickup or Mail-Back | UN3291 marked biohazard containers |
Non-hazardous Pharmaceuticals | Pharma Mail-Back or Pickup | Non-hazardous pharmaceutical containers |
RCRA Hazardous Waste | Hazardous Waste Pickup | UN-rated PGII black containers with hazard labeling |
Chemotherapy Waste (Trace) | RMW (if trace only) | Labeled "Trace Chemo" containers |
Chemotherapy Waste (Bulk) | Hazardous Waste Pickup | Black UN-rated PGII containers |
Batteries, Aerosols, Mercury Devices | Hazardous Waste Pickup | Approved hazardous waste containers |