🔎 Step 1: Waste Identification
Proper waste identification is the foundation of compliance. This includes:
A. Classify the Waste Type
Identify what kind of waste is being generated. The most common regulated waste types include:
Waste Type | Examples | Key Regulations |
Medical/Regulated Waste | Sharps, red bag waste, cultures | OSHA 1910.1030, DOT, state health departments |
Pharmaceutical Waste | Expired meds, chemotherapy agents | DEA, EPA Subpart P, RCRA |
Hazardous Waste | Solvents, corrosives, ignitables | EPA (RCRA), DOT |
Universal Waste | Batteries, lamps, mercury devices | EPA Universal Waste Rule |
Household Hazardous Waste (HHW) | Paints, cleaners, aerosols | Local solid waste authority rules |
B. Determine If the Waste is Regulated
Use the EPA hazardous waste determination process (40 CFR 262.11) or relevant medical waste rules to classify:
Is the waste infectious, hazardous, pharmaceutical, or sharps?
Is it regulated by OSHA, RCRA, DEA, or state/local authorities?
PureWay offers tools like waste stream analysis and regulatory consultation to help with this step.
🏢 Step 2: Site Risk Assessment
Evaluate the risk and exposure potential at the generation site:
Is the waste generated by employees, patients, or residents?
Are workers at risk of bloodborne pathogens exposure?
If yes, OSHA’s Bloodborne Pathogens Standard (29 CFR 1910.1030) applies.
Are pharmaceutical controls or drug diversion risks present?
DEA compliance may be needed (especially for controlled substances).
Does the site lack regular waste pickups?
Consider storage safety, spill potential, and volume overflow risks.
PureWay provides onsite compliance evaluations to assist with exposure control and service planning.
⚖️ Step 3: Volume Assumptions and Waste Generation Frequency
Understanding the quantity and frequency of waste generation helps narrow down the service type:
Low-Volume Generators:
Small clinics, dentists, tattoo studios, home healthcare
Typically produce <50 lbs of regulated waste per month
Medium/High-Volume Generators:
Hospitals, nursing homes, large labs, vet clinics
Generate waste daily or weekly, including multiple waste streams
Document:
Types and quantity of each waste stream
Frequency of generation (daily, weekly, monthly)
Use this to calculate storage capacity needs, container sizes, and service intervals.
♻️ Step 4: Select a Waste Disposal Method
Option A: Mail-Back Service
Best for: Low-volume, remote, or small generators
Advantages:
Fully compliant, pre-labeled systems (UN3291 for medical waste)
No DOT registration or manifesting required by the generator
No minimum pickup volume or contract
Convenient for home health, small clinics, residential sharps users
PureWay’s Mail-Back Benefits:
Systems for sharps, red bag waste, pharmaceuticals, and DEA-controlled substances
Prepaid return shipping via USPS
Includes waste tracking documentation and manifests
OSHA-compliant sharps containers
Option B: Contracted Hauler (Pickup Service)
Best for: High-volume, complex waste streams, or facilities requiring frequent service
Advantages:
Scalable for large volumes
Can handle multiple waste types under one provider
Often includes manifests, container supply, and documentation support
PureWay’s Pickup Service Benefits:
Scheduled pickups for regulated medical waste, hazardous waste, and universal waste
Full-service documentation and compliance management
Custom service frequencies and staff training options
Supports RCRA and Subpart P compliance
📄 Summary: Key Considerations
Criteria | Mail-Back | Contracted Pickup |
Volume | Low | Medium to High |
Frequency | Infrequent | Regular |
Location | Remote, residential, or small site | Commercial, large facilities |
Waste Types | Sharps, small RMW, non-controlled meds | All types, including bulk and hazardous |
Regulatory Simplicity | High | Requires more oversight (DOT, manifests) |
🔖 Final Notes
Ensure all staff are trained in OSHA Bloodborne Pathogens Standard if handling RMW.
Controlled substances must be handled per DEA destruction rules.
EPA generator status (e.g., CESQG, SQG, LQG) influences hazardous waste options.
👉 For a state-specific compliance guide, visit PureWay’s interactive map: 🔗 https://www.pureway.com/resources/map-temp