Regulated Medical Waste (RMW) Updates

The Virginia Department of Environmental Quality (DEQ) recently updated the regulations concerning its regulated medical waste (RMW), effective March 15. There were several key changes for MSV membership:

  1. The definition of “sharps” has been expanded and now explicitly includes culture slides and culture dishes, which shall be disposed of in sharps containers.
  2. Records of RMW treatment or shipment to offsite facility shall be maintained for 3 years by the generator.
  3. Generators of less than 250 gallons of RMW per calendar month must arrange for removal of such waste at least once per calendar month. No RMW may be stored for more than 45 calendar days.  Generators of more than 250 gallons must arrange for removal once a week.
  4. The definition of “storage” was updated to include all generators of RMW; whereas, previously it only applied to generators of 200+ gallons of RMW. There is a whole new section regarding storage, requiring RMW to be stored in a manner that maintains integrity of packaging, minimize potential for spills, is clean and orderly, and meets packaging and labeling requirements in the regulation.
  5. New rules pertaining to reusable RMW containers to ensure properly disinfected.
  6. New rules on how to handle spills of RMW—anyone handling RMW shall have a spill containment and cleanup kit onsite within the vicinity of where RMW is stored/managed. Such a kit must include material designed to absorb any liquids, one gallon of EPA-registered hospital grade disinfectant in a spray container, enough red plastic bags to enclose at least 150% of the RMW managed at the site, and relevant PPE.

If there are questions as to the new regulations, we encourage our members to work seek legal counsel, and if necessary, reach out to DEQ.