Kevin Noel

California Medical Waste Management Guide

If you generate medical waste in California, you should be very familiar with the California Medical Waste Management Act (MWMA) to maintain compliance with your medical waste.

California Medical Waste Disposal Management Guide

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California Medical Waste Management Guide

If you generate medical waste in California, you should be very familiar with the California Medical Waste Management Act (MWMA).

This document outlines everything a California medical waste generator needs to know about generating, handling, storing, and properly disposing of medical waste.

Since the medical waste management act is 59 pages, this guide will not cover everything - but it does give the basics and point you in the right direction to ensure you are properly generating, segregating, storing, transporting, and disposing of your California medical waste.

Definition of Medical Waste

The MWMA defines medical waste as:

“Medical waste is any biohazardous, pathology, pharmaceutical, or trace chemotherapy waste not regulated by the federal Resource Conservation and Recovery Act of 1976.”

Importance of Compliance

Compliance is a necessity to protect your facility, staff, patients, community, and environment. Since biohazard waste contains potentially infectious materials, mishandling your waste can increase the risk of injury and infection which can result in serious illness and even death.

Due to the complications involved with improper medical waste disposal, regulated medical waste is heavily regulated on a state and federal level.

Some of the relevant enforcement organizations for California medical waste management, handling, and disposal include:

The Occupational Safety and Health Administration (OSHA):

OSHA regulates all aspects of medical waste management that involve the safety of workers. OSHA’s bloodborne pathogens standard has provisions to protect employees during containment, storage, and transportation of regulated medical waste. OSHA has given out large fines for bloodborne pathogen related violations during inspections of medical waste generating facilities.

The Department of Transportation (DOT):

DOT regulates the transportation of infectious substances, including regulated medical waste. DOT requirements involve preparing, packaging, transporting and even signing medical waste manifests.

The Centers for Disease Control and Prevention (CDC):

CDC regulates medical waste in preventing the spread of infectious diseases.

Environmental Protection Agency (EPA):

Regulates hazardous wastes, including medical waste, in efforts to protect human health and the environment. This covers medical waste disposal from the point of generation to the point of final treatment and disposal to ensure medical waste goes through proper treatment.

Registration

California medical waste generators need to be registered with a local enforcement agency to generate medical waste. In order to register, you will need to complete applications and pay fees made payable to the Medical Waste Management Fund.

Depending on the amount of waste you generate, you will be classified as a large quantity generator (LQG) or a small quantity generator (SQG). If you generate more than 200lbs of medical waste monthly, you will be a LQG and you will have differing guidelines than a SQG.

Containment and Storage of Medical Waste

Information regarding containment and storage of medical waste can be found in chapter 9 of the MWMA

There is also a regulated medical waste state resource locator outlining in-depth information on regulated medical waste including registration, management planning, segregation and storage, treatment, disposal, and tracking.

The basics of containment and storage of regulated medical waste in California include:

Medical Waste Segregation (118275):

At the point of generation, medical waste should be properly segregated in order to contain it separately from other wastes. Each stream of waste has a specific container to ensure it is properly treated for disposal. These containers include: biohazardous waste, pathology waste, sharps waste, trace chemotherapy waste, pharmaceutical waste, hazardous waste, and regular trash.

Biohazardous waste:

Biohazardous waste or red bag waste should be placed in an appropriate USDOT approved biohazard bag that is red and has the international biohazard symbol. This bag should be tied in compliance with the MWMA to prevent any leakage or expulsion. After generation, this bag should be placed inside of a biohazardous waste container which is rigid, leak resistant, has tight fitting covers, and is kept in good condition. This container is typically red and should be labeled “Biohazardous waste” or “BIOHAZARD” with the international biohazard symbol on the lid and sides. 

Sharps waste:

All sharps waste should be placed inside of a sharps container which is puncture resistant, sealable, and labeled as “sharps waste” or with the international biohazard symbol and word “BIOHAZARD.” Sharps containers have a 3/4ths fill line and should be sealed once this line is met. Once a sharps container is appropriately sealed, it can be placed inside of a biohazard bin alongside other biohazard waste.

Pathology waste:

Pathology waste must be segregated from other red bag wastes and placed into a biohazard container which is labeled “Pathology Waste” or “PATH” on the lids and sides.

Trace Chemotherapy waste:

Trace chemo waste should be placed in a secondary container labeled “Chemotherapy Waste” or “CHEMO” on the lids and sides. Typically trace chemotherapy waste is placed into a yellow bag and a yellow container. It is important to note that sharps waste contaminated with chemotherapeutic agents must go in sharps containers labeled as chemo containers.

Pharmaceutical waste:

Non-hazardous pharmaceutical waste not subject to other regulations should be placed in secondary containers labeled “INCINERATION ONLY” on the lid and sides and in compliance with DEA requirements. Typically these are white and blue containers and oftentimes sequestration devices are used to ensure security of its contents.

Designated Accumulation Area:

All medical waste containers should be stored in a designated accumulation area meant to deny access to unauthorized persons and other protections in compliance with section 118310.

Accumulation Times

Each of these waste streams have additional storage requirements which regulate how long the waste can be stored or accumulated before transported offsite for treatment.

Biohazardous waste, trace chemotherapy waste, and pathology waste
should be disposed of at minimum within 30 days assuming it is not stored at sub 32 degrees Fahrenheit. If you generate more than 20 pounds monthly, you may need to have waste collected within just 7 days of generation.

Sharps waste must be disposed of within 30 days once full.

Pharmaceutical waste must be disposed of within 90 days once full and at a minimum of once annually.

Hazardous Waste Management

There are additional regulations for hazardous waste - which differs from medical waste.

Make sure you are following the regulations outlined in the Official California Code of Regulations (CCR) in title 22 which covers:

✔ Hazardous Waste Management System: General

✔ Identification and Listing of Hazardous Waste

✔ Standards Applicable to Generators of Hazardous Waste

And more on hazardous waste management in California.

Medical Waste Treatment Methods

Appropriate treatments are outlined in chapter 8 of the MWMA which includes approved methods for each stream of medical waste in codes 118215 through 118225, but since this is a guide specifically for medical waste generators and they typically have medical waste treated offsite, we will only include information which concerns the generator.

Since you are ultimately responsible for all waste from the point of generation to the final point of disposal under the cradle to grave requirement, it is crucial that you choose a trusted medical waste disposal service.

After collection takes place, you are still responsible.

This means you should be focusing on properly handling, segregating, containing and preparing waste for transportation -  and choosing a good medical waste partner who will dispose of the waste in accordance with California regulations and send you all the necessary documents you need to retain of medical waste treatment.

It is crucial that all waste is properly identified and goes into the correct container to ensure it is disposed of properly. For example, non-hazardous pharmaceuticals are required to be treated using incineration only, and placing them in the wrong container early in the medical waste journey means it will not be properly disposed of.

Safety Plans and Training

There are a variety of training certifications and safety plans that may be required for your facility. Knowing how to properly handle tasks is essential in avoiding workplace injuries and maintaining medical waste compliance. Check out the resource below for training information such as Bloodborne Pathogens, Hazard Communication, and DOT - RMW.

compliance pdf

Record Keeping

Medical waste generators are required to maintain documents and records which can be requested by enforcement agencies.


As a medical waste generator, you are required to maintain completed tracking documents for all of your untreated medical waste collected and transported off site for a period of three years. You also need to maintain training certifications for staff which prove they are certified and properly trained for their work tasks.

Additionally, you need an appropriate exposure control plan, fire prevention plan, hazard communication program, and emergency action plan.

Choosing a Biohazard Disposal Company

Since you are ultimately responsible for the medical waste you generate up until the final point of disposal, it is crucial to choose a trusted partner to dispose of your medical waste.

At Eco Medical, we are experts on California medical waste disposal and can help ensure you are compliant with all California medical waste regulations. We offer compliance training, safety plans, audits, document shredding, and medical waste disposal pickups. 

We have been a leader in biohazard waste management in California since 2013 with a perfect compliance record. Not only will we ensure your compliance to avoid any potential fines or penalties in California, but you will almost certainly save on your medical waste disposal costs as well.

Let’s face it - medical waste disposal compliance can be confusing. Get in contact with one of our local medical waste experts today to ensure you are compliant with all California medical waste management regulations.

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Health care facilities save 34% on average when choosing Eco Medical for their California medical waste disposal needs

Eco Medical CEO

KEVIN NOEL

Sales Account Executive

Passionate about creating exposure around practical products and services. My goal is to aid California medical facilities in exploring a more local, affordable, and personable service for medical waste disposal.

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