Do You Really Have to Weigh Your Infectious Waste?
By Barbara K. Garrison, M.S., CHMM, CET
Yes, you really do. The requirement is found in the Ohio Administrative Code 3745-27-30, Standards for Generators of Infectious Waste. Part 5 of the regulation states that generators who generate less than
50 pounds of infectious waste per month must:
"Quantify the waste generation rate and keep records recorded in pounds. This generation rate and record shall pertain to the aggregate quantity of waste generated on the premise owned or operated by the generator on a calendar month basis. Upon request of the board of health or its authorized representative, or the director (of the Ohio Environmental Protection Agency) or his authorized representative, the generator shall provide information regarding the infectious waste generation rate, the generator shall quantify and record the monthly generation rate utilizing one of the following:
(a) A monthly generation rate log which shall display the month and the weight of all the infectious waste generated on the premises during that calendar month; or
(b) Treatment shipping papers that have the weight of all the infectious waste that is generated and sent for treatment documented in pounds for a calendar month; or
(c) A combination of a monthly generation rate log and treatment shipping papers to document the monthly generation rate if the generator does not send
all infectious wastes generated on the premises for treatment. A generator shall indicate on the monthly generation rate log when this combination is being used. The treatment shipping papers shall be affixed to the corresponding generation rate log page for the indicated month. The mathematical calculation from the log page and the treatment shipping papers shall be clearly indicated on the log page.
If you have a copy of the OFDA's OSHA compliance manual, you have a waste generation log sheet in the manual that you can use. Post it in the prep room above the infectious waste container so embalmers remember to record the weight of all infectious waste. Of course, you'll need to put a scale next to the infectious waste container to weigh the waste. You do NOT need to record the weight of any infectious waste liquid materials (body fluids) that are discharged to the sanitary sewer.
If you have any questions about this regulation or any other infectious waste or OSHA regulation, please contact Safex, toll-free, at 1-866-723-3987.