Reuters’ recent report about the challenges of medical waste disposal in the face of Ebola (“U.S. Hospitals Unprepared to Handle Ebola Waste“) is cause for alarm for any medical waste management provider. As reported in the article, Emory University’s staff was completely overwhelmed by the sheer volume of hazardous waste generated by only two Ebola patients…waste that was forced to remain in the facility for six days, until a deal could be brokered with the hospital’s medical waste management provider which had initially refused to handle it.
We’ve been conducting our own research and preparing our own responses in the event that MedAssure will be called upon to handle Ebola medical waste. As mentioned in our earlier post, CDC guidelines are posted at the following two sources: “Interim Guidance for Environmental Infection Control in Hospitals for Ebola Virus,” and “Infection Prevention and Control Recommendations for Hospitalized Patients with Known or Suspected Ebola Hemorrhagic Fever in U.S. Hospitals.” Additionally, the CDC has launched a dedicated website for all Ebola related issues and concerns: http://www.cdc.gov/vhf/ebola/
The big question for our clients is: Are wastes generated during delivery of care to Ebola virus-infected patients subject to select agent regulations?
Infected patients follow the CDC’s Infection Prevention and Control Recommendations for Hospitalized Patients with Known or Suspected Ebola Hemorrhagic Fever in U.S. Hospital; as such, waste generated when treating infected patients would not be subject to Federal select agent regulations. (See the exclusion provision 42 CFR 73.3(d)(1).) However, this would not apply to any facility that intentionally collected or otherwise extracted the Ebola virus from waste generated during the delivery of patient care. For instance, blood or tissue samples to be sent for lab analysis to an outside location would need to comply with DOT Category A packaging and training rules.
CDC does recommend that Ebola contaminated waste be collected at the point of generation, meaning in the patient room, bagged and placed in a regulated medical waste container for transport and disposal as “regulated medical waste”. MedAssure recommends that waste be triple bagged and containers should be marked for “SPECIAL CARE”. Generators should note that the Ebola virus is relatively easy to inactivate or destroy. Many EPA approved disinfectants are effective to use, and exposure to 212 degree Farenheit for 5 minutes can destroy its infectivity. However, currently there is some conflict between the CDC and DOT on whether Ebola waste should be handled to DOT’s Select Agent rules for “Category A”, infectious waste. This particular issue remains unresolved, as detailed in the Reuter’s article cited above.
It’s noteworthy to realize that many of the CDC guidance publications on Ebola are called “Interim”. As the situation evolves and decisions are reached, we expect to continuously monitor the situation and advise our clients of any changes or updates as they become available. .
Let’s hope we never need to use it.