Infectious Waste Compliance

ACS’s continue to navigate evolving expectations related to infectious waste handling, regulatory compliance, and operational logistics. Recent industry discussions have highlighted the importance of consistent protocols, clear communication with waste management partners, and proactive monitoring to ensure both patient and employee safety while maintaining regulatory compliance.   

In response, MNASCA is facilitating the sharing of best practices and resources to support preparedness, risk mitigation, and ongoing operational sustainability.  This collaborative approach is intended to strengthen compliance efforts across our member facilities while encouraging continued dialogue as guidance and circumstances evolve.

MNASCA is also closely monitoring discussions and legislative bills being introduced in both the House and Senate regarding infectious waste.   

Education Recap: Infectious Waste Compliance – Risks, Regulations & What’s Ahead

On April 17, MNASCA convened members and regulatory experts for a timely discussion on infectious waste compliance and emerging policy considerations impacting ambulatory surgery centers.

Speakers from the Minnesota Pollution Control Agency and Ramsey/Washington County provided an overview of current regulatory requirements, emphasizing the importance of proper segregation, handling, and disposal of infectious waste to maintain compliance and protect public health. Presenters also highlighted increased enforcement activity and the operational and financial risks associated with improper disposal.

The session also included an update on legislation advancing at the Capitol that could further impact ASC responsibilities and oversight related to infectious waste management. Attendees were encouraged to stay engaged as these proposals evolve.

• Significant financial penalties for noncompliance
• Disproportionate impact on small and independent ASCs
• Increased operational costs
• Increased reporting obligations and administrative burden for internal audits
• Training and education requirements for ASC staff, generators, haulers, and regulatory personnel
• Complexity of implementation in multi-tenant facilities, including unclear responsibility and shared waste streams

Resources

Education Session: Infectious Waste Compliance Recording
Minnesota Pollution Control Agency – Infectious Waste Guidance
Ramsey/Washington County Recycling & Energy – Healthcare Waste Resources

The following resources have also been shared by MNASCA members.  Please contact Vicki Stute to contribute your organization’s best practices to the digital library.

Infectious Waste for Generators - Minnesota Pollution Control Agency
Pathological Waste Slides
Stericycle

Surgical Smoke
According to OSHA’s Surgical Smoke guidance, smoke evacuator tubing, filters, and absorbers should be considered infectious waste when contaminated with blood or other potentially infectious materials (OPIM) and disposed of accordingly. (OSHA eTool – Surgical Smoke Plume)

Minnesota law and MPCA guidance define infectious medical waste as including disposable items such as tubing, catheters, and dressings that have been in contact with surgical sites, wounds, or body fluids. (MPCA – Infectious Waste Management; Minnesota Statutes § 116.78)

Importantly, this guidance does not classify all smoke evacuator tubing as hazardous or RCRA waste. It only becomes hazardous waste if it contains regulated chemical hazards, such as chemotherapeutic agents, which are a small subset of cases. For standard surgical cases, tubing can be safely managed as biohazardous/infectious waste, in compliance with OSHA and MPCA standards, without requiring dual or hazardous waste disposal.