| FAQ - Waste Treatment & Disposal - 2015
I have recently heard from a waste hauling company that we must segregate local anesthesia cartridges and have them hauled due to epinephrine being in them and that is considered a pharmaceutical. Could use some help knowing if this is true. Thank you.
Please note that all federal, state, and local laws/regulations apply regarding the disposal of anesthetic carpules. There may be additional state laws governing the disposal of anesthetic carpules that Ask OSAP is not aware of. Some states do have specific laws regarding the disposal of anesthetic carpules. Additionally, the 2003 CDC Guidelines for Infection Control in Dental Healthcare Settings does not specifically address the disposal of anesthetic carpules.
In a letter pertaining to a Bloodborne Pathogens Standard Interpretation, the US Department of Labor - Occupational Safety & Health Administration (OSHA) states:
Question 1: Are dental anesthetic carpules considered sharps and must they be disposed of in the sharps container?
Reply 1: As you know, the bloodborne pathogens standard defines "contaminated sharps" as any contaminated object that can penetrate the skin, including but not limited to, needles, scalpels, broken glass, broken capillary tubes, and exposed ends of dental wires [29 CFR 1910.1030(b)]. Pharmaceutical containers, including anesthetics carpules used in dentistry, are generally not considered to be contaminated sharps unless they are broken and can penetrate the skin. Intact anesthetic carpules are not required by OSHA to be discarded in a sharps container.
Question 2: Are dental anesthetic carpules considered regulated waste?
Reply 2: The bloodborne pathogens standard defines regulated waste as liquid or semi-liquid blood or other potentially infectious material (OPIM); contaminated items that would release blood or OPIM in a liquid or semi-liquid state if compressed; items that are caked with dried blood or OPIM and are capable of releasing these materials during handling; contaminated sharps; and pathological and microbiological wastes containing blood or OPIM. Dental anesthetic carpules are not usually expected to become contaminated with blood. However, when there is visible blood inside the carpules, they are to be regarded as regulated waste. OSHA requires that the contaminated carpules be placed in containers that are closable, constructed to contain all contents and prevent leakage of fluids during handling, storage, transport, or shipping, and color-coded or labeled appropriately and closed prior to removal [29 CFR 1910.1030(d)(4)(iii)(B)]. if contaminated carpules are broken, the sharps container requirements of 29 CFR 1910.1030(d)(4)(iii)(A) would apply to the disposal of any contaminated carpules.
Question 3: If they are not contaminated sharps or other regulated waste, may they be thrown away in the trash?
Reply 3: The ultimate disposal of pharmaceutical vials must be in accordance with municipal, state and federal regulations (e.g., those of the Environmental Protection Agency, EPA). OSHA does not regulate the disposal of medical wastes which are not "regulated waste" within the meaning of the bloodborne pathogens standard. Product material safety data sheets may provide guidance on proper disposal of anesthetic carpules.1
The state Board of Dental Examiners/Licensing Board, State Public Health Board/Agency (Health Department) and State Board of Pharmacy should also be consulted for additional information concerning all applicable laws in your state.
Some states now consider dental anesthetic agents administered via glass anesthetic cartridges as pharmaceutical waste and require special disposal. For example, in the State of California, under the state Medical Waste Management Act, dental anesthetic carpules with residual anesthetic agent are regulated as pharmaceutical waste.2 This Act states as follows in Chapter 9; Containment and Storage - Section 118275 Medical Waste Segregation and Storage:
(h) A person may consolidate into a common container, which may be reusable, sharps waste, as defined in Section 117755, and pharmaceutical wastes, as defined in Section 117747, provided that the consolidated waste is treated pursuant to paragraph (1) of subdivision (a) of Section 118215 and the container meets the requirements of Section 118285. The container shall be labeled with the biohazardous waste symbol and the words ―HIGH HEAT ONLY,‖ ―INCINERATION,‖ or other label approved by the department on the lid and on the sides, so as to be visible from any lateral direction, to ensure treatment of the biohazardous waste pursuant to this subdivision. 3
It should also be noted that one must be aware that some carpules can become contaminated with varying amounts of blood when used. It is prudent to consider discarding them into sharps containers. Putting glass that may be contaminated with blood into the regular trash in a healthcare facility may cause injury to cleaning staff. If the carpule is broken when the trash is being handled, it could cause injury.
In summary, it is recommended that you contact the State Board of Dental Examiners/Licensing Board, State Public Health Board/Agency (Health Department) and the State Board of Pharmacy because the applicable laws in each state may vary.
1) US Department of Labor - Occupational Safety & Health Administration. Standard Interpretation Re: 1910.1030. http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25618 Accessed on April 7, 2015.
2) California Department of Public Health. Medical Waste Laws, Regulations, and Standards – Medical Waste Management Act. http://www.cdph.ca.gov/certlic/medicalwaste/Pages/LawsRegs.aspx and http://www.cdph.ca.gov/certlic/medicalwaste/Documents/MedicalWaste/MWMAfinal2012.pdf accessed on April 7, 2015.
3) California Department of Public Health. Medical Waste Laws, Regulations, and Standards – Medical Waste Management Act. http://www.cdph.ca.gov/certlic/medicalwaste/Documents/MedicalWaste/MWMAfinal2012.pdf accessed on April 7, 2015.