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Safe Community Needle Disposal

CaliforniaCalifornia Public Health Laws and Regulations: Impact on the Safe Disposal of Used Syringes by Individuals in the Community

Content Verified on: April 21, 2003


Summary

Regulatory Environment

  • Consolidation sites for sharps used at home are recognized in state law, which:
    • exempts consolidation sites from registration, permitting, and fees as medical waste generators;
    • excludes operators as generators;
    • excludes consolidation sites from meeting containment and storage requirements designed for regulated medical waste generators;
    • requires used syringes to be placed in sharps containers and disposed within 7 days.
  • Regulated medical waste generators may accept used sharps from the public.
  • Medical waste mailback services are regulated under the state’s medical waste law.
  • Used syringes from households may be legally disposed in the trash.

Identified Community-based Disposal Initiatives

  • Several community sharps container collection programs are operating in California, including:
    • San Francisco Community Syringe Collection Site Program
    • Ventura County Solid Waste Management Department Syringe Collection Site Program
    • The City of Rancho Cucamonga Syringe Collection Site Program
    • Waste Management Inc./Sharps Compliance Inc Syringe Mailback Program
    • City of San Bernardino Syringe Collection Site Program

Introduction

Disposing of contaminated medical waste, including needles, syringes, and other “sharps,” has become an important issue in public health policy. Waste generated in the health care system is highly regulated at the state and federal level. Hospitals and other health care facilities must follow special procedures for handling, transporting, and disposing of medical waste, including used needles that may contain blood. Facilities also have instituted strict safeguards to protect health care workers, housekeeping staff, sanitation workers, and waste haulers from needlesticks because of the risk of contracting HIV, hepatitis B and C, and other bloodborne infections.

Less attention has been paid to safe disposal of used syringes that come from individuals living in the community. However, as many as 3 billion syringes are used each year outside health care facilities: It is estimated that between 0.9 and 1.68 billion insulin injections and up to 1 billion illegal drug injections occur each year in the United States. After being used and discarded, most of these syringes end up in the public solid waste system. This presents a risk of needlestick injury and infection, mostly to solid waste workers. A much smaller number are discarded in public areas, such as parks, presenting a risk to the public.

This section of CDC’s Community Syringe Disposal, Laws and Regulations, and the Public Health web site looks at the public health dimensions of this problem. It describes this state’s solid and infectious waste laws and regulations as they relate to syringe disposal. It provides background information on several key disposal options currently used in the U.S. and describes the impact of this state’s laws and regulations on the way that individuals may use these options. It also includes brief descriptions of some safe disposal programs in the state and provides contact information for the state’s public health and environmental management agencies.

This web site is designed primarily for individuals and communities who are working to build safe syringe disposal programs and improve public understanding of this important issue. We hope that the information and tools provided here will help communities move closer to the ultimate goal of “no syringes discarded in the trash or in public locations such as parks, buildings, or the streets.”


Current Published Guidance for Individuals

California has not published community syringe disposal guidance.


Solid and Infectious Waste Policies

1. Medical Waste Law

Summary
Establishes for medical waste generators requirements – The law establishes standards for segregating, containing, treating, transporting, and disposing of medical waste.

Excludes medical waste generated from the household from regulation — Used syringes from households may be disposed in the trash. Local restrictions may apply.

Recognizes community sharps container collection sites – The law recognizes community-based collection sites and contains special provisions for these sites:

  • permit, registration, and fee requirements are waived;
  • requirements for containment and storage that apply to medical waste generators, such as hospitals, are waived;
  • sharps waste collected at community sites must be placed in sharps containers;
  • sharps containers ready for disposal cannot be stored for more than 7 days except with written approval of the Department of Health Services;
  • community syringe container site operators are not considered to be generators of the waste.

Allows registered medical waste generators to accept used syringes from individuals – Medical waste generators registered with the Department of Health Services may accept home-generated used syringes. Certain requirements apply.

Establishes approval and reporting requirements for medical waste mailback services – Medical waste mailback services must pay a fee and be approved by the Department of Health Services. These services must provide the Department with a list of all clients annually.

Law
California Health and Safety Code, Division 104 [Environmental Health], Part 14 [Medical Waste], Chapters 1-11, Sections 117600 – 118360 [Referred to as the “Medical Waste Management Act] [Ref 1]

Responsible Agency
California Department of Health Services


Bloodborne Pathogen Standards

Summary
Adopts federal bloodborne pathogen rule – California’s bloodborne pathogen rule was adopted from the federal standard. The state operates its own program under an U.S. Occupational Safety and Health Administration (OSHA)-approved state plan.

Sets requirements for collection sites when employees handle the sharps containers – Operators of sharps container collection sites in which employees physically accept and handle filled sharps containers from customers are required to meet the OSHA bloodborne pathogen standards. This involves developing a written Exposure Control Plan that identifies the frequency of exposure and the tasks and procedures in which exposure may occur. The Plan also must address methods of compliance, hepatitis B vaccination, hazard communication to employees, recordkeeping, and methods to evaluate exposure incidents.

Sets requirements for collection sites when employees do not handle the sharps containers – Operators of sharps container collection sites in which customers place filled sharps containers into a collection container are not subject to the bloodborne pathogen standard. In this situation, employees must not handle the sharps containers. Those involved with removing the sharps containers from the collection container must meet the standard.

Law
California Code of Regulations, Title 8, Section 5193, Bloodborne Pathogens [Ref 2]

Responsible Agency
California Department of Industrial Relations


Selected Community Syringe Disposal Options

Container Collection Sites

Read about California’s sharps container collection programs

Background

How This Option Works
An individual brings filled sharps containers to a collection site such as a pharmacy, medical facility (for example, a hospital or public health clinic), or non-medical facility (for example, a fire station) for safe disposal. Other sites have sharps collection drop boxes (a kiosk, mailbox-type receptacle, or other secured collection bin). This is a viable option that can capture many of the syringes generated in the community. Successful syringe container collection programs feature:

  • minimal regulatory constraints placed on collection sites;
  • easy access provided through numerous and well-publicized collection locations; and
  • minimal costs to users through subsidized costs of containers and disposal.

Even if a community does not have collection site programs, an individual may be able to develop an informal relationship with a local pharmacy or other facility that will accept and safely dispose of filled syringe containers.

Advantages and Disadvantages
Sharps container collection programs have two key advantages:

  • Used syringes are kept out of the regular solid waste stream, which reduces the risk of needlestick injuries to waste and recycling workers (see Disposal in the Trash for more information).
  • Syringes collected through these programs are disposed of safely as medical waste. This involves special disinfection to destroy germs and destruction or burial to ensure that the needle points cannot injure anyone.

Facilities and individuals may perceive some disadvantages:

  • Individuals may feel that bringing sharps containers to a collection site is inconvenient and reduces their privacy because it identifies them as a syringe user.
  • Collection sites may have to comply with state bloodborne pathogen standards and medical waste disposal requirements, and they must carefully maintain the collection bins or kiosks.

Effect of California’s Laws and Regulations
The approach taken by the California Medical Waste Management Law encourages communities to establish sharps container collection sites throughout California. This is accomplished by: 1) recognizing community sharps collection sites in the law; 2) excluding sites from registration and permitting requirements and fees; 3) not considering collection site operators to be generators of medical waste; 4) excluding sites from containment and storage requirements that apply to registered medical waste generators, such as hospitals; and 5) allowing medical waste generators to accept used syringes from individuals.

California’s bloodborne pathogen standard discourages programs in which employees handle filled sharps containers from customers, and encourages programs in which employees do not have to handle filled containers because customers place them directly into a collection container.

Container Mailback Programs

Background

How This Option Works
Sharps containers are distributed to customers and, when full, are mailed back to a syringe disposal company for safe disposal. This is a viable option that can capture some of the used syringes generated in the community.

Advantages and Disadvantages
Syringe mailback programs have the same advantages as syringe container collection sites:

  • Used syringes are kept out of the regular solid waste stream, which reduces the risk of needlestick injuries to waste and recycling workers (see Disposal in the Trash for more information).
  • Syringes collected through these programs are disposed of safely as medical waste. This involves special disinfection to destroy germs and destruction or burial to ensure that the needle points cannot injure anyone.

The cost of mailing the container to the disposal company varies. The cost may be too high for some individuals, and may be considered a disadvantage.

Effect of California’s Laws and Regulations
Medical waste (sharps) mailback services are recognized under California’s medical waste law and must meet certain requirements. In California, mailback services are seen as a viable alternative for medical waste disposal, which would be likely to increase their use.

Sharps container collection programs are also regulated under the U.S. Postal Service (USPS) when syringes are mailed [Ref 3]. The USPS regulations establish specific packaging, labeling, and tracking requirements for these syringes.

Disposal in the Trash

Background

How This Option Works
Individuals place their used syringes in the household trash, either loose or in a puncture-resistant container. Some individuals remove the needle from the syringe and put it in a container using a special device. The syringe and contained needle are then disposed of in the household trash.

Advantages and Disadvantages
The main advantages of this option are convenience and low cost.

This option has one important disadvantage – it places people at risk of being stuck by a needle and increases their chances of contracting a bloodborne infection:

  • Placing unprotected syringes into the household trash puts waste collectors at risk [Ref 4].
  • Placing used needles in a puncture-resistant container may help protect trash collectors from being stuck. Even so, most containers disposed of in the trash shatter in the garbage truck and release their contents. This places other waste workers at risk.
  • Bottles or cans used as puncture-resistant containers may be recycled by mistake. This puts waste recyclers at risk.

Effect of California’s Laws and Regulations
Individuals may legally dispose of their used syringes in the trash. It is likely that this would lessen participation in community sharps collection programs.


How Might California Ensure Safe Syringe Disposal by Individuals in the Community?

The state legislature and individual communities may wish to more actively encourage individuals to safely dispose of used syringes and make it easier for them to do so. Many options for state and local action exist. They range from gathering data, to developing community collection site programs and education efforts, to creating partnerships with interested groups, to considering amending laws and regulations. All will help California move toward the goal of “no syringes discarded in the trash or public locations.”


Current Identified Community Syringe Disposal Programs in California Go to Top

Identified sharps container collection site programs in California [Ref 5]

San Francisco Community Syringe Collection Site Program

An increasing number of communities throughout California are implementing programs to get home-generated sharps out of the solid waste stream. San Francisco has operated a disposal program for home-generated sharps since 1991. Through this program, residents are given free, 2.2-quart sharps containers from participating pharmacies, hospitals, and clinics. Individuals return the containers when full to these sites and they are picked up by a licensed medical waste hauler either on demand or on a fixed schedule. During the year 2000, 13,980 containers were distributed in San Francisco by 46 participating Walgreen's Pharmacies, 5 hospitals, and 2 clinics. The program disposes of an estimated 1.8 million needles per year. This resulted in a reported seven-fold reduction in needle sticks to garbage collectors in the year 2000 as compared to 1989 [Excerpt from McGurk by permission (Ref 5)].

Ventura County Solid Waste Management Department Syringe Collection Site Program

In response to needle stick injuries to workers doing recyclable sorting and a request from the County Environmental Health Division, the County of Ventura Solid Waste Management Department started a home-generated sharps program with the theme of: How NOT to Get Stuck in Ventura County. Their program was initiated in October 1998 and containers are distributed and collected at 18 facilities; 12 county-operated public health or family care clinics, and 6 privately operated hospitals and clinics. The program has distributed 3,202 sharps containers since October 1998 and collected 2,353 full ones from its sites through March 2001 [Excerpt from McGurk by permission (Ref 5)].

The City of Rancho Cucamonga Syringe Collection Site Program

The City of Rancho Cucamonga initiated a program that allows residents to bring their used syringes to its five fire stations on Saturdays from 10:00 a.m. to 2:00 p.m. Residents receive free sharps containers and bring them back for disposal when they are 2/3 full. The program costs approximately $6,200 annually for the new sharps containers and treatment and disposal. These program costs are shared between the three residential waste haulers that operate within the city. The Rancho Cucamonga Fire District contributes all on-site personnel costs, training, marketing, and collection. The City of Rancho Cucamonga's Waste Management Division oversees the contract with the waste haulers and the medical waste company and tracks the success of the program and monitors the budget. To date, the program has diverted over 2,000 pounds of sharps waste from the solid waste stream [Excerpt from McGurk by permission (Ref 5)].

Waste Management Inc./Sharps Compliance Inc. Syringe Mailback Program

Waste Management Incorporated (WMI) is teaming with Sharps Compliance Inc. (SCI) to implement a syringe mail back program in three areas of the country. The WMI/SCI project is being initiated in Orange County, California; Denver, Colorado; and Orlando, Florida. WMI customers are sent literature regarding the mailback program and offered an 800 number to call for further information and to sign up for the service. The program has recently been implemented in Chino, San Bernardino, and some of the other Inland Empire localities that are serviced by WMI. Residents who order the service are sent a postage-paid sharps container that they mail back to SCI's Texas facility when full [Excerpt from McGurk by permission (Ref 5)].

City of San Bernardino Syringe Collection Site Program

The City of San Bernardino instituted a home-generated sharps disposal program in 1999 using grant funds from the California Integrated Waste Management Board. The program works closely with 20 pharmacies, senior and assisted living facilities, veterinary hospitals, and diabetic centers. Clients who are not homebound go to the San Bernardino Public Services Department where a representative completes a service request that helps determine the size container that will be needed. The containers and drop off locations program then provides to the customer. Requests from homebound customers are received over the phone and a coordinator establishes a container delivery date with the customer. When the containers are full, the homebound patient calls the coordinator who contacts the contract hauling company to set a convenient pick up time with the customer. A new container is exchanged for the full one. The program uses several avenues for outreach such as health fairs, press releases, tag lines in water bills, senior center public service announcements and advertisements on paper bags from the pharmacies. During the year 2000 the program diverted a total of 67,000 sharps from the solid waste stream [Excerpt from McGurk by permission (Ref 5)].

Identified Syringe Exchange Programs in California [Ref 6]

San Diego Needle Exchange Program

Clean Needles Now, Los AngelesLink to a non-CDC site

San Francisco Needle Exchange SitesLink to a non-CDC site

AIDS Project Central Coast
Send Email

Santa Clara County HIV/AIDS Program
Send Email


Responsible Agencies in California

Links below will open in a new browser window.

Medical Waste Issues
State of California, Department of Health ServicesLink to a non-CDC site
Prevention Services
Division of Drinking Water & Environmental Management
Environmental Management BranchLink to a non-CDC site
Medical WasteLink to a non-CDC site
601 N. 7th St.
Sacramento, CA 94234-7320
Tel: (916) 327-6904

Contact: Jack McGurk, Chief
E-mail: JMcGurk@dhs.ca.gov
Tel: (916) 323-3023
Fax: (916) 323-9869

Bloodborne Pathogen Issues
California Department of Industrial RelationsLink to a non-CDC site
Occupational Safety and HealthLink to a non-CDC site
455 Golden Gate Avenue, 10th Floor
San Francisco, CA 94102
Tel: (415) 703-5050


References

Links below will open in a new browser window.

1. California Medical Waste Law - California Health and Safety Code, Division 1Link to a non-CDC site [Administration of Public Health], Part 14 [Medical Waste], Chapters 1-11, Sections 117600 – 118360 [Referred to as the “Medical Waste Management Act]

2. California Bloodborne Pathogen Rule – California Code of Regulations,Link to a non-CDC site Title 8, Section 5193, Bloodborne Pathogens

3. USPS Domestic Mail ManualLink to a non-CDC site [Click on “DMM Subject Index” then scroll to and click on “Sharps, CO23.85”]

4. Turnberg WL, Frost F. Survey of occupational exposure of waste industry workers to infectious waste in Washington State.Link to a non-CDC site American Journal of Public Health 1990;80(10):1262-1264.

5. McGurk, Jack, Chief, State of California, Department of Health Services, Division of Drinking Water & Environmental Management, Environmental Management Branch, 601 N. 7th St., Sacramento, CA 94234-7320, Tel: (916) 323-3023, Fax: (916) 323-9869, E-mail: JMcGurk@dhs.ca.gov. Spring 2001.

6. NASEN (North American Syringe Exchange Network),Link to a non-CDC site Needle Exchange California. [Click on "Needle Exchange Program Links" and select California from the U.S. map] March 25, 2003.



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