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Safe Community Needle Disposal

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

Content Verified on: January 24, 2003


Summary

Regulatory Environment

  • The Hazardous Materials and Waste Management Division of the Colorado Department of Public Health and Environment regulates the management of infectious waste and syringes.
  • Colorado law specifically exempts household-generated syringes from its infectious waste disposal regulations.

Identified Community-based Disposal Initiatives

  • No community-based disposal initiatives have been identified in Colorado.
  • The state has developed written guidance on safe disposal of household-generated syringes.

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

Colorado offers guidance on disposing of household-generated syringes through two bulletins created by the state’s Department of Public Health and Environment, Hazardous Materials and Waste Management Division. These bulletins are entitled “Household Medical Waste Management” and Infectious Waste Management.

The bulletins include these recommendations:

Needles, syringes, lancets, and other medical sharps should be:

  • Placed in strong plastic or metal containers with screw-on or tightly secured lids (examples include empty bleach bottles, liquid detergent bottles, plastic milk jugs, or coffee cans. Strong tape should be used to secure the lid of coffee cans.)
  • Once the container is full and sealed, it can be placed in the regular household trash.

The bulletins also include these warnings:

  • Recyclable containers should not be used as sharps containers.
  • Glass should never be used as a sharps container.
  • All infectious waste should be stored out of reach of children and pets.

Solid and Infectious Waste Policies

1. Colorado Infectious Waste Law

Summary
Defines infectious waste – “Contaminated sharps” are included in the definition of infectious waste.

Establishes requirements for an infectious waste management plan – The statute requires generators of infectious waste to develop and carry out an on-site infectious waste management plan appropriate for their facility. The plan must designate wastes that will be considered infectious wastes, describe how such wastes will be handled, and include a contingency plan for spills. The plan must also provide for staff training, designate a person responsible for implementing the management plan, and provide for appropriate on- and off-site treatment or disposal.

Establishes penalties – The statute sets penalties for generators who knowingly dispose of untreated infectious waste, haul untreated waste, or dispose of waste at an unlawful disposal or treatment site.

Law
Part 4 of Colorado Statute Title 25 [Ref 1]

Responsible Agency
Colorado Department of Public Health and Environment
Hazardous Materials and Waste Management Division

2. Colorado Infectious Waste Regulation

Summary
Establishes certificate requirements – All commercial or central facilities that handle solid or infectious waste must apply for a Certificate of Designation from the appropriate county or municipality and the Colorado Department of Public Health and Environment.

Establishes treatment requirements – Facilities must render infectious wastes noninfectious through incineration, decontamination, sterilization, autoclaving, or other approved methods. Once the infectious waste is rendered noninfectious it may be disposed of with other noninfectious waste or non-hazardous solid waste.

Establishes record keeping and monitoring requirements – The code requires facilities to maintain infectious waste records about the volume, type of waste, generator name and address, type of transport, container types, treatment and disposal methods, and dates of pick-up. The code also requires facilities to maintain operating and monitoring records.

Establishes the requirements for an operating plan – Facilities must establish an engineering design and operations report that includes a Facility Operating Plan.

Establishes labeling requirements – All infectious waste must be labeled with a biohazard symbol or the words “infectious waste” and handled and transported in a safe manner.

Establishes requirements for sharps – Contaminated sharps must be placed in puncture-resistant containers and rendered noninfectious. Sharps containers that are untreated should not be compacted.

Exempts household infectious waste – Household infectious waste is exempt from the infectious waste disposal regulations. Therefore, home users of syringes are not required to comply with these regulations.

Regulation
Section 13 of the “Regulations Pertaining to Solid Waste Disposal Sites and Facilities” [Ref 2]

Responsible Agency
Colorado Department of Public Health & Environment
Hazardous Materials and Waste Management Division

Bloodborne Pathogen Standards

Summary
Federal bloodborne pathogen rule applies
– Colorado has not established its own state plan for regulating bloodborne pathogens. Therefore, the federal Occupational Safety and Health Administration (OSHA) standards apply.

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
29 CFR Part 1910.1030 [Ref 3]

Responsible Agency
US Occupational Safety and Health Administration
Regional Office (Responsible for administrative activities in Region 8)
Area Office (Responsible for OSHA compliance in Colorado)


Selected Community Syringe Disposal Options

Container Collection Sites

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 Colorado’s Laws and Regulations
Colorado’s solid waste regulations do not specifically address community syringe collection sites.

Individuals may bring sharps to a pharmacy, medical facility, or non-medical facility without obtaining a Certificate of Designation if the facility accepts household-generated sharps as a community service and if it properly manages and disposes of the waste. The facility must determine whether other local requirements must be met, such as code enforcement, zoning, or standards for solid waste transfer facilities.

Local authorities must also evaluate sharps collection drop boxes on a site-by-site basis to determine whether the location of the bins and the bins themselves are sufficiently secure. Controls must be in place to ensure that the bins and the waste are properly managed and disposed. Local authorities would likely evaluate the placement of household waste drop boxes.

Collection site operators may also be subject to meeting bloodborne pathogen standards, depending on how the sharps containers are collected and handled.

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 Colorado’s Laws and Regulations
Sharps container mailback programs are not addressed by Colorado’s infectious waste rule. However, sharps container collection programs are regulated under the U.S. Postal Service (USPS) when syringes are mailed [Ref 4]. 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 5].
  • 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 Colorado’s Laws and Regulations
The Colorado Code of Regulations specifically exempts household-generated infectious waste from its regulations. Therefore, home users of syringes are not required to comply with the regulations and may dispose of their syringes in the trash.


How Might Colorado 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 Colorado move toward the goal of “no syringes discarded in the trash or public locations.”


Current Identified Community Syringe Disposal Programs in Colorado Go to Top

No current community syringe collection programs were identified in Colorado. However, this does not mean that no programs operate in the state.


Responsible Agencies in Arkansas

Links below will open in a new browser window.

Colorado Department of Public Health & EnvironmentLink to a non-CDC site
Hazardous Materials and Waste Management Division
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Telephone: 303/692-3300

For more information:
Customer Technical Assistance
Telephone: 303/692-3320 or 888/569-1831 Ext. 3320

US Occupational Safety and Health Administration
Regional Office – Region 8
1999 Broadway, Suite 1690
PO Box 46550
Denver, CO 80201-6550
(303) 844-1600
(303) 844-1616 FAX

Denver Area Office
1391 Speer Boulevard, Suite 210
Denver, Colorado 80204-2552
Telephone: 303/844-5285
Toll Free: 1-800-755-7090
Fax: 303/844-6676

Englewood Area Office
7935 East Prentice Avenue, Suite 209
Englewood, Colorado 80111-2714
Telephone: 303/843-4500
Toll Free: 1-800-669-5771
Fax: 303/843-4515


References

Links below will open in a new browser window.

1. Colorado Infectious Waste Law – Colorado Code of Regulations Title 25 [Health], Article 15 [Hazardous Waste], Part 4 [Infectious Waste]Link to a non-CDC site [Type “infectious waste” in Search box]

2. Colorado Infectious Waste Regulation - Code of Colorado Regulations, 6 CCR 1007-2 Section 13 [Infectious Waste Disposal]PDF IconLink to a non-CDC site

3. OSHA Bloodborne Pathogen StandardsLink to a non-CDC site – 29 CFR Part 1910.1030.

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

5. 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.

 



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