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Safe Community Needle Disposal

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

Content Verified on: August 20, 2003


Summary

Regulatory Environment

  • The Maryland Department of the Environment enforces the laws and regulations relating to medical wastes and provides management standards for its treatment and disposal.
  • Sharps (syringes and needles) are contained within Maryland’s definition of “special medical waste” and are therefore subject to Maryland’s special medical waste regulations
  • Maryland’s special medical waste regulations specifically exclude household waste as a form of special medical waste.

Identified Community-based Disposal Initiatives

  • Baltimore has instituted a program called Operation Red Box in which four mailboxes have been painted red and located in areas of the city with high drug use. Used syringes are placed into the drop boxes for safe handling and disposal.

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

The Maryland Department of the EnvironmentPDF IconLink to a non-CDC site (MDE)
has developed a document called Maryland Envirothon 2001 Resource Packet and Study Guide for Urban Non-Point Source Pollution-Household/Home Site. This document provides guidance how to safely dispose of medical waste, including syringes used at home.

The document recommends that sharps be:

  • wrapped securely in paper or other material;
  • placed in tough plastic or metal containers with tightly sealed lids, such as detergent containers or coffee cans; and
  • placed safely in the trash can.

It also includes these warnings:

  • Sharps cannot be recycled.
  • Sharps should only be properly disposed of.
  • Sharps should not be tossed in the trash haphazardly.
  • Sharps should not be placed in soft containers such as milk jugs or cartons that can be easily punctured.

It also suggests that individuals get more information on pharmaceuticals and medical wastes (including sharps), by visiting these two U.S. Environmental Protection Agency websites:


Solid and Infectious Waste Policies

1. Special Medical Waste Statute

Summary
Establishes rule writing authority: The statute gives rule writing authority to the Secretary and Department of the Environment to establish rules relating to special medical wastes.

Statute
Environment Articles 7-104, 7-201, 9-252, and 9-314 of the Annotated Code of Maryland [Ref 1]

2. Special Medical Waste Regulations

Summary
Establishes a definition: “Sharps” (hypodermic needles and syringes) are classified as a form of special medical waste.

Exempts household generated special medical waste: The regulations specifically exclude household waste as a form of special medical waste.

Establishes standards for generators of special medical waste: The regulations require generators of special medical waste to obtain a Maryland Identification number from the Secretary of the Department of the Environment before treatment, storage, transport or disposal of the waste. Shipping papers are required for those generators who transport, or offer for transport, special medical waste for off-site treatment, storage, or disposal.

Establishes packaging, labeling and treatment requirements for sharps: Sharps must be: (1) placed in a container that is impervious to puncture; (2) clearly labeled with the generator identification number and the words “Special Medical Waste”; and (3) incinerated or first sterilized and then mechanically destroyed. Generators are also required to keep records of reports, tests, and analyses for a period of three years.

Establishes special medical waste transportation requirements: Persons transporting special medical waste must obtain a state identification number from the Secretary and a special medical waste hauler certificate from the department. Transporters must also comply with vehicle standards, stoppage requirements and safety inspections. A transporter of special medical waste may not accept special medical waste from a generator unless the waste is accompanied by a shipping paper.

Establishes conditional exclusion for small quantities of Special Medical Waste - This exclusion provides reduced requirements for those persons who generate less than 50 pounds of special medical waste in a calendar month and do not accumulate more than 50 pounds at any time.

Regulation
Chapters 11, 12 and 13 of the Code of Maryland Regulations, Title 26, Subtitle 13 [Ref 2]

Chapter 10 of Maryland Regulations, Title 10, Subtitle 06 [Ref 3]

Responsible Agency
Maryland Department of the Environment
Maryland Department of Health and Mental Hygiene


Bloodborne Pathogen Standards

Summary
Adopts federal bloodborne pathogen rule – Maryland’s bloodborne pathogen rule was adopted by reference 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
29 CFR Part 1910.1030 [Ref 4]

Responsible Agency
Maryland Department of Labor, Licensing & Regulation


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 Maryland’s Laws and Regulations on Container Collection Sites
Community syringe collection sites are not specifically addressed in Maryland’s special waste regulations. Based on a conservative interpretation of Maryland law, a collection site would be viewed as a facility that has collected waste derived from a household, which is excluded from special medical waste regulations by virtue of its source of generation.

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 Maryland’s Laws and Regulations on Container Mailback Programs
Sharps container mailback programs are not addressed by Maryland’s laws and regulations. However, sharps container collection programs are regulated under the U.S. Postal Service (USPS) when syringes are mailed [Ref 5]. 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 Maryland’s Laws and Regulations on Disposal in the Trash
Maryland specifically excludes household waste from its special medical waste regulations. Therefore, home users of syringes are not required to comply with these regulations and may dispose of their syringes in the trash. However, the state of Maryland offers guidance on the disposal of household-generated syringes through a document created by the Maryland Department of the Environment entitled Maryland Envirothon 2001 Resource Packet and Study Guide for Urban Non-Point Source Pollution-Household/Home Site.PDF IconLink to a non-CDC site


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

The state legislature and individual communities may wish to 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 Maryland move toward the goal of “no syringes discarded in the trash or public locations.”


Current Identified Community Syringe Disposal Programs in Maryland Go to Top

Baltimore has instituted a program called Operation Red Box in which four mailboxes have been painted red and located in areas of the city with high drug use [Ref 7]. The locations were chosen by the Baltimore City Health Department in consultation with community associations. Used syringes are placed into the drop boxes for safe handling and disposal. These boxes are “one-way only” – syringes go into the box but cannot be retrieved. This reduces the reuse of contaminated syringes and the risk of accidental needlesticks.

For more information about Operation Red Box, contact:
Baltimore City Health Department
Tel: (410) 396-4387


Responsible Agencies in Maryland

Links below will open in a new browser window.

Maryland Department of the EnvironmentLink to a non-CDC site
Hazardous Waste ProgramLink to a non-CDC site
Regulation/Permitting Division
Montgomery Park
1800 Washington Blvd.
Baltimore, Maryland 21230-1719
Contact: Ed Hammerberg
Tel: (410) 537-3345

Maryland Department of Labor, Licensing & RegulationLink to a non-CDC site
Maryland Occupational Safety and Health (MOSH)
1100 North Eutaw Street, Room 613
Baltimore, Maryland 21201-2206
Tel: (410) 767-2215
Fax: (410) 333-7747

Maryland Occupational Safety and Health (MOSH)
1100 North Eutaw Street, Room 613
Baltimore, Maryland 21201-2206
Tel: (410) 767-2215
Fax: (410) 333-7747


References

Links below will open in a new browser window.

1. Special Medical Waste Statute - Annotated Code of Maryland, Environment Article 7-104, 7-201, 9-252, and 9-314Link to a non-CDC site

2. Special Medical Waste Regulations - Code of Maryland Regulations (COMAR), Title 26 Department of the Environment, Subtitle 13 Disposal of Controlled Hazardous SubstancesLink to a non-CDC site

  • Chapter 11 Special Medical Waste
  • Chapter 12 Standards Applicable to Generators of Special Medical Waste
  • Chapter 13 Standards Applicable to Transporters of Special Medical Waste

3. Special Medical Waste Regulations – Code of Maryland Regulations (COMAR), Title 10 Department of Health and Mental Hygiene, Subtitle 06 DiseasesLink to a non-CDC site

4 .OSHA Bloodborne Pathogen StandardsLink to a non-CDC site – 29 CFR Part 1910.1030. [Scroll to and click on “1910.1030 – Bloodborne pathogens”]

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

6. 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.

7. Macalino GE, Springer KW, Rahman ZS, Vlahov D, Jones TS. Community-based programs for safe disposal of used needles and syringes. JAIDS, 1998;18(Suppl 1):S111-S119.



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