The solid waste program in Tennessee is administered by
the Tennessee Department of Environment and Conservation, Division
of Solid
Waste Management.
Medical waste is regulated as a "special
waste" under
the Tennessee solid waste rules, and has specific management,
disposal, and
fee requirements.
Household generators of medical waste
are exempt from the state's special waste requirements
and fees
according to a Division of Solid Waste Management policy document.
Identified Community-based Disposal Initiatives
No syringe disposal programs were identified in Tennessee,
but that does not mean that no such programs operate in the state.
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.”
Summary Establishes rule making authority – The Tennessee
statute provides rule writing authority to the Solid Waste Disposal
Control Board to
establish solid waste rules.
Law
Chapter 211 of the Tennessee Code, Title 68 [Ref 1]
2. Solid Waste Processing and Disposal Regulations
Summary Establishes a definition – “Sharps” (hypodermic
needles and syringes) are classified as a form of medical waste.
The rule also
defines medical waste as a form of special waste.
Establishes special waste approval requirements
and fees – The
regulations require all disposal and processing facilities that manage
special waste to obtain approval from the Tennessee Division of Solid
Waste Management by contacting the Commissioner of the Department for
a waste evaluation. The regulations also require all facilities that
handle such waste to pay a $250 special waste approval fee.
Establishes medical waste disposal requirements – Sharps
must be placed in puncture-proof containers before disposal in
a landfill.
Regulation
Chapter 1200-1-7 of the Solid Waste Processing and Disposal Requirements
[Ref 2]
3. Standard Operating Procedure for Special Waste Approval
Summary Exempts household-generated special waste – The standard
operating procedure specifically exempts household generators of
special waste
from obtaining a special waste approval from the Division of Solid
Waste Management and from paying the special waste approval fee. Therefore,
homeowners who generate medical waste, including syringes, are not
required to meet the special waste requirements of the solid waste
rule regulations and may dispose of their syringes in the trash.
Regulation
Division of Solid Waste Management, Standard Operating Procedure for
Special Waste Approval [Ref 3]
Summary Adopts federal bloodborne pathogen rule – Tennessee’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.
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 Tennessee’s Laws and Regulations
on Container Collection Sites
Container collection sites are not specifically addressed in Tennessee’s
solid waste regulations. Based on a conservative interpretation of
the regulations, a collection site would be required to obtain a special
waste approval from the Division of Solid Waste and pay the special
waste approval fee. Sharps would have to be placed in a securely packaged
puncture-resistant container before disposal in a landfill. However,
landfills are not obligated to accept sharps waste.
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 Tennessee’s Laws and Regulations
on Container Mailback Programs
Sharps container mailback programs are not addressed by Tennessee’s
solid waste 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
6].
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 Tennessee’s Laws and
Regulations on Disposal in the Trash
The Tennessee Division of Solid Waste Management has published a Standard
Operating Procedure that excludes homeowners from having to obtain
a special waste evaluation and approval from the Division and paying
a
special waste disposal fee before disposing of their household-generated
sharps. Under this policy, individuals may dispose of their used syringes
in the trash.
How
Might Tennessee 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 Tennessee move toward the goal of “no
syringes discarded in the trash or public locations.”
Current
Identified Community Syringe Disposal Programs in Tennessee
Tennessee Bureau of Environmental Health Services
Dept of Environmental Conservation
Division of Solid and Hazardous Waste Management
5th Floor, L&C Tower
401 Church Street
Nashville, Tennessee 37243-1535
Tel: (615) 532-0780
Contact: Sam Faleh
Tennessee Bureau of Environmental Health Services
Division of Solid and Hazardous Waste Management
Tel: (615) 532-0796
Email: bassam.faleh@state.tn.us
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Tennessee's Public Health Laws and Regulations:
Impact on the Safe Disposal of Used Syringes by Individuals in the
Community
