COVID-19 Waste Management Protocols and Federal and State Enforcement Discretion
AUGUST 28, 2020
As the COVID-19 pandemic continues, federal and state agencies have clarified procedures around enforcing waste management protocols. The bottom line? Despite a national emergency, compliance with environmental regulations is still expected
We recently held a webinar around waste management protocols and enforcement. Below, we’ve highlighted key points to keep you up-to-date.
Waste Management Protocols
There are no additional regulatory requirements regarding waste management for COVID-19, according to OSHA and the CDC. Hazardous waste (including hazardous waste pharmaceuticals) generated in a potential COVID-19 exposure situation should be managed in accordance with current waste protocols and disposed of in the appropriate receptacles.
All properly permitted regulated medical waste (RMW) facilities can manage COVID-19 waste, and incineration is only required for those regulated medical wastes that already require incineration. The Healthcare Waste Institute and have also issued guidance for managing COVID-19 waste.
Federal Enforcement Discretion
The EPA, DOT and OSHA have each issued guidelines around relief and compliance. The DOT has also issued employee training protocols. While there are slight differences, the common message is if compliance is not reasonably practicable, companies should identify the specific nature and dates of the noncompliance and how COVID-19 was the cause, the actions taken in response, including best efforts to comply, and document what is being done to return to compliance.
In addition, OSHA has issued some enforcement discretion around annual fit-testing for N95 filtering facepieces, but initial fit-testing is still required for all healthcare personnel providing direct care of COVID-19 patients.
State-Level Enforcement Discretion
As stated above, compliance is still expected despite the state of emergency. But it’s important to note that each state is taking their own approach to enforcement, with differences including time frame for relief, programs and activities that are subject to relief and procedures (including specific documentation requirements) to request relief. So far, only certain states have issued alerts and guidance on protocols.
Information is constantly changing and added frequently – check State Health Department and State Environmental COVID-19 websites for the latest.
Communication and Resources
Again, news around COVID-19 protocols is changing often. To stay up to date with the latest, here’s a list of helpful resources:
- CDC
- OSHA
- World Health Organization (WHO):
- EPA List N: Disinfectants for Use Against SARS-CoV-2
- NWRA – HWI Press Release and Guidance Document
Remaining vigilant around COVID-19 waste helps keep patients, healthcare workers, waste removal employees, our communities and the environment safe. To learn more about how Clean Earth can help, please visit our Coronavirus Knowledge Center.