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					                                  Senior Housing Management
SOP: # S 850    Revision 1
Effective Date: May 1, 2001
Reviewed Date: December 11, 2003
Prepared by: MCL                                                         Approved by:CAM

Title:    Waste Disposal Policy


                                  WASTE MANAGEMENT PLAN

PURPOSE: The purpose of the Waste Management Plan is to establish, implement,
monitor, and document an ongoing waste management program and to ensure there is minimal
risk to patients, personnel, and the environment. The plan will provide guidelines that ensure
all wastes are handled and disposed of in accordance with the Environmental Protection
Agency (EPA), Department of Transportation (DOT), and state and local regulations and
guidelines.

I. WASTE MANAGEMENT PLAN

         A.      The Waste Management Plan will consist of the following elements:

                1.       Infectious Waste Management Plan

                2.       Hazardous Chemical Waster Management Plan

                3.       General Waste Plan

         B.     The facility manager is the coordinator of the Waste Management Plan for each
                Senior Housing Management facility and has overall responsibility for ensuring
                implementation of the Waste Management Plan.

         C.     The applicable Federal, state, and local regulations and Senior Housing
                Management’s Waste Management Plan will be available upon request and are
                filed at each facility location.

         D.     The Waste Management Plan will be reviewed and revised annually, and
                whenever necessary, to reflect new or modified tasks and to reflect new or
                revised employee positions with responsibility for handling waste.

         E.     All personnel required to handle waste or contaminated materials will be provided
                with appropriate orientation, equipment, and training prior to assignment and will
                be retrained with the introduction of any changes in policy or procedures.

II.       INFECTIOUS WASTE MANAGEMENT PLAN

         A.     The Infectious Waste Management Plan will detail the procedures for the
                identification, packaging, storage, transportation, and disposal of infectious
                wastes.

Infectious waste is “defined as any waste, solid or liquid, capable of producing an infection.
 SOP# P850    Page: 42

These wastes are characterized by the known or suspected presence of pathogens”.

      B.     Infectious waste will be classified by the facility manager and revised or reviewed
             annually. At a minimum, the following will be classified as infectious:

             1.      Isolation wastes

             2.      Cultures and stocks of etiologic agents

             3.      Needles and sharps

             4.      Blood and blood products

             5.      Surgical and pathological specimens

      C.     Regulated waste collection, handling, processing, storage, transportation, or
             shipping will meet the following criteria:

             1.      Infectious waste will not be placed in a trash chute or compacted.

             2.     Infectious waste will be segregated from other waste by placing it in a
                    designated container marked clearly with the words “INFECTIOUS
                    WASTE”.

             3.     All specimens will be placed in recognizable specimen containers. If
                    samples are not placed in recognizable sample containers, labels or color-
                    coding will be applied to the specimen container.

             4.     Additional labeling will not be required for containers recognized as
                    containing specimens and designated for in-house use only.

             5.     Labeling or color-coding will be required when specimens/containers leave
                    each facility.

             6.      All containers will be closed prior to being stored, transported, or shipped.

             7.     If outside contamination of the primary container occurs, the primary
                    container will be placed within a second container that prevents leakage
                    during handling, processing, storage, transportation, or shipping. The
                    secondary container will be labeled or color-coded.

             8.     If the specimen could puncture the primary container, the primary
                    container will be placed within a secondary container that is puncture
                    resistant and appropriately labeled and color-coded.

      D.      Regulated Waste Disposal

             1.     All Senior Housing Management facilities will dispose of all infectious
                    wastes according to applicable Federal, state, and local regulations.
SOP# P850     Page: 43

              2.     Other regulated waste will be placed in containers that can be closed, are
                     constructed to contain all contents, and will prevent all leakage of fluids.
                     In addition, the containers will be color-coded, labeled or tagged, and
                     closed prior to removal to prevent spillage or protrusion of contents during
                     handling, storage, transportation, or shipping.

Regulated waste means “liquid or semi-liquid blood or other potentially infectious materials;
contaminated items that would release blood or other potentially infectious materials, in a liquid
or semi-liquid state if compressed; items that are caked with dried blood or other potentially
infectious materials, and are capable of releasing these materials during handling;
contaminated sharps; and pathological and microbiological waste containing blood and other
potentially infectious material”.

              3.     If the outside of the container is contaminated with blood or other
                     potentially infectious agents, the regulated waste will be placed in a
                     secondary container prior to handling, storing, transporting, or shipping.
                     The second container will be closable, constructed to contain all contents,
                     and will prevent all leakage of fluids. In addition, the containers will be
                     color-coded, labeled or tagged, and closed prior to removal to prevent
                     spillage or protrusion of contents during handling, storage, transportation
                     of shipping.

              4.     When containers of contaminated sharps are moved from the area of use,
                     they will be closed immediately prior to removal or replacement to prevent
                     spillage or protrusion of contents during handling, storage, transportation,
                     or shipping. These containers will be placed in a secondary container if
                     leakage is possible.         The secondary container will meet the
                     aforementioned requirements.

              5.     Reusable containers will not be opened, emptied, or cleaned manually, or
                     handled in any other manner that will expose an employee to
                     percutaneous injury.

       E.     Disposition of disposable needles, syringes, and other disposable sharps will be
              as follows:

              1.     Contaminated sharps will be discarded immediately, or as soon as
                     feasible, in containers that are closable, puncture resistant, leakproof on
                     the sides and bottom, and appropriately labeled or color-coded.

              2.     Sharps containers will be easily accessible to personnel and located as
                     close as feasible to the immediate use area or where they can be
                     reasonable anticipated to be found (for example, laundry).

              3.     All sharps containers will be disposed when three-quarters full.

              4.     Sharps containers will remain upright throughout use.

              5.     Contaminated needles and sharps will not be sheared, bent, or broken.
                     Contaminated needles will not be removed from disposable syringes.
SOP# P850     Page: 44


Contaminated means “the presence, or the reasonably anticipated presence, of blood or other
potentially infectious materials on an item or surface”.

Contaminated sharp means “any contaminated object that can penetrate the skin, including,
but not limited to, needles, scalpels, broken glass, broken capillary tubes, and exposed ends of
dental wires”.

              6.     Contaminated needles will not be recapped or re-sheathed, except when
                     each facility can demonstrate that no alternative is feasible or that such
                     action is required by a specific medical procedure (for example, arterial
                     blood gases, blood cultures, or administration of incremental doses of a
                     medication). Recapping or needle removal must be accomplished
                     through the use of a mechanical device or a one-handed technique.

              7.     Contaminated, reusable sharps will be placed in appropriate containers
                     immediately, or as soon as possible after use, for proper processing.
                     These containers will be puncture resistant, labeled or color-coded, and
                     leakproof on the sides and bottom.

              8.     Contaminated, reusable sharps will not be stored or processed in a
                     manner that requires employees to reach by hand into the containers
                     where these sharps have been placed.

       F.     Labels and Bags

              1.     Senior Housing Management will incorporate tags that comply with 29
                     CFR 1910.145(F) identifying the presence of an actual or potential
                     biological hazard. These labels will be affixed to containers of regulated
                     waste, refrigerators and freezers containing blood, and other containers
                     used to store, transport, or ship. The following containers need not be
                     labeled:

                     a.     Containers of blood, blood components, or blood products that
                            have been labeled for their contents and have been released for
                            transfusion or other clinical use.

                     b.     Individual containers of blood or other potentially infectious material
                            that are placed in a labeled container during storage,
                            transportation, shipment, or disposal.

              2.     Tags shall contain the word “BIOHAZARD” or the appropriate biological
                     symbol.

              3.     The label should be fluorescent orange or orange-red with lettering or
                     symbols in a contrasting color.

              4.     Labels or tags may be an integral part of the container or affixed to the
                     hazard, as close as feasible, by string, wire, or adhesive to prevent their
                     loss or unintentional; removal.
SOP# P850    Page: 45


             5.     Red bags or red containers may be substituted for labels on containers of
                    regulated material.

             6.     Regulated waste that has been decontaminated need not be labeled or
                    color-coded. However, documentation of decontamination efficacy is
                    required.

III.   HAZARDOUS CHEMICAL WASTE MANAGEMENT PLAN

       A.    The Hazardous Chemical Waste Management Plan describes procedures for the
             identification and disposal of chemical waste, radiation waste, and antineoplastic
             waste.

Hazardous chemical waste is “defined as any chemical that is toxic, flammable, corrosive,
reactive, and is capable of causing harm or serious injury to humans, animals or the
environment”.

Radiation waste is generated from many different areas and uses of radioactive materials.
These areas include Radiation Therapy, Nuclear Medicine, and a variety of research labs.

Antineoplastic waste is defined as those antineoplastic chemicals remaining in containers,
tubes, vials, or wastes due to accident or spillage.

             1.     The facility manager will be authorized to institute the Emergency
                    Evacuation plan during a major chemical waste accident or incident.

             2.     A Material Safety Data Sheet (MSDS) will be obtained on every chemical
                    used in the facility and maintained in the work place.

             3.     A master file of the MSDS’s will be maintained by the facility manager and
                    will be located [specific location]#. A duplicate file will be contained in the
                    work area for use in the event of a hazardous spill, splash, burn, or other
                    accident or incident.

             4.     A list of drugs identified by the Environmental Protection Agency (EPA) as
                    hazardous waste will be provided to the pharmacy by the facility manager
                    { } and reviewed every time a new medication is added or deleted from the
                    pharmacy supply. All other drugs will be segregated and disposed of in
                    accordance with guidance from the facility manager.

             5.     All hazardous chemical wastes will be identified by the originator using the
                    criteria defined by the Resource Conservation and Recovery Act of 1976
                    (RCRA), Subtitle C, Hazardous Waste Regulations, 40 CFR, Part 261. A
                    brief summary of hazardous chemical wastes identification criteria is as
                    follows:

                    a.     Chemical characteristics:

                           I)     Ignitability (flammability of > 140 degrees F). Examples
SOP# P850   Page: 46

                                include ethyl ether, acetone, methanol, and xylene.

                         ii)    Corrosiveness (pH below 2.0 or pH above 12.5). Examples
                                include sodium hydroxide, hydrochloric acid, sulfuric acid,
                                and formic acid.

                         iii)   Reactivity (unstable at normal temperatures and pressures
                                or release of explosive vapors). Examples include azides,
                                hydrogen peroxide (30%), picric acid, and perchloric acid
                                (60%).

                         iv)    EPA toxicity (toxic due to contaminated heavy metals or
                                specific chlorinated organics).      Examples include
                                compounds containing lead, mercury, and/or silver.

                  b.     Acutely hazardous chemical wastes. Examples include cyanide-
                         containing compounds and sodium oxide.

                  c.     Commercial chemical products and manufacturing chemical
                         intermediates. Examples include chloroform, chlordane, and
                         Mitomycin C.

                  d.     Toxic waste. Examples include phenol and daunomycin.

            6.    All drums, buckets, jugs, pails, or any other container containing a
                  hazardous chemical substance will have clear, complete, conspicuous,
                  and durable labels identifying the chemical used.

      B.    Chemical Waste Storage and Handling

            1.    Hazardous chemical waste retained for recycling or contractor disposal
                  will be stored in chemical waste labeled containers maintained for this
                  purpose.

            2.    The facility manager will regularly inspect the storage site to ensure there
                  are no leaking or spilled containers. If a spill or leak is detected, the
                  guidelines outlined in the Chemical Spill Response procedure will be
                  followed.

            3.    Materials that ignite easily under normal conditions (flammables) are
                  considered fire hazards and will be stored in a cool, dry, well-ventilated
                  storage space, well away from areas of fire hazard.

            4.    Highly flammable materials will be kept in an area separate from oxidizing
                  agents (material susceptible to spontaneous heating explosives, etc).

            5.    The storage area for flammables will be supplied with fire fighting
                  equipment, either automatic or manual. “NO SMOKING OR STRIKING
                  OF MATCHES” signs will be posted in and around the storage area.
SOP# P850   Page: 47

            6.    Oxidizers will not be stored close to liquids of low flash point.

            7.    Acids and acid fume sensitive materials will be stored in a cool, dry, well-
                  ventilated area, preferably of wooden construction.

            8.    Materials that are toxic when stored or that can decompose into toxic
                  components from contact with heat, moisture, acids or acid fumes will be
                  stored in a cool, well-ventilated place out of the direct rays of the sun.
                  Incompatible toxic materials will be isolated from each other.

            9.    Corrosive materials will be stored in a cool, well-ventilated area (above
                  their freezing point). The containers will be inspected at regular intervals
                  to ensure they are labeled and kept closed.

            10.   Corrosives will be isolated from other materials.

            11.   Protective clothing and equipment will be available for use when handling
                  these materials.

            12.   Water reactive chemicals will not be stored where there are water
                  sprinklers.

      C.    Chemical Waste Disposal

            1.    Chemical waste will not be poured down the drain without approval from
                  the facility manager.

            2.    No empty drums, buckets, jugs, pails, or any other containers that have
                  held toxic, corrosive materials, or chemicals will ever be reused for
                  anything.

            3.    Expired and unused portions of pharmaceuticals will be disposed of by the
                  facility manager or any other designated individual.

            4.    The facility manager will be responsible for assuring proper permits are
                  obtained by Senior Housing Management for the disposal of all hazardous
                  chemical waste generated at the facility.

            5.    A certificate of disposal will be obtained from the receiver for all hazardous
                  chemicals disposed off site.

IV.   GENERAL WASTE PLAN

      A.    General waste is defined as any waste other than that identified in previous
            sections. General waste for the most part is comprised of paper products (such
            as computer paper, billing forms, and patient records) and includes packaging
            material, food service, and general office waste.

      B.    General waste will be segregated from infectious waste.
SOP# P850   Page: 48

      C.    General waste will be placed in containers lined with brown bags.

				
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