Q1. Are regulated medical waste (RMW) generators required to dispose of (have a registered transporter pick up) their waste monthly or at definite time periods?

A. No, the medical waste regulations do not require generators to dispose of their waste monthly or provide specific time frames for the disposal of RMW. However, all RMW must be disposed of at least once per year. (N.J.A.C. 7:26-3A.12.(b))

Q.2 Are carpules generated at a
dentist's office considered RMW?

A. Yes, carpules are RMW (N.J.A.C. 7:26-3A.6(a)). They are classified as Class 4 - Sharps. They must be handled with the other sharps such as syringes (with or without the attached needle), needles, endo files, burrs, etc. generated at a dentist's office.

Q3. What are the regulated body fluids?

A. Regulated body fluids are liquids emanating or derived from humans and are limited to blood, cerebrospinal, synovial, pleural, peritoneal, pericardial fluids, semen, vaginal secretions, and amniotic fluid. Saliva and urine are not regulated body fluids.

Q4. What is isolation waste Class 6? Is waste generated while treating a patient with AIDS (Acquired Immune Deficiency Syndrome) considered to be isolation waste?

A. Isolation waste is defined as "Any biological waste and discarded materials contaminated with blood, excretion, exudates or secretions from humans who are isolated to protect others from certain highly communicable diseases (such as lassa fever or smallpox, etc.) or animals known to be infected with highly communicable diseases" (N.J.A.C. 7:26-3A.6(a)). The infectious agents causing these diseases are listed in Level 4 of the Centers for Disease Control's (CDC's) Document "Classification of Etiologic Agents on the Basis of Hazard". The CDC guidelines do not list the AIDS virus, therefore waste generated while treating a patient with AIDS is not an isolation waste Class 6. A list of infectious agents included in Class 6 is available from the Bureau of Resource Recovery and Technical Programs (Bureau).

Q5. Are intravenous (IV) bags, tubes and needles that had only saline or nutrient medium in them considered regulated medical waste (RMW)?

A. The needles are always considered RMW pursuant to N.J.A.C. 7:26-3A.6(a). However, if the IV bags and tubing have not come into contact with blood or other regulated body fluid, and they are separated from the needle then the IV bag and tubing alone are not considered RMW.

Q6. Are paper towels or latex gloves containing a drop (or a few drops) of blood or other regulated body fluid considered RMW?

A. No, paper towels or gloves that are not saturated with blood or a regulated body fluid and are not either dripping and soaked in or have dried or caked after having been saturated with such fluids are not RMW.

Q7. Are orthodontic wires, brackets and bonding material considered RMW?

A. Orthodontic wires, brackets and bonding material are generally not considered RMW as they do not meet the definition of RMW. These items would only meet the definition for Class 4 RMW and have to be managed as RMW, if they became saturated and/or dripping with blood or regulated body fluids, or were saturated and/or dripping and are now dried and caked with blood or regulated body fluids (N.J.A.C. 7:26-3A.6(a)). Additionally, in certain very rare circumstances, orthodontic wires or other oral appliances would be regulated as Class 6 - Isolation Wastes, if they were removed for some reason from a patient with any of the serious diseases listed at CDC Level 4.

Q8. Are strep test cards, discs and slides considered RMW?

A. If strep test cards, discs and slides are medical diagnostic test systems that contain any biologicals, such as animal antibodies or products of their metabolism, they would be considered RMW Class 1 - Cultures and Stocks and would be subject to all RMW regulations(N.J.A.C. 7:26-3A.6(a)). However, if they are medical diagnostic test systems that consist of non-biological reagents, they would not be considered RMW. Swabs that are used to inoculate aculture are considered RMW Class 1 - Cultures and Stocks.

Q9. Are animal blood and vaccine vials considered RMW?

A. Blood vials that have been used in animal care are considered RMW Class 4 Sharps and must be handled as such. Animal vaccine vials that have contained agents that have the potential to cause disease in humans are considered RMW Class 4 - Sharps (N.J.A.C. 7:26-3A.6(a)). Vaccine vials that have contained agents infectious only to non-humans are not considered RMW.

Q10. Are barium enema bags considered RMW?

A. No, barium enema bags are generally not considered RMW, as they do not meet the definition of RMW found at N.J.A.C. 7:26-3A.6. These items would only be considered RMW if they are saturated and/or dripping with blood or are now caked with dried human blood or regulated body fluids. Additionally, in certain very rare circumstances these items would be regulated as Class 6 - Isolation Wastes, if they were generated from a patient with any of the serious diseases listed at CDC Level 4.

Q11. When is my annual generator report (AGR) due? Must I request it be mailed to me?

submitting a completed annual report to NJDEP by July 21 of each calendar year (N.J.A.C. 7:26-3A.21.d). The AGR form is mailed to all registered generators. However, if you fail to receive a form you may request one by calling (609) 984-6620.

Q12. If for some reason the NJDEP did not receive an AGR from a generator by the due date and requests the AGR from the generator; however, the generator did submit the report and has documentation to prove that, what should the generator do to respond to such request?

A. The generator should submit a copy of the completed AGR from its records.

Q13. If I have more than one office, must I register each location with the Department?

A. Yes, each location that generates RMW must be registered with the NJDEP (N.J.A.C. 7:26-3A.5) unless a location is a temporary location operating less than 15 days per year (N.J.A.C.7:26-3A.17(e)). Call (609)984-3448 for a registration packet

Q14. If generators treat and destroy their own RMW by methods such as treating with chlorine bleach and grinding, are they considered to be a destination facility? Do they have to be registered as a destination facility?

A. Yes, generators that both treat and destroy their own RMW on site are considered destination facilities and they must be registered as such with the NJDEP. This includes all facilities that accept RMW from other registered generators for treatment and destruction. Registration forms are available by calling (609) 984-6620.

Q15. Where can a generator obtain medical waste tracking forms? Is there a fee for them? How many forms can be ordered at one time?

A. A generator/transporter can obtain the medical waste tracking forms, free of charge from the NJDEP, Bureau of Resource Recovery and Technical Programs, PO Box 414, Trenton, NJ 08625-0414 or by calling (609) 984-6620 during normal business hours.

Q16. Is a generator required to submit copies of tracking forms to the NJDEP?

A. No, generators are not required to submit copies of tracking forms to the NJDEP. The copies of these forms must be retained at the generator's office for at least three years from the date the waste was generated/accepted by the initial medical waste transporter unless the NJDEP specifically requires an additional retention period. The New Jersey Department of Health and Senior Services (DHSS) inspectors during their compliance inspections check these records.

Q17. Are other generators, such as hospitals, permitted to pick up RMW generated by another generator, such as a private practitioner?

A. No, generators, such as hospitals cannot transport another generator's RMW without possessing the permits listed at N.J.A.C. 7:26-3A.27. These requirements include:
a. Registering as an RMW transporter in accordance with N.J.A.C. 7:26- 3A.8;
b. Registering as a solid waste
transporter; and
c. Obtaining a certificate of public
convenience and necessity issued
by the Division of Solid and
Hazardous Waste.

Q18. What should I do if I do not receive Copy 1 of the Medical Waste Tracking Form from the destination facility?

A. If you do not receive a completed Copy 1 of the tracking form with a handwritten signature of the owner/operator within 35 days of initial transport off site, you should contact the destination facility and attempt to determine the status of the tracked waste. If, within 45 days of initial transport off site you still do not receive Copy 1 of the tracking form you must submit an exception report to: NJDEP, Bureau of Solid Waste Compliance and Enforcement, P0 Box 407, Trenton, NJ 08625-0407 (N.J.A.C. 7:26-3A.22(b)).

Q19. If I have more than one office, may I take the RMW to one site for storage, consolidation or disposal?

A. Yes, if a generator generates less than 50 lbs. per month and transports its waste in a vehicle weighing less than 8,000 lbs. (N.J.A.C. 7:26-3A.17) but a RMW tracking form must still be used to transport the RMW from one site to another. Please note that generators which accept RMW for storage or consolidation must be registered as a collection facility and generators which accept RMW for disposal must be registered as RMW destination facility.

Q20. May mail services be used to transport RMW?

A. Yes, the U.S. Postal Service can be used to transport RMW Class 4 - Sharps and Class 7 - Unused Sharps for disposal. The RMW must be sent registered or certified mail, return receipt requested (indicating the person to which the package is sent, signature of the sender, date and address where delivered) or priority mail as required by N.J.A.C. 7:26-3A.17(b). The generator must retain the original receipt and the returned registered or certified mail receipt and attach them to the generator copy of the tracking form.

The generator must sign the certification section of the tracking form by hand; sign the transporter section indicating the transporter is the U.S. Postal Service and note the date the shipment was mailed; and ensure that the tracking form accompanies the RMW while in transit (N.J.A.C. 7:26-3A.17(b)).

Q21. How do I dispose of RMW that is derived from radioactive medical materials?

A. Such waste may be returned to the supplier of the original radioactive medical materials using a registered RMW transporter and completing a RMW form as described in N.J.A.C. 7:26-3A.19(h).

Q22. May I recycle RMW?

A. Yes, certain materials that are reused or recycled in accordance with all applicable Federal, State and local laws and regulations for the handling and managing of such materials, are not considered RMW if the generator first treats the materials and, for sharps, destroys them prior to shipping off site (N.J.A.C. 7:26-3A.6(b)).

Q23. What is the proper way to mark and label packages of RMW?

A. See Figure 1 on page 4 (N.J.A.C. 7:26-3A .14 and 15)

Q24. If I am in compliance with the NJDEP's medical waste regulations, can I assume that I am in compliance with OSHA's regulations?

A. No, the Federal Occupational Safety and Health Administration (OSHA) has separate regulations with which you must comply for a broader range of patient contact issues; materials and wastes produced at your business other than RMW. You may contact OSHA at (609) 757-5181.

Q25. Is waste generated from Body Art Establishments (i.e. tattoo parlors, Body Piercers and permanent cosmetic professionals) considered RMW?

The public health risks inherent to Body Art arise largely from the use of sharps and the potential to transmit bloodborne pathogens. Therefore, in 2001 the Department of Health & Senior Services promulgated N.J.A.C. 7:26-8:27 entitled "Body Art Procedures". This subchapter incorporates the RMW regulations at N.J.A.C. 7:26-
3A by cross-reference. Therefore sharps and blood soaked items from Body Art establishments must be managed as RMW.

Medical Waste Registration:
*Generators
(609) 984-3448

*Transporter Registration
(609)292-7081

*Facilities
(609) 984-6620

Bureau of Solid Waste Compliance and Enforcement
(Transporters & Facilities)
(609) 584-4180