Managing Toxins
Medical waste is defined as all waste materials generated by health care facilities, such as hospitals, clinics, physician's offices, dental practices, blood banks, and veterinary hospitals/clinics. Medical waste from these facilities generally fall into one of four categories: infectious, hazardous, radioactive, and other general wastes. While the majority of facilities carefully monitor the use and disposal of blood soaked bandages, culture dishes and surgical instruments they often tend to overlook their radiography equipment and supplies. Though it is true that waste classified as hazardous and radioactive represent a small portion of medical waste generated, they garner the greatest concern.The Environmental Protection Agency (EPA) has regulations governing medical waste, as well as requirements under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). The Department of Transportation Office of Hazardous Materials Safety regulates its transportation. The Food and Drug Administration (FDA) regulates medical devices. The Nuclear Regulatory Commission regulates some types of radioactive waste. Occupational Safety & Health Administration (OSHA) regulates it in the workplace. The US Postal Service (USPS) regulates it via the postal system. The Health Insurance Portability and Accountability Act (HIPAA) regulates patients' right to privacy.
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When hiring a company to dispose of radiography equipment, processing chemicals and x-ray film all facilities are legally obligated to hire a company that is licensed to disable, remove, transport, recycle and/or dispose of the materials. This also includes any item that has been exposed to radiation by an x-ray machine such as film cassettes and positioners. If you are unsure of a company's license, you are encouraged by the agencies above to request a copy or obtain a license number. Once received you may contact the department that issued the license to check on its validity. State agencies also suggest that you retain any information received regarding the license for instances where you may be questioned by an agency regarding the disposal. HIPAA requires that, upon request, patients be provided with a list of who has had access to or been provided a copy of their records for reasons other than treatment. A log must be kept detailing who had access, for what reason and when access was provided. This includes the disposal of patient x-ray films, even after they have left your facility. Besides assurances of continued patient confidentiality, you should be able to determine that these films are destroyed in an environmentally sound manner. Your selection of an outside vendor is a matter of trust and serious obligation. |
Dealing with regulatory agencies diminishes for facilities who invest in digital radiography, but for those with conventional equipment the requirements can be cumbersome. There are however several tried and true guidelines you can follow to make your radiography environment healthier.
(1) Prior to installation select a company that can properly configure your radiography department. When done correctly this will reduce the lead shielding required and thus your installation cost.
(2) When purchasing an x-ray film processor select a company that can decrease the effects of chemical emissions by providing you with insight on how to adequately ventilate your darkroom.
(3) Keep vermiculite (a natural mineral that expands) or other inert material on hand for x-ray processor chemical spills and a chemical waste container for the discarded material.
(4) Obtain a licensed company that will honor your local, state and federal regulations to haul or dispose of your chemical waste. Costs are usually minimal, if any at all and are well worth it.
(5) If filters are used for disposing of chemical wastes make sure your service company is routinely monitoring and replacing them. Don't just assume they did because they billed you for it.
In addition, service companies are obligated to provide their clients with current Material Safety Data Sheets (MSDS) when available. A MSDS is a form containing data regarding the properties of a particular substance. Workers and emergency personnel can utilize the procedures listed on those forms to handle and work with substances in a safe manner. With a little know how, the proper tools and a licensed service company medical waste can be managed in a controlled environment.
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