06/01/2015

Dentists must comply with new medical waste law


California’s Medical Waste Management Act (MWMA) was amended earlier this year. As a result of this amendment, there are changes dental practices need to make. It has come to CDA’s attention that there has been some misinformation circulated which is causing confusion.
Below are the facts of the MWMA changes that impact dental practices:

•  A dental practice that uses a mail-back system for medical waste need only obtain proof that the system is approved by the U.S. Postal Service. It is no longer required that the state approve mail-back systems for medical waste. 

•  A dental practice that self-hauls its medical waste to a permitted transfer station, treatment facility or other health facility for waste consolidation must comply with the U.S. Department of Transportation Materials of Trade regulation. Registration or permit from a local enforcement agency is no longer required.

•  When a dentist is participating in a temporary event that results in the generation of medical waste (e.g., health fairs, veteran stand downs), the dentist will either (1) obtain documentation from the event sponsor that the sponsor has notified the local enforcement agency of the event, or (2) notify the local enforcement agency of intended participation in the event at least 72 hours before the event.

Storage times for medical waste, which in a dental practice includes sharps, bio-hazardous waste and expired noncontrolled drugs, have not changed for “small-quantity generators” (facilities that generate less than 200 pounds of medical waste per month). For containers that contain only sharps waste or only pharmaceutical waste, the storage time clock begins when the contents are at the container fill line. Containers with combined waste must be disposed within the shorter storage time allowed. For example, a container with both sharps and bio-hazardous waste must be disposed within 30 days of placing the bio-hazardous waste in the container; if the container held only sharps, the dental practice has 30 days after the container is filled to dispose of the waste.

All dental practices will need to revise their medical waste management plans to conform with the changes in the Medical Waste Management Act. As a member benefit, CDA offers a sample Medical Waste Management and Disposal Plan as part of the Regulatory Compliance Manual, available at cda.org/practicesupport. A list of medical waste disposal options and a table listing dental waste storage times and disposal options also are available on cda.org/practicesupport.



Related Items

The subject of medical waste disposal has been one of the more frequent questions from members coming into CDA’s Practice Support lately. The state Department of Public Health (DPH) has posted a new chart on dental medical waste disposal. While the law hasn't changed, the new chart can help dentists who are curious about the storage time for different types of medical waste.

CDA Regulatory Compliance Manual
Use this sample plan to describe the medical waste management and disposal procedures of your dental practice. It contains information required by the California Medical Waste Management Act, Health and Safety Code Sections 117600-118360. This resource is part of the CDA Regulatory Compliance Manual. Updated May 2015

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