Medical Waste and Sharps Safety Policy

1. Policy Statement

It is the policy of this organization that safe handling and disposal of regulated medical waste shall protect healthcare workers, patients, waste handlers, and the broader community from exposure to potentially infectious materials and sharps injuries. Waste management practices shall be based on all applicable federal, state, and local laws and regulations and implemented through organizational policies, procedures, and practice guidelines. The organization shall incorporate risk reduction for exposure to potentially infectious materials and needlestick injuries into its comprehensive quality improvement program and shall ensure that all personnel—including patients and caregivers receiving home infusion therapy—receive appropriate education and resources.

2. Purpose

This policy exists to:

• Mandate the use of safety-engineered devices to prevent needlestick and sharps injuries in all settings where vascular access and infusion procedures are performed.
• Define sharps container requirements, placement standards, and safe disposal practices.
• Prohibit unsafe sharps handling practices including recapping, breaking, and bending.
• Establish comprehensive education requirements for clinical staff, patients, and caregivers.
• Define injury reporting and follow-up processes that support appropriate postexposure prophylaxis and generate data for quality improvement.
• Standardize medical waste segregation and disposal in compliance with applicable regulatory requirements.
• Promote waste minimization strategies where clinically appropriate.

3. Scope

This policy applies to:

• All healthcare workers who handle sharps, use vascular access devices, or generate medical waste in any care setting.
• Environmental Services, Waste Management, Supply Chain, Infection Prevention, and Occupational Health insofar as they manage, procure, or oversee medical waste handling.
• Patients and caregivers who receive home infusion therapy and generate sharps or medical waste in the home setting.
• All care settings, including inpatient units, emergency departments, ambulatory infusion centers, home health, and any setting where sharps or infusion-related waste is generated.

4. Policy Requirements

4.1 Foundational Principles

4.1.1 Medical waste management shall be based on applicable laws, rules, and regulations established in each jurisdiction—including federal, state, and local requirements—and implemented through organizational policies and practice guidelines.

4.1.2 The organization shall systematically track and analyze exposure incidents, waste handling practices, and sharps injuries to identify trends and implement targeted risk-reduction interventions through its quality improvement program.

4.2 Sharps Container Requirements and Placement

4.2.1 Container Standards. Contaminated sharps shall be discarded only in containers that are: closable, non-permeable, puncture-resistant, tamperproof, and clearly labeled with biohazard markings.

4.2.2 Point-of-Use Placement. Sharps containers shall be: (a) easily accessible and located in the immediate area where sharps are used to encourage immediate disposal after use, and (b) never positioned so that healthcare workers must walk more than a few steps to discard a used sharp. Transport of used sharps from the point of use to a distant disposal container is prohibited.

4.2.3 Container Sizing. Sharps containers shall be large enough to accommodate disposal of entire blood collection assemblies—including the holder and needle—without requiring disassembly. Attempting to separate blood collection device components increases needlestick injury risk and is prohibited.

4.2.4 Enhanced Security. Areas with elevated tampering risk—including pediatric units, mental health units, and correctional facilities—shall implement additional or enhanced security measures for sharps containers, such as locked containers, video monitoring, or supervised disposal.

4.3 Needlestick Injury Prevention

4.3.1 Safety-Engineered Devices (SEDs). Healthcare workers shall use safety-engineered devices for all parenteral medication preparation, vascular access device insertion, blood sampling, and related procedures. Safety-engineered devices that isolate or remove the bloodborne pathogen hazard shall be available in the workplace and used in accordance with manufacturer’s directions.

4.3.2 Passive Safety Devices. Passive safety-engineered devices—which activate automatically without requiring a deliberate activation step—shall be used whenever possible. Passive devices provide superior protection compared to active devices because they do not depend on healthcare worker compliance with activation procedures. Studies demonstrate that passive safety devices achieve higher activation rates and lower injury rates than active devices.

4.3.3 Safe Handling Practices. Healthcare workers shall observe the following mandatory practices:

• No recapping. Needles shall never be recapped, even using a one-handed scoop technique, except in rare circumstances where no safe alternative exists and the clinical rationale is documented.
• No bending or breaking. Needles and sharps shall never be bent, broken, or manually manipulated before disposal. Breaking or bending sharps provides no safety benefit and significantly increases injury risk.
• Immediate disposal. Used sharps shall be discarded directly into the nearest appropriate sharps container immediately after use.
• No disassembly. Devices with built-in safety controls shall have their safety features activated, and the entire device shall be discarded as a single unit without disassembly.

4.4 Education and Training

4.4.1 Comprehensive Staff Education. The organization shall educate all clinical staff in: safe sharps handling practices, proper use and activation of safety-engineered devices per manufacturer’s directions, medical waste segregation and disposal procedures, and the importance of reporting needlestick injuries and bloodborne pathogen exposures. Research demonstrates that education combined with implementation of sharps safety products synergistically reduces needlestick injury risk.

4.4.2 Hands-On Training. Training shall include hands-on practice with assigned safety-engineered devices and demonstrated competency assessment before independent clinical use. Competency shall be reassessed when new devices are adopted.

4.4.3 End-User Involvement. Clinical end users shall participate in the evaluation of safety-engineered devices before organizational purchasing decisions. End-user evaluation ensures that selected devices meet real-world clinical needs, achieve adequate user acceptance, and function effectively in actual care environments.

4.4.4 Patient and Caregiver Education. Patients and caregivers receiving home infusion therapy shall receive comprehensive education on: safe sharps handling, use of sharps containers, proper containment of contaminated materials, and community disposal resources (pharmacy take-back programs, mail-back programs, hospital drop-off sites).

4.5 Injury Reporting and Follow-up

4.5.1 Mandatory Reporting. All exposures to potentially infectious materials or injuries from sharps shall be reported immediately to the occupational health or employee health department and documented according to organizational protocols. Immediate reporting enables appropriate postexposure prophylaxis, establishes workers’ compensation eligibility, generates data for quality improvement, and demonstrates organizational commitment to worker protection.

4.5.2 Documentation Requirements. Documentation of sharps injuries shall include: the type and brand of device involved, the procedure being performed, the area of the body affected, whether the safety feature was activated and if not, why not, and relevant patient information for bloodborne pathogen exposure risk assessment.

4.5.3 Trend Analysis. The organization shall monitor and analyze exposure data on a regular basis to identify specific devices, procedures, or work areas with elevated injury rates, enabling targeted interventions to reduce risk.

4.5.4 Reporting Culture. Needlestick injuries remain significantly underreported in many healthcare settings. The organization shall promote a non-punitive reporting culture and shall simplify the reporting process to remove barriers. Retaliation against a clinician for reporting a sharps injury is a policy violation.

4.6 Medical Waste Segregation and Disposal

4.6.1 Waste Segregation. The organization shall sort and segregate medical waste according to applicable federal, state, and local guidelines. Proper segregation ensures appropriate processing and disposal and may reduce costs associated with unnecessary classification of non-hazardous waste as regulated medical waste.

4.6.2 Segregation Categories. At minimum, medical waste shall be segregated into: regulated medical waste (potentially infectious materials), hazardous waste (including hazardous drug waste, as governed by the Hazardous Drug Management Policy), sharps waste, pharmaceutical waste, and non-regulated waste. Each category has specific containment, labeling, and disposal requirements.

4.6.3 Waste Minimization. The organization shall implement strategies to reduce unnecessary waste generation where clinically appropriate. This includes: using standardized checklists for waste handling procedures to reduce errors and improve compliance, evaluating whether procedures requiring Surgical-ANTT could safely use Standard-ANTT where the infection risk does not require full surgical asepsis (per the ANTT Risk Assessment framework), and reducing unnecessary sterile packaging.

4.6.4 Environmental Responsibility. The organization recognizes the substantial environmental burden of medical waste and shall pursue waste minimization as a strategic and ethical priority without compromising patient or worker safety.

4.7 Patient and Caregiver Education for Home Waste Disposal

4.7.1 Patients and caregivers receiving home infusion therapy shall receive comprehensive instruction on: proper disposal of unused non-hazardous drugs or solutions, disposal of infusion-related supplies including tubing, bags, and dressings, and use of sharps containers for needles, syringes, and lancets.

4.7.2 Information shall be provided about community disposal options including: pharmacies with sharps disposal programs, hospital or clinic drop-off programs, mail-back sharps disposal services, and local waste management authority options.

4.7.3 Patients and caregivers shall be instructed on proper containment of contaminated materials to prevent injury to household members, waste collection personnel, and the general public.

5. Compliance

5.1 Monitoring. Compliance shall be monitored through: tracking of needlestick injury rates and near-miss reporting rates, concurrent observational audits of sharps safety device activation rates during clinical rounding, sharps container placement and fill-level audits, waste segregation compliance audits, staff safety education completion rates, and annual review of safety-engineered device performance data.

5.2 Key Performance Indicators.

• Needlestick injury rate per 1,000 procedures (target: year-over-year reduction).
• Safety-engineered device activation rate (target: ≥95%).
• Sharps injury reporting rate (target: 100% of known injuries reported).
• Waste segregation compliance rate (target: ≥95%).
• Patient/caregiver home waste disposal education completion rate prior to home infusion discharge (target: 100%).

5.3 Enforcement. Unsafe sharps handling practices (recapping, breaking, bending) identified through observation shall result in immediate individual coaching and, if recurrent, progressive corrective action. Failure to report a sharps injury is a policy violation subject to disciplinary action. Systemic waste segregation failures shall be addressed through process redesign and targeted education.

6. Exceptions

6.1 Recapping of a needle may occur only when there is no safe alternative and the clinical rationale is documented. The one-handed scoop technique shall be used when recapping cannot be avoided. Any recapping incident shall be reported through the safety reporting system.

6.2 In mass casualty or surge situations, temporary deviations from standard waste segregation practices may be approved by the CNO with documentation of the deviation and a plan for restoration of standard practices upon resolution.

7. Related Documents

• POL-015: Hazardous Drug Management
• POL-001: Foundations of Clinical Practice and Specialized Population Management
• POL-009: Patient Education in Infusion Therapy
• OSHA Bloodborne Pathogen Standard (29 CFR 1910.1030)
• OSHA Needlestick Safety and Prevention Act
• EPA Medical Waste Regulations
• Applicable State Medical Waste Disposal Regulations
• Organizational Bloodborne Pathogen Exposure Control Plan
• Organizational Postexposure Prophylaxis Protocol
• Organizational Sharps Injury Log and Reporting System

8. Revision History