Off-site Treatment and Disposal

In nearly all states, transporters of RMW must have a transport permit to pick up and transport the waste to a treatment and disposal facility.7 Some states allow small amounts of RMW to be transported without a permit. Disposal of RMW by a contractor is convenient, but may be expensive. The contractor will usually supply shipping containers, which meet federal and state requirements, and provide the documentation needed for record keeping purposes.

OSHA requires that RMW containers be closed prior to removal from the workstation to prevent spillage or protrusion of contents during handling, storage, transport, or shipping.4 The United States Department of Transportation (USDOT) mandates that the biohazard bags used to line approved shipping containers for transport of RMW from the generator’s facility to a treatment and disposal facility be certified by the manufacturer to meet USDOT standards.23

The USDOT requires tear resistance of 480 grams by the American Society for Testing Materials (ASTM) D1922 Standard Test Method for Propagation Tear Resistance of Plastic Film and Thin Sheeting by Pendulum Method and impact resistance of 165 grams by the ASTM D1709 Standard Test Methods for Impact Resistance of Plastic Film by the Free-Falling Dart Method in both parallel and perpendicular planes with respect to the length of the bag.22,23

Consequently, USDOT-approved containers must be lined with a biohazard bag that is both ASTM D1709 and ASTM D1922 certified. If the biohazard bags used to collect and transport RMW within a facility meet impact resistance of 165 grams by the ASTM D1709 method, but not tear resistance by the ASTM 1922 method, the ASTM D1709-certified bag must be placed into an ASTM D1922-certified biohazard bag before placing it into a shipping container.