Livestock and Potentially Infectious Medical Waste

Livestock Producer Requirements

Title XV of the Illinois Environmental Protection Act (Act) establishes statutory requirements to ensure that Potentially Infectious Medical Waste (PIMW) will be handled in a safe and responsible manner. On June 17, 1993, the Illinois Pollution Control Board (Board), in accordance with Title VII of the Act, adopted regulations prescribing the standards and criteria for the handling of PIMW. These regulations became effective June 21, 1993. The requirements found in the Act and the Board’s regulations are intended to reduce the occupational and environmental health risks that occur during the storage, treatment, transport, transfer, and disposal of PIMW.

The information presented in this fact sheet does not eliminate any person’s responsibility to fulfill any legal obligation under the Act or regulations promulgated thereunder.

The purpose of this fact sheet is to provide some of the PIMW requirements, found in both the Act and the Board’s regulations. For the complete requirements, please see Title XV of the Act and 35 Illinois Administrative Code (Ill. Adm. Code): Subtitle M.

For additional information on PIMW regulations in Illinois, contact the PIMW Coordinator at the Illinois Environmental Protection Agency; Bureau of Land #33; 1021 North Grand Avenue East; P.O. Box 19276; Springfield, Illinois 62794-9276, or call (217) 524-3289.

What is Potentially Infectious Medical Waste (PIMW)?

Potentially Infectious Medical Waste (PIMW) is waste generated in connection with:

  1. The diagnosis, treatment (i.e., provision of medical services), or immunization of human beings or animals;
  2. Research pertaining to the provision of medical services; or
  3. The production or testing of biological agents.

Types of PIMW wastes are:

  1. Cultures and stocks;
  2. Human pathological wastes;
  3. Human blood and blood products;
  4. Used sharps;
  5. Animal waste;
  6. Isolation waste;
  7. Unused sharps.

PIMW does NOT include:

  1. Medical waste generated as general household waste;
  2. PIMW (except for sharps) which has been treated properly to eliminate its infectious nature; and
  3. Sharps which have been treated to eliminate their infectious nature and which have been rendered unrecognizable by treatment.

What is animal waste?

"... discarded materials, including carcasses, body parts, body fluids, blood, or bedding originating from animals inoculated during research, production of biological agents, or pharmaceutical testing with agents infectious to humans."

Therefore, carcasses and waste generated from animals not inoculated with agents infectious to humans would not be PIMW. Animal carcasses that do not meet the definition of "animal waste" may be disposed of in a lawfully permitted landfill. Current Illinois land disposal regulations do not prohibit such activity. However, a landfill operator has the authority to refuse acceptance of any waste at the landfill(s).

What “sharps” are PIMW?

The Act identifies used and unused sharps generated in connection with the diagnosis, treatment, or immunization of animals as PIMW. The Act defines "used and unused sharps" as follows:

Used sharps: This waste shall include but not be limited to discarded sharps used in animal or human patient care, medical research, or clinical or pharmaceutical laboratories; hypodermic, intravenous, or other medical needles; hypodermic or intravenous syringes; Pasteur pipettes; scalpel blades; or blood vials. This waste shall also include but not be limited to other types of broken or unbroken glass (including slides and cover slips) in contact with infectious agents.

Unused sharps: This waste shall include but not be limited to the following unused, discarded sharps: hypodermic, intravenous, or other needles; hypodermic or intravenous syringes; or scalpel blades.

Discarded live or attenuated vaccines, as well as culture dishes and devices used to inoculate or mix cultures that are generated in connection with the diagnosis, treatment, or immunization of animals, are PIMW.

How should PIMW be segregated and packaged for off-site transport?

Livestock producers should separate their PIMW from other types of wastes (i.e., general refuse, special wastes, hazardous wastes, and radioactive wastes). For PIMW commingled with other waste types, the whole lot must be managed in accordance with the regulations for each waste type.

The PIMW should be sorted into 3 categories: (1) sharps, (2) oversized PIMW, and (3) all other PIMW. To insure that PIMW is packaged securely and will not leak during transport, the containers should be (1) rigid, (2) leak-resistant, (3) impervious to moisture, (4) of sufficient strength to prevent tearing or bursting, and (5) sealed to prevent leakage.

In addition to the requirements listed above, sharps must be packaged in containers that are also puncture-resistant. Oversized PIMW must be covered or packaged so that contact with transport workers and the public is minimized. Sharps may not be packaged with oversized PIMW.

How should PIMW be labeled for off-site transport?

Livestock producers who package PIMW for off-site transportation must mark on two opposite sides of the exterior of the PIMW package (on one side of oversized PIMW), in lettering that is readable at a minimum distance of five feet: (1) the word 'BIOHAZARD', (2) the word 'Sharps' if the package contains sharps, and (3) the International Biohazard Symbol.

In addition, the producer must securely attach a water-resistant label or tag to each package and write in indelible ink: (1) Generator's name, (2) Generator's address, and (3) Generator's phone number (24-hour number, if available).

Inner packages must be marked with the word 'BIOHAZARD', the word 'SHARPS' if they contain sharps, and the International Biohazard Symbol.

How should PIMW be stored?

Livestock producers who store PIMW prior to treatment or disposal on-site, or transport off-site must comply with the following:

  1. Maintain the integrity of the packaging and provide protection from water, rain, and wind;
  2. Maintain PIMW in a non-putrescent state, using refrigeration when necessary;
  3. Lock the outdoor storage areas containing PIMW to prevent unauthorized access;
  4. Limit access to on-site storage areas to authorized employees;
  5. Store the PIMW in a manner that affords protection from animals and does not provide a breeding place or food source for vectors (i.e., insects and rodents);
  6. Must not compact the PIMW packages or subject them to stress which compromises the integrity of the container;
  7. Reusable PIMW containers or equipment which are visibly contaminated with PIMW must be cleaned in a designated area.

What should be done with residues from cleaning or treating PIMW?

Treatment residuals must be disposed of in accordance with all applicable regulations.

Residues from cleaning and disinfecting anything contaminated with PIMW are regulated as PIMW, except when discharged directly into a sanitary or combined sewer in accordance with 35 Ill. Adm. Code: Subtitle C (Water Pollution Control). Please note: Local government or sanitary districts may have requirements that are more restrictive than these regulations. The generator of any residue is responsible for checking with the local sanitary district before disposing of any liquid PIMW into the sewer system. Solids are prohibited from disposal into any sewer system.

Residues which have been treated as PIMW in accordance with these regulations are no longer considered PIMW and may go to any municipal landfill, EXCEPT:

  1. ash from incineration, which must be managed as a "special waste";
  2. liquids ONLY may be discharged to the sewer system in accordance with a water pollution permit and local sanitary district regulations;
  3. sharps must be treated to eliminate the infectious potential and be unrecognizable or packaged in accordance with these regulations before they can be placed in landfills.

Who can transport PIMW and what are the special requirements?

A livestock producer may: (1) use a permitted PIMW transporter; (2) use a noncommercial transporter who transports less than 50 pounds of PIMW at any one time; (3) use the U.S. Postal Service; or (4) transport the waste themselves.

Who can accept PIMW for storage, treatment, or transfer?

Only PIMW facilities issued permits by Illinois EPA to treat, store, or transfer PIMW will be authorized to accept PIMW from off-site. Only PIMW that has been packaged and labeled in accordance with the regulations may be shipped to these facilities.

Untreated medical waste cannot be disposed of into any landfill!

Untreated PIMW is banned from all landfills in Illinois. Once PIMW has been properly treated to eliminate its infectious potential, it is no longer PIMW (except in the case of sharps) and may be disposed of into any landfill permitted by the Illinois EPA to accept municipal waste. For sharps, both the infectious nature must be eliminated and the sharps must either be rendered unrecognizable or packaged in accordance with the regulations prior to disposal. A livestock producer who treats the PIMW on-site must certify to the transporter, if other than the generator, and certify to the landfill operator or receiving facility operator that the PIMW has been treated in accordance with 35 Ill. Adm. Code 1422 and, if applicable, with all terms and conditions specified in his operating permit. Data verifying the efficacy of the treatment unit must be made available to the receiving facility upon request of the receiving facility.

PIMW treated by Incineration

Waste incinerators require a permit from the Illinois EPA Bureau of Air. If the incinerator owner/operator accepts any waste from a person or facility off-site, then permits from the Illinois EPA Bureau of Land will be required. Incinerators must meet all testing requirements as described in the regulations, even if no Bureau of Land permit is required.

Ash resulting from the incineration of PIMW is categorized as an industrial process waste, and therefore must be managed as a special waste. Special waste requires a special waste manifest, must be transported by a permitted special waste hauler, and can only be disposed of into landfills permitted to accept special waste. Details of the management of special waste may be found in Section 3.45 of the Act or in the Illinois EPA Fact Sheet on Non-Special Waste Certification.

PIMW treated by Autoclaving

Autoclaves will not require a permit from Illinois EPA for the treatment of PIMW generated at the site. If the owner/operator accepts any waste from a person or facility off-site, then a permit from the Illinois EPA Bureau of Land will be required. Autoclaves must meet all testing requirements as described in 35 Ill. Adm. Code: Subtitle M, even if no Bureau of Land permit is required.

What records and reports does a livestock producer need to complete for PIMW?

Manifests:
Manifests are required for the transport of PIMW (except for the exemptions described above). Livestock producers, transporters, and storage/transfer/treatment facilities are required to retain these manifests for 3 years and must make them available for inspection and copying by Illinois EPA.

Annual Reports:
A report must be filed with Illinois EPA by March 31 each year by livestock producers who treat more than 50 pounds per month of PIMW, specifying the quantities and disposition of PIMW transported, stored, treated, disposed, or transferred during the previous calendar year. Such reports must be on forms prescribed and provided by Illinois EPA.