Biohazardous Waste – What Is It and What Do I Do With It?








The terms “biohazardous material,” “biohazardous waste,” “medical waste,” “regulated waste,” and “regulated medical waste” are used somewhat interchangeably, but they all have different definitions, and the definitions can change depending on the state in which you are located.

Biohazardous Material

– refers to materials that present a risk or potential risk to the health of humans, animals, or the environment.  They can be infectious agents or chemicals or other products that can damage the environment. Certain chemotherapy drugs and most laboratory reagents fall into the biohazardous material category.

Biohazardous Waste

– refers to waste (e.g. body fluids or tissues) which has the risk of carrying human pathogens.  Biohazardous Waste is usually generated at health care facilities or research facilities, and the term is used interchangeably with Medical Waste.

Regulated Waste

– is the term OSHA uses to describe blood and body fluids and “OPIM” (other potentially infectious material) as defined in the Bloodborne Pathogens regulation (BBP).

Regulated Medical Waste

– refers to biohazardous waste whose handling is regulated by state or federal laws.

In a medical practice or laboratory we are most often concerned with the BBP-defined Regulated Waste and the state-defined Regulated Medical Waste which we must discard per state and federal regulations.  The failure to understand the difference in the definitions can lead to unnecessary expenses for disposing of regulated medical waste.

The Bloodborne Pathogens Standard uses the term “regulated waste” to refer to the following categories of waste:

  • Liquid or semi-liquid blood or other potentially infectious materials (OPIM)
  • Items contaminated with blood or OPIM and which would release these substances in a liquid or semi-liquid state if compressed
  • Items that are caked with dried blood or OPIM and are capable of releasing these materials during handling
  • Contaminated sharps
  • Pathological and microbiological waste containing blood or OPIM

In order to avoid some confusion, I’m going to refer to the BBP-defined regulated waste as “medical waste” or “biohazardous waste”  to more easily differentiate it from “regulated medical waste” as administered by the state.

Biohazardous Medical Waste:

  • must be discarded in containers that are clearly marked with a biohazard symbol or in a red bag, which is universally accepted as a symbol of biohazardous waste.
  • sharps must be disposed of in hard-sided containers which cannot be penetrated by the sharp material and marked as biohazardous if the container has potentially infectious material within.  Almost all sharps generated in a medical practice contain potentially infectious materials.

“Regulated Medical Waste” generally refers to waste whose disposal is regulated by state and/or federal laws.  In North Carolina, regulated medical waste is defined in general as “blood and body fluids in individual containers in volumes greater than 20 ml, microbiological waste, and pathological waste that have not been treated pursuant to specific standards.” Therefore, a 10 ml tube of blood is medical (biohazardous) waste, but is not regulated medical waste — it doesn’t meet the 20 ml individual container specification.   Table paper contaminated with blood or vaginal secretions is medical (biohazardous) waste but not regulated medical waste—it doesn’t meet the expressible blood specification.

Regulated medical waste:

  • is generally handled by contracting with a waste management company to take the waste offsite and bury it or decontaminate it or otherwise destroy the potential for harm from it
  • the big square boxes with the red liners and biohazard signs on all sides that you have picked up by waste disposal companies contain regulated medical waste
  • you pay (per box) to have these removed
  • you get a receipt when a box is picked up, and eventually a certificate with proof of destruction or decontamination.  (This information must be saved for at least 3 years in NC.)

Technically, most medical practices do not generate any state-defined regulated medical waste.  Individual tubes of blood or body fluids are almost always smaller than 20 ml.  Urine, which is not considered medical waste unless it is visibly contaminated with blood or pus, may be disposed of by pouring it down the sink.  Contaminated table paper doesn’t fit the “expressible blood” definition required for “regulated medical waste.”  Gloves which do not have visible blood on them are not considered medical waste.

OK, so why are we paying so much

to have the big square boxes with the red liners picked up and taken offsite?  Because most landfills won’t accept the red biohazardous bags in which we discard the biohazardous waste that is not regulated.  Therefore  the practice is left with little choice but to pack it up and send it with the waste management people as regulated medical waste.  I would recommend checking with the municipal authorities to see if it is allowable to discard red biohazard bags (that don’t contain regulated medical waste) in the landfill.  If your municipality does allow this, there is no need to put these red bags in the large boxes dedicated to regulated medical waste.

Whether or not you are allowed to dispose of biohazardous waste that isn’t regulated in the community landfill, you can limit the amount of regulated medical waste you have picked up by educating your staff as to what qualifies for the big square boxes or a biohazard bag disposal, and what can be put in ordinary trash.

Table paper that isn’t visibly contaminated does not qualify as medical waste – put it in the regular trash.  Gloves that are not contaminated with blood can go in the regular trash.  And make sure the staff isn’t putting paper waste into a big square box just because it is conveniently located!

Pearls of Wisdom from OSHA…per OSHA, it is the employer’s responsibility to determine the existence of medical waste.  This determination, according to OSHA, should not be made based on the volume of blood, but rather on the potential to release blood (e.g. when compacted in a waste container).  OSHA states that bandages which are not saturated to the point of releasing blood or OPIM if compressed is not considered biohazardous waste.  Likewise, discarded feminine hygiene products do not normally meet the criteria for medical waste as defined by the BBP standard.  Beyond these guidelines, it is the employer’s responsibility to determine the existence of medical waste.

Here is a link to a website where you can get to the state regulated medical waste regulations by state.

Guest Author Libby Knollmeyer

Consultant Elizabeth Knollmeyer, B.S., MT (ASCP) has over 40 years experience in the laboratory industry. She specializes in financial, operational management and compliance issues for both hospital and physician office laboratories. Libby has a wide variety of experience with her areas of special expertise including financial review and management, Quality Management protocols, Outreach development, compliance and regulatory assistance, lab design and up fitting, lab remodeling, and market research for IVD manufacturers. She works independently and with large consulting groups to provide interim management for hospitals, and serves as adviser to lab equipment and supply distributors. She can be reached at (336) 288-5823 or at

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Leave a Comment (18) ↓


  1. Michelle Morrison November 1, 2011

    I have a question. Where can we dispose of used syringes that do not have any attached sharps device? These may have been used to draw up a medication, etc. The reason we may have syringes without needles or other sharps is because we may have used a needle to draw up a med and then switched to a reusable cannula (which gets removed after use and reprocessed).

    • Mary Pat Whaley November 1, 2011

      Hi Michelle,

      Here’s the answer from our resident Lab Goddess, Libby Knollmeyer:
      If the syringes were not used to collect blood or body fluids and they have no needle attached, they can go in regular garbage. If they have a needle attached, they must go in a sharps container. If they were used to collect blood or body fluids, they must go in a red bag, but not necessarily a regulated medical waste box (depending on the municipal regulations about accepting red bags at the land fill—some do and some do not). It would never qualify as regulated medical waste, but if the landfill won’t allow biohazard bags, then the regulated medical waste box disposal is the only option. Hope this info helps.

      Best wishes,

      Mary Pat & Libby

  2. April January 22, 2013

    Quick question. Can the small biohazard bags if empty be discarded in the regular trash or does state laws say it wud need to go in a larger biohazard red bag.

    • Mary Pat Whaley January 23, 2013

      Hi April,

      Yes, waste that is appropriate to be discarded in a small biohazard bag must ultimately be destroyed by a waste company that provides written/digital proof that the waste was handled/destroyed as per state law. Usually small red biohazard bags are loaded into boxes lined by larger red bags, which are then sealed and picked up by special waste management companies.

      Best wishes,

      Mary Pat

  3. Kristy February 26, 2013

    If we are a medical device company receiving returned goods, is there a way to detect if the device is biohazardous or not?

    • Mary Pat Whaley February 26, 2013

      Hi Kristy,

      I do not know the answer to your question and have no idea who to ask this question of.

      Does any reader have any ideas?

      Mary Pat

  4. Kristy February 28, 2013

    Thanks for your response Mary Pat. I can post if I find an answer.

    • Mary Pat Whaley March 3, 2013

      Thanks, Kristy!


  5. Cathy March 19, 2013

    Are used plastic speculums considered to be medical waste?

    • Mary Pat Whaley March 20, 2013

      Hi Cathy,

      It depends on your state. Refer to your state regulations for their definition of medical waste. For instance, in North Carolina regulated medical waste is defined in general as “blood and body fluids in individual containers in volumes greater than 20 ml, microbiological waste, and pathological waste that have not been treated pursuant to specific standards.” There should be a contact in your state that can answer specific questions.

      Best wishes,

      Mary Pat

  6. Nguyen March 21, 2013

    Are the empty bottles containing antibiotics, vaccines, steroids required to be disposed of in the red biohazard containers or sharps containers? An office coworker has a habit of throwing those in the sharps containers and the waste company says it has to charge our office more for doing that. Would it make a difference if we disposed of them in the red biohazard boxes? I’m assuming you can’t throw those away in the regular trash. We’re in Texas.

    • Mary Pat Whaley March 22, 2013

      Hi Nguyen,

      This is becoming a very hot topic lately. There is some packaging, particularly packaging for “patches,” where the drugs may leach into the packaging and it will need to be destroyed by incineration. However, most standard medication packaging does not need to be destroyed or discarded via the sharps container.

      I reviewed the Texas law on medical waste and it was not clear to me what their view is on discarding medication packaging, so I suggest you contact the Texas Commission on Environmental Quality, which gives this email address for questions or comments:

      Best wishes,

      Mary Pat

  7. Katie August 22, 2013

    Hello! I was wondering about the disposal of used JP Drains in Georgia? Thank you!

    • Mary Pat Whaley August 26, 2013

      Hi Katie,

      I do not know the answer to this question, but maybe someone reading this will know. Anyone?


      Mary Pat

  8. Helen August 28, 2013

    We currently label several of our regular trash cans in our office as “Biohazard.” These are emptied in to the regular trash. Is that legal?

    • Mary Pat Whaley August 30, 2013

      Hi Helen,

      The question is whether or not those regular trash cans have regular trash in them.

      If there is non-biohazardous waste in those regular trash cans labeled “Biohazard”, then this is not a problem.

      If, however, you are putting biohazardous waste in regular trash cans, then emptying them into the regular trash, this is not appropriate. I would check on the laws in your state and see what the requirements are for disposing of biohazardous waste.

      Best wishes,

      Mary Pat

  9. Jane September 6, 2013

    Hello, I have a question. If a Dr. is Improperly discarding bio hazard waste such as a patients bloody gauze, in a regular waste basket, to then be thrown outside in a larger industrial dumpster that multiple companies share. IS that breaking the law? and would he be held liable if someone were to see that, or would the person taking the trash out be held liable??

    • Mary Pat Whaley September 10, 2013

      Hi Jane,

      This very much depends on the laws of your state. You will need to check with your state to see if what the doctor is discarding falls under your state’s description of regulated medical waste or biohazardous waste. Fines and sanctions will be applied to the business that is breaking the law, not to the employees of the business.

      Best wishes,

      Mary Pat