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Generator Storage Requirements for Regulated Medical Waste

Prior to disposal, all regulated medical waste (RMW) must be treated at a permitted RMW treatment facility (e.g. autoclave, incinerator). Facilities that generate RMW but do not treat RMW on-site, nor transfer and consolidate RMW from other sites, are not required to obtain an RMW permit from DEQ as long as RMW is stored in accordance with the applicable storage requirements of the Virginia RMW Management Regulations as summarized below.


Facilities that Generate Less than 100 Gallons of RMW per Week

  •  RMW should be properly packaged, labeled and sealed such that no waste materials can leak.
  •  Appropriate personal protective equipment (PPE) must be worn when packaging RMW.
  •  No more than 200 gallons total of RMW may be held on-site at any one time.
  •  All RMW should be held in a safe and secure manner ensuring that waste cannot spill, or contact workers or the general public.
  •  No more than 25% of the RMW can be generated from off-site.
  •  RMW may not be treated on-site.
  •  Records of RMW disposal are recommended (but not required) to be maintained.
  •  The generator must comply with the requirements for temporary storage of RMW on loading docks or in loading areas (see section below).

Facilities that Generate 100 Gallons or More of RMW per Week

  •  RMW should be properly packaged, labeled and sealed such that no waste materials can leak.
  •  RMW should be stored in a designated storage area, on floors or surfaces that are clean and impermeable to liquids (i.e. no carpets, cracks or gaps).
  •  RMW storage areas should have access controls, such as locked doors, to limit access only to individuals specifically designated to manage RMW.
  •  RMW may only be stored up to 7 days without refrigeration, and up to a maximum of 15 days. The storage start date should be indicated on the RMW outer packaging.
  •  Floor drains in RMW storage areas must discharge directly to the sanitary sewer, and ventilation should discharge to minimize human exposure to the effluent.  RMW should be stored under cover and protected from the elements, and over a floor or bermed pavement that will contain leaks and spills.
  •  Reusable RMW containers, if used, should be cleaned with detergent or general purpose disinfectant after each use.
  •  Appropriate PPE must be worn when handling containers of RMW.
  •  No more than 25% of the RMW can be generated from off-site.
  •  RMW may not be treated on-site.
  •  Records should be maintained of all RMW received from off-site, the generator, amount and its storage and receipt dates. Other required records include a contact list for the infection control committee members, an RMW spill log, facility RMW policies and procedures, and an RMW training log. Records should be maintained for at least three years.
  •  The generator must comply with the requirements for temporary storage of RMW on loading docks or in loading areas (see section below).

Temporary Storage of RMW on Loading Docks or in Loading Areas

  •  RMW must be packaged, marked, and labeled for transport per US DOT requirements.
  •  RMW may not be held for more than 24 hours on the loading dock or in the loading area.
  •  No more than 25% of the RMW can be generated from off-site.
  •  RMW storage areas must be secure from unauthorized access (locked, gated, etc.).
  •  RMW packaging must be protected from damage and the elements.
  •  Appropriate PPE must be worn when loading RMW into vehicles for transportation.

Storage at Permitted RMW Transfer Stations and Treatment Facilities

Permitted RMW Transfer Stations and Treatment Facilities should store RMW in accordance with the requirements specified by the facility’s permit. Storage requirements for permitted RMW facilities are at least as stringent, or more stringent, as the requirements for facilities that generate 100 gallons or more of RMW per week.

More information about the management requirements for RMW can be found here.

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Virginia Department of
Environmental Quality
P.O. Box 1105
Richmond, VA 23218
(804) 698-4000


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