What is Viral Hemorrhagic Fever?
Viral hemorrhagic fever (VHF) is a severe illness that can be caused by a number of viruses that are generally spread through direct contact with body fluids of a person who is very ill with a VHF disease (i.e., Ebola, Lassa, Marburg, etc.), or with objects contaminated with blood or body fluids of an infected individual. Mortality rates associated with VHF diseases can be quite high and there may be no known antiviral treatments available for human infections with these viruses.
What Infection Control Precautions Should be Followed?
Healthcare facilities delivering VHF patient care and those engaged in the handling of the associated Other Infectious Waste that will be generated should follow both the Centers for Disease Control (CDC) Ebola Virus Disease (EVD) guidance entitled: “EVD Infection Control Guidance” (link leaves DEC’s website) and the New York State Department of Health (NYSDOH) “Ebola Virus Disease (EVD) Update #2” (link leaves DEC’s website) found under “Health Care Worker Exposures”.
Is VHF-related Waste a Concern?
Yes. In New York State, the waste resulting from the treatment of VHF patients or VHF contaminated materials are considered Regulated Medical Waste (RMW) or Other Infectious Waste (i.e., incidental waste that is not RMW but has come into contact with an infectious agent). The amount of waste generated from the treatment of an VHF patient can be considerable due to associated disposable items and personal protective equipment that must be worn.
Anyone who generates RMW or Other Infectious Waste suspected of being contaminated with VHF materials (such as hospitals, funeral establishments, bio-response and hazardous materials cleanup businesses etc.) must notify the Department of the names of each permitted RMW transporter that will be used to transport the waste.
How is the Waste Managed?
There are both State and federal requirements that apply to the transport, treatment, and disposal of RMW and Other Infectious Waste. The RMW generated from VHF patient care, and Other Infectious Waste generated from residences or common spaces visited by the patient must be treated before it can be disposed. The treatment can occur either at the healthcare facility where it is generated or at a treatment facility located at another location, such as a permitted commercial treatment facility that accepts RMW.
How is the Waste Treated?
Treatment of the RMW at the healthcare facility must be done in accordance with NYSDOH standards for operation and treatment. The treated RMW can then be disposed at a New York State Department of Environmental Conservation (NYSDEC) approved facility as a solid waste. The treated RMW must be accompanied by a certificate of treatment form, all sharps must be destroyed as well as treated, and the disposal facility must be approved by NYSDEC for this type of waste. Treatment of the RMW and Other Infectious Waste at a commercial facility(e.g., by incineration, autoclaving or chemical decontamination), rather than at a healthcare facility authorized under NYSDOH regulations, requires a permit from NYSDEC under 6 NYCRR Part 365 “Regulated Medical Waste and Other Infectious Wastes” (Part 365). Part 365 sets forth detailed requirements concerning the handling and treatment of RMW and Other Infectious Wastes. Similar to RMW, treated at a healthcare facility, the RMW or Other Infectious Waste that has been treated at a Part 365 permitted commercial facility can be disposed at a NYSDEC approved facility as a solid waste, in accordance with the criteria outlined above.
What About Liquids that May be Generated During Treatment?
Current CDC guidance states that sanitary sewers may be used for the safe disposal of liquid wastes from patients. NYSDOH and NYSDEC regulations allow facilities to discharge liquid or semi-liquid waste containing pathogens directly into a sanitary sewer, unless specifically prohibited by local law or ordinance. Complex aqueous matrices, such as contaminated VHF wastewater may have significant oxidant demand requiring additional chemical disinfectant. Disposal of aqueous waste, even if chemically treated, via discharge to a sanitary sewer, may require consultation with the respective authorities. Additional information can be found on the NYSDOH website under Waste Management (link leaves DEC’s website).
How is the Waste Transported?
Materials suspected of being contaminated with Viral Hemorrhagic Fever Diseases (VHF) must be transported by a permitted regulated medical waste (RMW) transporter that is authorized by the Department to transport VHF contaminated waste.
The transport of both treated and untreated RMW and Other Infectious Waste requires authorization under 6 NYCRR Part 364 Waste Transporters (Part 364). A transporter that will be transporting treated RMW and Other Infectious Waste from either a healthcare facility or a permitted commercial RMW treatment facility requires a Part 364 Waste Transporter permit to transport non-hazardous industrial-commercial waste. A transporter that will be transporting untreated RMW or Other Infectious Waste associated with the treatment, assessment and cleanup activities of an VHF patient is subject to both United States Department of Transportation (USDOT) regulations and NYSDEC regulations. IMPORTANT: All VHF waste must be directly transported to the treatment or disposal facility with no transfer or storage allowed.
Note: Transportation of VHF contaminated wastes from the site of generation to an out-of-state disposal facility may require public notification and approval by those states for the transport and disposal phases. Agreements must be reached between the waste transporter and the treatment and disposal facilities before the waste is transported.
USDOT regulates how the waste must be packaged and otherwise managed during transport – See USDOT Guidance for Transporting Ebola Contaminated Items, a Category A Infectious Substance (link leaves DEC’s website).
In addition to USDOT criteria, NYSDEC requires transporters that will be transporting untreated RMW and Other Infectious Waste associated with the treatment of VHF to obtain authorization to transport RMW under a Part 364 Waste Transporter permit with a special VHF certification. Current Part 364 transporters, including those currently approved to handle RMW, must modify their permits to transport RMW from VHF treatment to obtain the special VHF certification.
In order for a permitted RMW transporter to obtain authorization from the Department to transport VHF contaminated waste, the transporter must provide evidence that they have USDOT special permit or Party Status to DOT special permit as may be required for packaging and transporting VHF waste and must complete and submit to NYSDEC a Certification for Transport of VHF Waste Form (PDF) (28 KB) and a completed medical waste tracking form (PDF) (94 KB) for each shipment of waste.