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How current is your practice on Michigan's medical waste requirements? Regulated medical waste and Sharps handling fall under strict oversight from the Michigan Medical Waste Regulatory Act and MIOSHA.
Four areas tend to trip up practices most often: exposure control planning, sharps container standards, injury logging, and staff training.
It's worth taking a fresh look at your procedures and making sure new staff are properly trained.
1. Exposure Control Plans (ECPs)
Under the OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030), enforced in Michigan through MIOSHA Part 554, every practice with employees who may contact blood or other potentially infectious materials must maintain a written Exposure Control Plan. The ECP must be reviewed and updated at least annually, and whenever new positions, procedures, or exposure risks are introduced. A stale ECP is one of the most common findings in MIOSHA inspections.
2. Sharps Container Placement
Sharps containers must be located as close as feasible to the immediate area where Sharps are used, not in a shared hallway or supply closet down the unit. This is one of the most common findings in MIOSHA inspections. Exam rooms, procedure areas, and treatment stations typically need their own container within easy reach of staff.
3. Sharps Injury Log
Practices with employees exposed to Sharps injuries must maintain a Sharps Injury Log documenting the device type and brand, department, and a description of each incident. This log must be kept confidential and retained for a minimum of five years, per OSHA recordkeeping requirements.
4. Employee Training Certificates
Employees with occupational exposure must receive bloodborne pathogens training at initial assignment, then annually thereafter. Training records and certificates should be retained and readily available for review.
Separately, staff who handle packaging or shipping of regulated medical waste are DOT hazmat employees under 49 CFR Part 172, Subpart H, and must complete DOT medical waste training every three years.
Source: Superior Medical Waste Disposal, one of TPA's Affiliate Partners, helps practices stay compliant. For questions on compliance or a complimentary compliance audit, email compliance@superiorwastedisposal.com. Call Gerald Belanger at (734) 656-8843 for more information on TPA special discounts.
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