Monday, September 21, 2009

Melissa Young, MD: A medical waste permit?

So as I said in my previous post, I probably know more about running a practice than most physicians I know. I have read books about starting a new business and starting a new practice. I read about personnel management, financial risk management and marketing. I learned about captives, the accrual method and HCPCS. I talked to physician friends. I read blogs. I asked questions on physician bulletin boards. I scoured the Web.

And yet, I still found surprises along the way. One week, I started asking fellow MDs who they used for medical waste pick-up. A couple of docs gave me the names of the companies they use. Two had me ask their office managers. But it was the administrative assistant of one of them who asked me if I had applied for my waste permit.

My what?!?!
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This wasn’t in the books! This wasn’t in the four dozen articles I had read. And no one else had mentioned this before. I figured she must be wrong. If I needed this permit, surely someone else would have mentioned this along the way. So I asked my doctor friends. None of them had any idea what I was talking about. They were going to “check with the office.” Turns out, yes, I do need a medical waste generator permit. And yes, I do need to pay the government for the privilege of generating said waste.

Just like I have to pay for the privilege to perform a waived test. I had always figured that when you say something is a CLIA waived test that you didn’t need to apply for anything. But, nooooo…You need to apply for a waiver. And they don’t even tell you ahead of time how much you have to pay. You need to tell them what test you plan to do and how often, then they tell you what the fee is. This is another tidbit of information I discovered on my own.

What other little surprises await? I guess we’ll find out.

Melissa G. Young, MD, FACE, FACP, is an endocrinologist in private practice, an assistant clinical professor at Robert Wood Johnson, and a working suburban mother of two in Freehold, N.J. She is a regular contributor to Practice Notes.


  1. Great question! Made me look up more info from AZ Dept. of Envir. Quality regarding hazardous waste permits. I have a company that picks up a half-sized barrel (size??) quarterly for a good rate. In FP, it is mostly filled sharps containers since I went back to metal, sterilizable vaginal specula... Those plastic specs took up a lot of room in the bin but that doesn't apply to you. We even accept patient's sharps for disposal and still are considered a CESQG "Conditionally Exempt Small Quantity Generator" and thus EXEMPT from needing a permit...B Garcia, PHX AZ

  2. I meant to say "I use a haz waste company that picks up for a good rate..."

  3. Disposable vaginal speculums are not considered hazardous waste and can go in the regular garbage. So can bandages that are not saturated with blood, gloves used for pelvic exams and rectals. Millions wasted filling red containers with non-hazardous waste!

  4. I foresee needing a pick up once or twice a year, primarily for sharps - syringes with needles, lancets, some bloodied gauze. In NJ, the lowest fee is for 80lb a year or less. I don't think there's an exemption.

  5. In Michigan, it has changed according to the political climate. A democratic governor started the requirement, a republican governor discontinued the need for a permit, and now we have a democratic governor who has reinstated the need for the permit. Medical waste is not allowed to be stored onsite for more than 90 days (this includes sharps containers) so we have to have a pick up every 90 days.