Medical Waste and Requirements For Consideration

Did you know healthcare facilities must train all associates who prepare regulated medical waste for transport and/or sign manifest/shipping papers when that waste is picked up?

The Pipeline and Hazardous Materials Safety Administration (PHMSA), a division of the U.S. Department of Transportation, revised the Hazardous Materials Regulations (HMR) to conform with the amendments made to the Federal Hazardous Materials Transportation Law – which requires DOT to regulate the training of all employees who handle hazardous materials (“hazmat”). This includes medical waste.

Ultimately, the training is designed to increase a hazmat employee’s safety awareness and aims to reduce potential hazmat incidents.


A “hazmat employee” refers to someone employed by a hazmat employer who directly impacts hazmat transportation safety, or a motor vehicle operator who transports hazmat (including a self-employed person), which includes items like medical waste, who:

  • loads, unloads, or handles hazmat
  • tests, reconditions, repairs, modifies, marks, or otherwise represents packagings qualified for use in the transportation of hazmat
  • prepares hazmat for transportation
  • is responsible for safety of transporting hazmat, or
  • operates a vehicle used to transport hazmat

A “hazmat employer” refers to someone who has one or more of its employees doing any of:

  • transporting hazmat in commerce (such as medical waste)
  • causing hazmat to be transported or shipped in commerce, or
  • representing, marking, certifying, selling, offering, reconditioning, testing, repairing, or modifying packagings as qualified for use in the transportation of hazmat (Generator Certification)

Training and the Hazmat Law

The Federal Hazardous Materials Transportation Law is the basic statute regulating the transportation of hazardous materials (hazmat) in the country, which requires the training of all hazmat employees. The HMR include training requirements in several sections of Title 49 Code of Federal Regulations (CFR), including the following:

Each hazmat employer must train and test, certify, and develop and retain records of current training and preceding three years training for each hazmat employee during the period of employment and 90 days thereafter.

Hazmat training must include:

  • general awareness/familiarization
  • function-specific training
  • safety
  • security awareness
  • in-depth security training (if a security plan is required), and
  • driver training for hazmat employee operating a motor vehicle

All training must address components specified in 172.704(a) of the HMR to be considered applicable.

Additionally, the DOT provides guidelines of initial training versus ongoing, recurrent training:

Initially, a new employee (or one who changes job) may perform hazmat job functions before completing training as long as they either complete training within 90 days of employment (or job change), or the employee is under the direct supervision of a properly-trained and knowledgeable hazmat employee.

Ongoing, employees are required to take recurrent training at least once every three years, with the three year period beginning on the actual date of the first training.

Finally, any training record must include the following information:

  • hazmat employee’s name
  • completion date of most recent training
  • training materials (copy, description, or location)
  • name and address of hazmat trainer, and
  • certification that the hazmat employee has been trained and tested

When considering a medical waste disposal partner, ensure they can not only provide you with medical waste disposal services, sharps containers, and other materials, but that they are also familiar with this federal law and can assist you with training resources are needed.



  • Code of Federal Regulations Title 49, Subpart H, §172.700-172.704 (Formerly Docket HM-126F)
  • Federal Hazardous Materials Transportation Law: 49 U.S.C. § 5101 et seq.
  • The HMR include training requirements in several sections of Title 49 Code of Federal Regulations (CFR) as follows: GENERAL § 173.1, SPECIFIC § 172.704, and MODAL: Air § 175.20, Vessel § 176.13, Highway §§ 177.800, 177.816.