Federal Issue Brief

 H.R. 2546, Medical Waste Management Act

AVMA Position:

Nonsupport 

Summary:

Introduced by Congressman Frank Pallone (NJ-6th), H.R. 2546 would amend the Solid Waste Disposal Act to require the Administrator of the Environmental Protection Agency to promulgate regulations on the management of medical waste.

Background:

  • The regulation of medical waste is governed at the federal level by the Solid Waste Disposal Act, which was amended by and may be better known as the Resource Conservation and Recovery Act (RCRA). 
  • The Solid Waste Disposal Act is mainly implemented by the EPA, which can delegate authority to appropriate State agencies, and the Act’s associated codified regulations are contained in Title 40 of the Code of Federal Regulations (CFR) Parts 239 through 299. State authorities oversee the majority of the medical waste disposal regulations. 
  • State specific regulatory information is available here.
  • Relative to veterinary medicine, animal carcasses, body parts, tissues, fluids, excreta, and other wastes are generally not considered regulated medical waste unless they are derived from animals inoculated during research, production of biologicals, or pharmaceutical testing with agents infectious to humans, or are from animals suspected or known to have an infectious agent zoonotic to humans.

Justification:

  • The AVMA encourages the use of sound science to characterize veterinary medical waste hazards, associated risks, and define methods to minimize those risks. 
  • The AVMA encourages authorities addressing veterinary medical waste issues to use reasonable approaches in the formulation of regulations and to consider risk/benefit analyses relative to the health and welfare of patients, public health, the environment, and potential impacts on the veterinary profession, especially considering that many types of veterinary medical wastes pose no to negligible risk to humans or other animals.
  • Several aspects of the bill usurp current rights and authorities of the States to manage medical wastes and would disrupt current medical waste disposal programs. 
  • Because the language of the bill expands what is considered regulated medical waste and requires additional recordkeeping, registrations, inspections, and trainings, the bill will increase regulatory, administrative, and economic burdens on veterinary practices, many of which are small businesses that already meet or exceed medical waste disposal requirements.

Current Status:

House Committee on Energy and Commerce, Subcommittee on Environment and the Economy.

AVMA Contact: 

Dr. Whitney Miller, Assistant Director, Governmental Relations Division, 202-289-3211.