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Home > Laws and Legislation > Regulatory Issues > Potentially Infectious Medical Waste Disposal > Special Requirements for Small Generators of PIMW

Special Requirements for Small Generators of Potential Infectious Medical Waste (PIMW)

In order to improve the management of medical waste, the Illinois Environmental Protection Act was amended by adding Title XV (Public Act 87-752, House Bill 2491). This Title establishes statutory and regulatory requirements to ensure that Potentially Infectious Medical Waste (“PIMW”) will be handled in a safe and responsible manner. PIMW has replaced the term Hazardous (Infectious) Hospital Waste in the Illinois Environmental Protection Act and related regulations when describing medical waste.

What is Potentially Infectious Medical Waste?

Potentially Infectious Medical Waste (“PIMW”) has replaced the term Hazardous (Infectious) Hospital Waste in the Illinois Environmental Protection Act and related regulations when describing medical waste.

PIMW is a “Special Waste” generated in connection with:

1. The diagnosis, treatment (i.e., provision of medical services), immunization of human beings or animals;
2. research pertaining to the provision of medical services; or
3. the production or testing of biologicals.

Types of PIMW wastes are: (a) Cultures and stocks; (b) Human blood and blood products; (d) Used sharps; (e) Animal waste; (f) Isolation waste; or (g) Unused sharps.

PIMW does NOT include:

1. Waste generated as general household waste;
2. waste (except for sharps) for which the infectious potential has been eliminated by treatment, or
3. sharps which the infectious potential has been eliminated by treatment and rendered unrecognizable by treatment.

What is difference between small and large quantities?

Under the Title XV of the Act, Potentially Infectious Medical Waste (PIMW) are managed depending upon the amount produced and shipped off-site in any one month.

Less than 50 pounds per month: If you determine that your professional practice or facility produces and ships off-site for disposal less than 50 pounds of PIMW in any one month, your facility is a “small quantity generator”.

More than 50 pounds per month: If you are responsible for a hospital, professional practice, clinic, infirmary, laboratory, research facility, pharmaceutical business or other facility that produces and ships off-site for disposal more than 50 pounds of PIMW in any one month, your facility is a “large quantity generator”.

PIMW shall be segregated and packaged to protect workers, handlers, and the public from exposure to these materials.

Small quantity generators must:

1. Separate their PIMW from other types of wastes (i.e., general refuse, special wastes, hazardous wastes, and radioactive wastes) where practicable. For PIMW commingled with other waste types, the whole lot shall be managed in accordance with the regulations for each waste type.
2. Segregate and prepare PIMW for transport to a permitted facility. The PIMW should be sorted into 3 categories: (1) sharps; (2) oversized PIMW; and (3) all other. To insure that PIMW is packed securely and will not leak during transport, the containers should be:
1. Rigid;
2. leak-resistant;
3. impervious to moisture;
4. of a strength sufficient to prevent tearing or bursting; and
5. sealed to prevent leakage.

In addition to the above requirements for packaging, the sharps containers shall also be puncture-resistant.

Oversized PIMW does not need to be placed into containers, but shall be handled to reduce the potential for releasing agents into the environment and protecting public health.

How should PIMW be stored?

Prior to treatment, or disposal on-site, or transport off-site, PIMW should:

1. Be stored in a manner and location that maintains the integrity of the packaging and provides protection from water, rain, and wind;
2. be maintained in a nonputrescent state, using refrigeration when necessary;
3. be locked up if stored in outdoor storage areas, thereby preventing unauthorized access;
4. have limited access to authorized employees for on-site storage areas; and
5. be stored in a manner that affords protection from animals and does not provide a breeding place or a food source for insects and rodents.

Who can accept PIMW for transfer and who is exempt from the special requirements?

To accept PIMW for transfer, a person will be required to have a permit issued by the Agency that specifically authorizes the transfer of PIMW.

Effective January 1, 1992, a transfer station means a site or facility that accepts waste for temporary storage or consolidation and further transfer to a waste disposal, treatment or storage facility.

No transfer permit is required for:

1. PIMW generated by the person’s own activities that are transferred within the site where the PIMW is generated; and
2. PIMW generated by a hospital’s own activities or by members of its medical staff.

Therefore, a hospital can accept PIMW from members of its medical staff without a transfer permit.

Who can transport PIMW and what are the special requirements?

Small quantity generators may either: (1) use a permitted PIMW transporter; (2) use a transporter who transport less than 50 pounds per month generated at the same site; or (3) transport the waste themselves.

If a small quantity generator transports or offers for transport more than 50 pounds of PIMW in any one shipment, then this generator comes under the regulations for large quantity generators (see IEPA Fact Sheet for Special Requirements for Hospitals). No manifest, as well as the 1.5 cents transportation fee, is required for the transport of PIMW from generators who generate less than 50 pounds per month of such waste.

Who can accept PIMW for storage, treatment, or transfer?

Beginning July 1, 1991, only PIMW facilities issued permits by IEPA to treat, store, or transfer PIMW will be authorized to accept PIMW. Only PIMW that has been stored and packaged in accordance with this Act may be shipped to these facilities. A hospital can accept PIMW from members of its medical staff without a permit so long as it has been properly packaged.

Untreated medical waste cannot be disposed of into any landfill!

Under Section 56.1(a) of this legislation, PIMW is banned from all landfills. The only exception is sharps where the infectious nature has been removed and that are packaged in accordance to this legislation.

PIMW should be treated to eliminate the infectious nature in accordance with the Environmental Protection Act, Illinois Pollution Control Board criteria, and if appropriate, Agency permits. Treatments to render the PIMW non-infectious can include, but are not limited to, sterilization in an autoclave or ethylene oxide unit and incineration.

Once PIMW has been properly treated to eliminate its infectious potential, it is no longer PIMW (except in the case of sharps) and may be disposed of into any landfill permitted by the IEPA to accept municipal waste. For sharps, both the infectious nature must be eliminated and the sharps must either be rendered unrecognizable or packaged in accordance with the Act prior to disposal. If the small quantity generator treats the PIMW on-site, then the generator should make arrangements with its transporter and the landfill to accept the treated and properly packaged medical waste (i.e., provide documentation with the shipment to insure that the medical waste has been treated and packaged in accordance with this Act).

What records and reports does the small quantity generator need to complete for PIMW?

Small quantity generators are exempt from retaining manifest forms on their PIMW and filing PIMW annual reports with the Agency.

PIMW treated by Incineration

Waste incinerators shall be permitted by the Division of Air Pollution. If the incinerator owner/operator accepts any waste from a person or facility not owned, controlled, or operated by the incinerator’s owner/operator, then permits from the Division of Land Pollution Control shall be required.

Ash resulting from the incineration of PIMW is categorized as an “industrial process waste” and shall be managed as special waste (i.e., a special waste manifest is required).

Beginning January 1, 1994, PIMW treatment operations at an incinerator must meet the emission standards established under Section 129 of the Clean Air Act (42 USC 7429), as amended.

PIMW treated by Autoclaving

Autoclaves will not require a permit from the Agency for the treatment of PIMW generated by its own activities or by members of its staff. If the facility accepts any waste from a person or facility not owned, controlled, or operated by the autoclave’s owner, then a permit from the Division of Land Pollution Control shall be required.