By Lauren Johnson
In 2024, the Alabama Department of Environmental Management (ADEM) brought together a group of associations and companies to work together to propose updates to the medical waste regulations. As a result, ADEM revised multiple chapters of the Medical Waste Program, which could result in costly fines if medical practices are unaware of the changes. Regulation updates were implemented in two phases – Phase One, effective February 14, 2025, and Phase Two, effective August 14, 2025.
The updated regulations involve a range of topics including documentation requirements, the transport window for medical waste, how waste must be packaged and stored, new guidelines for smaller practices and more, all for the purpose of clarifying definitions, correcting federal references and strengthening expectations. These rules apply specifically to regulated medical waste (RMW) – materials that pose infectious or hazardous risk, including sharps, blood-saturated materials, pathological waste and microbiological cultures.
“I think the regulations came out really well, especially considering how difficult it can be to get regulatory changes passed,” said Kevin Webber, president of TriHaz Solutions, a medical waste disposal company that was the only treatment facility involved in the undertaking. Through this process, he had the opportunity to explain to hospital associations and others the impact certain regulation changes would have on their practice.
Several of the changes center around documentation. First, practices are required to maintain dated training records for an employee, which must be kept for current personnel until the facility closes.
“Pre-2025, it said that practices had to train their employees, but it was vague language with no retention period,” Webber said. “Now, it specifies that you have to keep your records. You have to have written documentation that the employee was actually trained versus someone just saying that person was trained.”
Second, the updates require medical waste treatment facilities to provide certificates of destruction for every disposal event. Generators – the facilities generating medical waste including physician practices, clinics, surgery centers, labs, etc. – must keep those certificates for audit purposes.
Generator facilities must also continue to register with ADEM. Registration has always been a requirement, but the process has been more clearly defined so generators should check their status with ADEM.
And the transportation window for medical waste was revised to 14 days. “Before this, it had to be transported within four hours of pickup, and if it was longer than four hours, it had to be refrigerated,” Webber said. “That, obviously, was not realistic. That’s not standard practice in any state that we operate in or any states that I’m aware of.”
Now, the extended 14-day timeframe provides a manageable window. If there is going to be any exception to this timeframe, a documented notification must be sent to ADEM. The waste must reach a treatment facility within 14 days of pickup, and the waste must be processed by the treatment facility within 30 days.
“Treatment used to be within 24 hours. In our facility, waste that comes in on a Monday is treated on Tuesday, so we still go with the 24 hours,” Webber said.
Prior to the 2025 updates, small generators (smaller practices generating under 220 pounds of medical waste per month) had no storage condition requirements at all.
“Now small generators have a six-month period to store it. Then it has to be picked up,” Webber said. “They’re now required to ensure waste remains in a non-putrescent state throughout that six-month period, which essentially means that it’s not decomposing and smelling.”
ADEM’s penalties for failing to follow these regulations are severe, starting at $25,000 per day per violation for the first offense. Repeat violations escalate to $50,000 per day. This does not include any potential federal EPA enforcement.
In 2024, a regional hospital in Minnesota was fined $100,000 for improperly disposing of infectious waste. This hospital was also required to review and make major changes to their waste management plan.
“Generators are now held to stricter regulations. They also tightened up the regulations around treatment facilities,” Webber said. “There’s a more detailed, formal process for getting permitted for those facilities (TriHaz is one of three commercial steam-sterilization treatment facilities in Alabama), similar to how solid waste landfills get permitted. There’s a public comment period and there are public notices, which are good things.”
Webber encourages practices to review and update their medical waste management plan, verify that their waste vendor holds a current ADEM transporter permit, make sure their pickup schedule aligns with the 14-day transport window and keep certificates of destruction and training records.
While ADEM manages state regulations for medical waste, the EPA manages federal regulations for hazardous waste. The EPA is in the process of implementing additional requirements on top of state rules, which will reach most jurisdictions by late 2026.
Medical waste includes different types of biological waste – blood, tissues or microbiological cultures – while hazardous waste includes chemicals, toxic material, or radioactive material. Some medical facilities create hazardous waste in addition to medical waste.
“Hazardous waste is something that’s flammable or something like mercury, and it’s treated in a separate way from how medical waste is treated,” Webber said. “Certain pharmaceutical waste streams are hazardous. Chemotherapy drugs in bulk are hazardous because it’s a toxin, and there’s others that are considered hazardous. TriHaz is permitted to pick up hazardous waste too, but the treatment is different. It goes to a different facility once we pick it up and organize it.”
The EPA will soon require a transition from paper-based documentation to electronic reporting for hazardous waste, improving accuracy and tracking through an online platform. This e-manifest will only apply to hazardous waste.
“Alabama facilities still catching up to the 2025 ADEM changes will face a steeper climb when federal electronic reporting requirements follow,” Webber said.