Small practice. Same rules.
Utah practices where waste is a background task, not somebody's job title.
- Primary care and family practice
- Urgent care and walk-in clinics
- Specialty practices: dermatology, podiatry, OB-GYN, cardiology
- Occupational health and employer clinics
Handling & compliance details
Your invoice will tell you what your provider will not.
Four things to do with the invoice already on your desk. You do not need us to do any of them.
Find the term and the notice period
Both usually live on the agreement rather than the invoice. Write down the end date and how many days of written notice a cancellation needs. Do this first, because it sets how much time every other answer is worth.
Separate service lines from everything else
List every line that is not a pickup: fuel, environmental, energy, administrative, anything with the word recovery in it. Add them up and take them as a share of the total. That share is the part of your bill that is not service.
Count the stops you actually got
Compare the number of visits billed against the number your staff can remember. A stop that did not happen is still a line on the invoice, and nobody at your practice is auditing it.
Count the rooms against the containers
Count the rooms that genuinely generate sharps. OSHA requires a sharps container as close as feasible to the immediate area where sharps are used, so a room short is a compliance problem and a room over is a billing one.
Six records. None of them are ours to keep.
This is the paperwork half of the job, and it is the half a hauler cannot do for you.
| Record | What it is | How often or how long | Rule | Source |
|---|---|---|---|---|
| Exposure Control Plan | A written plan for how the practice protects employees from bloodborne pathogens | Reviewed and updated at least annually | 29 CFR 1910.1030 | 29 CFR 1910.1030 |
| Bloodborne pathogens training | Training for every employee with occupational exposure | Annually | 29 CFR 1910.1030 | 29 CFR 1910.1030 |
| Hepatitis B vaccination offer | The vaccination offered at no cost to employees with occupational exposure | Within 10 working days of initial assignment | 29 CFR 1910.1030 | 29 CFR 1910.1030 |
| Sharps injury log | A log of injuries from contaminated sharps | Required of employers who must maintain OSHA injury and illness records | 29 CFR 1910.1030 | 29 CFR 1910.1030 |
| Training records | The record that the training happened | Kept 3 years | OSHA recordkeeping | OSHA recordkeeping |
| Employee medical records | Records for employees with occupational exposure | Duration of employment plus 30 years | OSHA recordkeeping | OSHA recordkeeping |
This table lists what the rule asks of the employer. It is a starting point for a conversation with whoever handles compliance at your practice, not a determination about it.
Three of these are compliance. One is just money.
All four show up in small offices far more than in large ones, mostly because nobody owns waste as a job.
Treating the Exposure Control Plan as a document you write once.
OSHAOSHA's Bloodborne Pathogens Standard requires the written Exposure Control Plan to be reviewed and updated at least annually, so a plan written at opening and never touched is not a current plan.
Do this insteadPut the plan review on the same annual calendar entry as the training.
29 CFR 1910.1030Assuming "small quantity generator" means the same thing everywhere it appears.
EPASmall quantity generator is a RCRA hazardous-waste category set by how many kilograms of hazardous waste a site generates per month, and it is a different thing from a state medical-waste small-generator category. Practices routinely apply one rule to the other.
Do this insteadAsk which category is being claimed and under which rule, before you rely on it for anything.
RCRA generator categoriesRed-bagging ordinary exam-room trash because the red bin is closer.
CostOrdinary clinic trash, meaning paper, packaging and uncontaminated gloves and wrappers, is not regulated medical waste. Red-bag volume is driven by what staff put in the bag rather than by patient volume, and regulated medical waste costs more per pound to transport and treat.
Do this insteadPair every red-bag container with an ordinary waste bin at the same height and the same distance.
Assuming the privacy question and the waste question have one answer.
HIPAA governs protected health information, not waste as a category. A patient name printed on a label or a package is a privacy question with its own answer, separate from whether the contents are regulated medical waste.
Do this insteadDecide the waste question and the privacy question separately, then route each one to the stream that answers it.
Switching
Send us your current invoice
It is the fastest way to find out whether you are being charged for service you do not receive.
We will read it, tell you what is actually on it, and quote against what your practice really generates. If your current provider is cheaper, we will say so. See Why Shred Med for what changes and Compliance for where the responsibilities sit.

Ready for a cleaner, easier solution?
Send us what you generate in a normal week and we will quote it straight.

