Opening a Medical Practice: The Medical Waste Setup Checklist for Day One

MedPro Disposal lays out the five steps a new practice should finish before the first patient: state rules, containers, hauler contract, OSHA training and records. It covers federal rules only, so check your state's rules too.

MedPro Disposal recommends that a new medical practice work through five steps before the first patient: confirm your state's medical waste rules and any registration, set up containers, sign a hauler contract, complete OSHA Bloodborne Pathogens training and your written plan, and start your records on day one. Most of this takes weeks, so begin while the space is still being built out.

This checklist is for offices at the moment they need a hauler. It covers federal rules only. Medical waste rules vary by state, so your state's own rules apply. Find your state on our locations page.

Key Takeaways

• MedPro Disposal (founded in 2009, based in Naperville, Illinois) serves 40,000+ providers and works through partner haulers outside the Chicago area.
• Medical waste is mainly regulated by states, so confirm registration or notification rules with your state agency before you open.
• OSHA's Bloodborne Pathogens standard (29 CFR 1910.1030) requires a written Exposure Control Plan and staff training, and the plan must be reviewed at least annually.
• Controlled substances and hazardous pharmaceuticals do not belong in your regulated medical waste containers.
• Sign the hauler contract before you stock exam rooms, so containers and the first pickup are ready on opening day.

Step 1: What do I need to confirm with my state before opening?

MedPro Disposal tells new practices to start with their state, because medical waste is regulated mainly at the state level. The federal Medical Waste Tracking Act program ran from 1989 to 1991 and expired, according to EPA records, so there is no single federal medical waste permit.

Each state has its own name for the waste, its own regulator, and its own rules on registration, notification, storage time and treatment. Some also add county or city rules. The state's own rules apply, not the ones in this article.

1. 1Find the state agency that regulates medical waste (usually the health or environmental department).
2. 2Ask whether a generator registration, notification or permit is required for a practice of your size and type.
3. 3Ask how long waste can be stored on site and what the storage area must look like.
4. 4Check county, city and sewer authority rules too.
5. 5Write down the agency contact, the rule you relied on and the date you checked.

Our locations pages link to state-level guidance, and the state-by-state checklist gives a broader view.

Step 2: Which waste streams and containers does a new practice need?

A new practice needs a separate container plan for each waste stream it will produce: sharps, regulated medical waste, pharmaceuticals and general trash. List the streams by specialty and by procedure before you order anything.

OSHA's standard describes sharps containers as closable, puncture resistant, leakproof and labeled or color-coded. Place them close to where sharps are used. For regulated waste, OSHA requires closable, leakproof containers that are labeled or color-coded.

MedPro Disposal does not sell sharps containers. Buy containers from a medical supplier, then confirm with your hauler which container types and sizes it accepts. Under DOT rules, regulated medical waste must travel in rigid packagings that meet the UN standard (49 CFR 173.197), and your hauler handles that packaging. Our sharps container disposal guide covers what happens when containers are full. Very low-volume practices can read about mail-back options for small practices.

Two pharmaceutical rules apply from day one. EPA bans sewering hazardous waste pharmaceuticals for all healthcare facilities, including the smallest generators (40 CFR 266.505). DEA requires practices that hold controlled substances to destroy them on site by approved methods or send them to a reverse distributor (21 CFR 1317.05). Neither stream goes into a red bag.

Step 3: What should a medical waste hauler contract cover?

At MedPro Disposal, we tell new practices that a hauler contract should name what is collected, how often, and who is responsible at each point from pickup to treatment. Read it before you sign, not after the first pickup.

• Scope: which waste streams are covered (sharps, regulated medical waste, pharmaceutical) and which are not.
• Pickup schedule: frequency, and how to request extra pickups.
• Containers: which types and sizes the hauler accepts, and whether any are supplied.
• Tracking paperwork: the documents you receive at each pickup and how long the hauler keeps copies.
• Responsibility: who holds title to the waste after pickup. MedPro takes legal title to regulated medical waste at pickup (not hazardous waste).
• Insurance: the coverage the hauler carries. MedPro carries $33M in combined general liability, umbrella and pollution insurance.
• Term and exit: how long the agreement runs and how to end or change it.

For comparison questions, use our vendor checklist and the seven questions to ask before hiring. For budgeting, see the cost guide. MedPro customers save 30% on average. Outside the Chicago area, MedPro works through partner haulers.

Step 4: What OSHA training and written plan are required before the first patient?

MedPro Disposal reminds new practices that OSHA's Bloodborne Pathogens standard (29 CFR 1910.1030) requires a written Exposure Control Plan for any employer with staff who may be exposed to blood or other potentially infectious material. The plan must be reviewed and updated at least annually, and when tasks, procedures or positions change.

The same standard requires training at no cost to the employee. Training must be given at the time of initial assignment and then annually, within one year of the last session. It must cover the elements OSHA lists, including an accessible copy of the standard, how bloodborne diseases spread, and how to report an exposure. Hepatitis B vaccination must be made available within 10 days of hire.

1. 1Write the Exposure Control Plan for your own tasks and job titles.
2. 2Choose safer devices where they exist, and document that choice. OSHA expects the annual review to show you considered safer medical devices.
3. 3Offer hepatitis B vaccination to exposed staff.
4. 4Train every exposed employee before they handle sharps or waste.
5. 5Post the post-exposure steps where staff can find them.

Once you are open, the self-audit checklist is the tool for later reviews of a running program.

Step 5: What medical waste records should I start on day one?

A new practice should start four sets of records on day one: hauler paperwork, training records, medical records for exposed staff, and a log of your own checks. Starting early is easier than rebuilding them later.

• Hauler paperwork: your contract, every pickup document, and any treatment or disposal confirmation your hauler provides.
• Training records: OSHA requires these to be kept for 3 years from the training date.
• Medical records for exposed employees: OSHA requires these to be kept for the duration of employment plus 30 years.
• State records: any registration, notification or other record your state requires. Keep the length of time your state sets.
• Internal log: container changes, incidents and the date the Exposure Control Plan was last reviewed.

Our documentation guide goes deeper on the records. For a plain overview of what small practices must do, see medical waste disposal for small clinics.

Sources

• OSHA, 29 CFR 1910.1030 Bloodborne pathogens (checked 2026-11-15)
• OSHA, Bloodborne Pathogens enforcement (checked 2026-11-15)
• eCFR, 49 CFR 173.197 Regulated medical waste (checked 2026-11-15)
• eCFR, 40 CFR 266.505 Prohibition on sewering hazardous waste pharmaceuticals (checked 2026-11-15)
• eCFR, 21 CFR 1317.05 Registrant disposal (checked 2026-11-15)
• EPA RCRA Online, Medical Waste Tracking Act status (checked 2026-11-15)