Wisconsin's infectious waste regulations
Managing healthcare waste from COVID-19
The U.S. Centers for Disease Control and Prevention is recommending routine management and disposal of healthcare waste from COVID-19 patients or persons under investigation. For more information on requirements and recommended practices for healthcare facilities, households and waste management professionals handling COVID-19-related waste, see the COVID-19 tabs on this page.
Infectious waste — also known as biohazardous, red bag or regulated medical waste — must be segregated from other waste types and disinfected before it is disposed of in a solid waste landfill. Businesses and institutions should review the information on this page. Households are only required to manage their sharps separately.
Infectious Waste Basics
The difference between infectious waste and medical waste
Basically, infectious waste is waste that can pass on infectious diseases to people or animals, such as sharps (including hypodermic needles, syringes and lancets), blood or human tissue. Medical waste is infectious waste plus any non-infectious waste that may be mixed with them.
- In s. 287.07(7)(c)1.c., Wis. Stats., Infectious waste means solid waste that contains pathogens with sufficient virulence and in sufficient quantity that exposure of a susceptible human or animal to the solid waste could cause the human or animal to contract an infectious disease.
- In s. 299.51(1)(b), Wis. Stats., Medical waste means infectious waste, as defined above, and other waste that contains or may be mixed with infectious waste.
Note that medical waste does not mean all of the waste produced in a healthcare setting. Non-infectious materials from a healthcare facility are considered to be "medical waste" only if the generator mixes them with infectious waste or manages them as though they are infectious waste. Any other waste materials from a healthcare facility are not considered "medical waste" under Wisconsin law. If possible, these non-infectious items should be reused or recycled.
Items considered to be infectious waste
The following items are presumed to be infectious waste.
- Sharps, including unused or disinfected sharps that are being discarded, such as hypodermic needles, syringes with needles, scalpel blades, lancets, broken glass or rigid plastic vials and laboratory slides.
- Bulk blood or body fluids, including pourable or dripable amounts of blood or body fluids or items saturated with blood or body fluids.
- Microbiological laboratory waste, such as cultures derived from clinical specimens and discarded laboratory equipment that has contacted cultures.
- Human tissue, including teeth but not hair or nails.
- Tissue, bulk blood or body fluids from an animal carrying a zoonotic infectious agent such as rabies, anthrax or tuberculosis.
For legal definitions of infectious and medical waste and related terms, see:
Note: Households are only required to manage their sharps as infectious waste. The rest of these items, when managed by households, may be put in the regular trash. The DNR recommends wrapping them in plastic first.
Items usually not considered to be infectious waste
The following are presumed not to be infectious waste.
- Items soiled or spotted, but not saturated, with human blood or body fluids, such as gloves, gowns, dressings, bandages, surgical drapes and feminine hygiene products.
- Items containing non-infectious body fluids, such as diapers.
- Containers, packaging, waste glass, laboratory equipment or other materials that have had no contact with blood, body fluids, clinical cultures or infectious agents.
- Animal manure and bedding.
- Tissue, blood or body fluids from animals not known to be carrying a zoonotic infectious agent.
- Teeth that individuals take home from the dentist. Get more information on dental waste.
Note: If these items were mixed with infectious waste, they would have to be managed as though they were infectious. Also, see s. NR 526.05(2), Wis. Adm. Code.
If you are unsure whether an item is infectious waste
Contact the Wisconsin Department of Health Services.
Items that are both infectious waste and hazardous waste
Some wastes can be both hazardous waste and infectious waste. For example, laboratory samples of blood mixed with a reagent containing mercury is both an infectious waste and a hazardous waste. People handling wastes that are both hazardous and infectious should send them to a hazardous waste facility that can also handle infectious waste.
- Basic Infectious Waste Requirements for Generators of Small Amounts (WA-815)
- List of licensed infectious waste transporters
- Wisconsin's sharps collection program
- Map of registered sharps collection stations in Wisconsin
- U.S. Environmental Protection Agency's medical waste page
- Healthcare Environmental Resource Center
- U.S. Occupational Safety and Health Administration: Healthcare
Legal requirements for medical and infectious waste
Anyone generating or managing infectious waste must follow Wisconsin's medical waste rules.
Those who generate or manage small quantities of infectious waste must segregate wastes and follow all safety-related requirements but may be exempt from administrative requirements such as licensing and paperwork. This fact sheet will help you manage your infectious waste safely and may also help reduce your costs.
Businesses and institutions may have to file annual reports on the amounts they send off-site for treatment.
EPA ID numbers for infectious waste generators
The DNR does not require infectious waste generators to obtain EPA ID numbers. However, some infectious waste vendors require their customers to obtain an EPA ID number. The DNR provides EPA ID numbers at no cost upon request.
To apply for an EPA ID number, you must file a Notification of Regulated Waste Activity (EPA Form 8700-12).
- EPA Form 8700-12
- Contact your DNR regional environmental program associate for assistance or to submit completed applications.
Segregating infectious waste
Segregation of wastes, also known as source separation, is mandatory at the time they are generated for all non-household infectious waste generators according to NR 526.06.
All facilities that generate infectious waste must keep adequate records
Regardless of whether your facility is exempt from filing a report, you need to maintain adequate records of the amounts of waste you generate, treat on-site and send off-site for treatment. These records can include any of the following:
- Your infectious waste manifests or records of waste sent off-site for treatment (hospitals, clinics and nursing homes must retain for 5 years, all others for three years).
- Your certificates of destruction or treatment (hospitals, clinics and nursing homes must retain for 5 years, all others for three years).
- Logs of the amounts sent off-site for treatment and the destination facility.
- Logs of the amounts generated.
- Records related to on-site treatment (see s. NR 526.12, Wis. Adm. Code).
In addition, hospitals, clinics and nursing homes (unless exempt) must retain:
- Your waste audits (must retain all past audits).
- Your current medical waste reduction policy (recommend retain any previous versions of the policy for 5 years after they are retired).
- Your medical waste reduction plan and updates to the plan (recommend retain previous versions of the plan for 5 years after they are retired).
- Copies of the annual reports you have submitted to DNR (must retain for 5 years, recommended retain for 10 years).
- Infectious waste manifests (hospitals, clinics and nursing homes must retain for 5 years, all others for 3 years).
- Certificates of destruction or treatment (hospitals, clinics and nursing homes must retain for 5 years, all others for 3 years).
- Training records (recommend retain for 5 years).
- Any other documentation that supports how and when you implemented your plan’s goals and objectives (recommend retain for 5 years).
Documentation may be paper or electronic. You should store these records at your facility in a file that is secure yet accessible, in case the DNR or EPA asks to see them. Be sure they are not discarded when people change positions or leave your facility. Recordkeeping requirements are in s. NR 526.14, Wis. Adm. Code.
Reducing healthcare waste
Hospitals, clinics and nursing homes, unless exempt, must write and implement plans for reducing healthcare waste (see ss. NR 526.16 through .22).
If your hospital, clinic or nursing home has a medical waste reduction plan, it must be made available to the public, according to s. NR 526.22, Wis. Adm. Code.
Treating infectious waste
Healthcare facilities must ensure their infectious waste is properly treated before it is sent to the landfill. Generators may treat their own wastes if they follow the requirements of ss. NR 526.11 and 12.
Generators treating fewer than 500 pounds of infectious waste per day are exempt from licensing. All others must obtain DNR approval and an operating license. Prospective treatment facility operators should contact the DNR Medical Waste Coordinator before submitting the facility plan of operation to ensure the plan will address DNR concerns, particularly about testing protocols.
Transporting infectious waste
You may either hire a licensed infectious waste transporter or transport the waste yourself as an exempt or licensed transporter.
All transporters, exempt from licensing or not, must follow minimum safety requirements in s. NR 526.10(3), Wis. Adm. Code.
Determining whether you need a license
Those transporting less than 50 pounds per month, in every month of a calendar year, may transport infectious waste without a special license. Special licenses and license exemptions are in s. NR 526.10 (2). Those transporting 50 pounds or more of infectious waste must obtain an infectious waste transportation license.
If a vehicle carrying infectious waste is traveling through Wisconsin without stopping to pick up, drop off or transfer waste, the vehicle does not need to have a Wisconsin infectious waste transportation license.
For more information or to obtain a license application form, see:
If you are starting a trauma scene or crime scene cleanup business, please see the questions about trauma scene requirements in the Healthcare waste treatment FAQ.
COVID-19 Healthcare Waste
Requirements and best management practices for generators of COVID-19 healthcare waste in Wisconsin
Recommended practices for managing COVID-19 waste
The U.S. Centers for Disease Control is recommending routine management and disposal of healthcare waste from COVID-19 patients or persons under investigation.
Status of COVID-19 in Wisconsin
To learn more about the current status of COVID-19 in Wisconsin and all information pertaining to management, visit the Wisconsin Department of Health Services COVID-19 webpage
Due to the recommendations for routine management of healthcare wastes, an overview of Wisconsin's requirements for managing healthcare waste is described below, along with additional recommended practices. If at any time the CDC makes additional recommendations for managing COVID-19 healthcare waste, we will update this information as soon as possible. Recommendations from a reputable source such as the CDC, World Health Organization and U.S. Occupational Safety and Health Administration can always be used in accordance with the minimum requirements covered below. Healthcare facilities may also want to work directly with their infectious waste management facility, as they may establish additional protocols.
OSHA is recommending routine personal protective equipment (PPE) and safe handling practices for all solid waste and wastewater workers and employers when managing confirmed or potential COVID-19 healthcare waste.
- OSHA's COVID-19 control and prevention measures for solid waste and wastewater management workers and employers
Infectious waste requirements for non-household generators
Non-household generators of healthcare waste are required to keep wastes that meet the statutory definition of infectious waste separate from other solid wastes and manage it accordingly.
The statutory definition of infectious waste is “solid waste that contains pathogens with sufficient virulence and in sufficient quantity that exposure of a susceptible human or animal to the solid waste could cause the human or animal to contract an infectious disease.” [s. 287.07(7)(c)1.c., Wis. Stats.]
Section NR 526.06 of the Wisconsin Administrative Code lists the categories of healthcare wastes that should be assumed to be infectious unless demonstrated otherwise. Regardless of whether these wastes are generated by COVID-19 healthcare measures or not, the following should be managed as infectious waste.
- Sharps, including:
- contaminated sharps which are both infectious and may easily cause punctures or cuts in the skin, including but not limited to: hypodermic needles, syringes with needles attached, scalpel blades, lancets, broken glass vials, broken rigid plastic vials and laboratory slides; and
- unused or disinfected sharps which are being discarded, including hypodermic needles, scalpel blades, lancets and syringes with needles attached
- Bulk (dripable or pourable quantities or items saturated with) blood and body fluids from humans (whole blood or blood components, blood specimens, semen, vaginal secretions, cerebrospinal fluid, synovial fluid, amniotic fluid, peritoneal fluid, peritoneal dialysate, pericardial fluid, pleural fluid and other body fluids visibly contaminated with blood)
- Human tissue (including teeth but not including hair or fingernails)
- Microbiological laboratory waste
- Tissue, bulk blood or body fluids from an animal which is carrying a zoonotic infectious agent (Zoonotic infectious agents include Bacillus anthracis (anthrax), Brucella abortus (brucellosis), Chlamydia psittaci (psittacosis), Coxiella burnetii (Q fever), Lyssa virus (rabies), Mycobacterium bovis and Mycobacterium tuberculosis)
Full requirements for the management of infectious waste can be found in ch. NR 526, Wis. Adm. Code. Infectious wastes other than sharps (which must be placed in rigid, puncture-resistant, labeled containers) shall be placed in a bag that meets or exceeds 165 grams of resistance and is tear-resistant, a double bag that meets the same standards or a rigid reusable container. The container must be securely sealed to prevent the expulsion of waste. Once the wastes are placed in the container they cannot be opened, separated or mixed with other solid wastes. Infectious waste must be stored in an enclosed building, vehicle, or container and on a surface impermeable to liquids.
- List of licensed infectious waste transporters in Wisconsin (select “IW Transporter” under “Facility Type”)
Mail-back programs are also commonly available for small-volume generators.
Healthcare wastes that are not hazardous waste (per NR 661.03, Wis. Adm. Code) and not listed above must be properly managed and disposed of as solid wastes, per chs. NR 500-599, Wis. Adm. Code. This includes items soiled but not saturated with blood or body fluids, items soiled with body fluids from humans not included in the definition of “bulk blood and body fluids" (such as urine), intravenous tubing after needles have been detached, and other solid wastes, including but not limited to containers, packages, waste glass, laboratory equipment and other materials which have had no contact with blood, body fluids, clinical cultures or infectious agents. Solid wastes shall be stored in durable, leak-proof containers and be transported by a licensed solid waste hauler or self-hauled to a licensed solid waste transfer facility or landfill if transporting less than 20 tons per year. Full requirements for the management of solid waste can be found in chs. NR 500, Wis. Adm. Code.
The CDC recommends managing and disposing of any non-hazardous waste (as defined by ch. NR 661.03, Wis. Adm. Code) generated by COVID-19 healthcare measures as solid waste unless they otherwise meet the definition of infectious waste.
“Medical waste (trash) coming from healthcare facilities treating COVID-2019 patients is no different than waste coming from facilities without COVID-19 patients. CDC’s guidance states that management of laundry, food service utensils, and medical waste should be performed in accordance with routine procedures. There is no evidence to suggest that facility waste needs any additional disinfection.” (CDC FAQ for Healthcare Professionals)
Additional recommendations for non-household generators
The National Waste and Recycling Association’s Healthcare Waste Institute recommends the use of single-use infectious waste containers for COVID-19 infectious wastes and notifying your infectious waste hauler and/or treatment facility of infectious waste that was generated by COVID-19 healthcare measures.
Requirements for household generators
Household generators of infectious waste are exempt from the infectious waste requirements except for the management and disposal of medical sharps.
Additional recommendations for household generators
The CDC’s page for environmental cleaning and disinfection for U.S. households with suspected/confirmed COVID-19 has laundering recommendations for clothing, towels and linens and for washing reusable food service items. These items are not required to be disposed of after use. Recommendations for disinfection of surfaces include the use of diluted bleach solutions and alcohol solutions of 70% alcohol.
- CDC Interim Cleaning and Disinfection Recommendations for U.S. Households with Suspected/Confirmed COVID-19
The page also makes recommendations to:
- dedicate a specific-lined trash can for waste from the ill person;
- use gloves when handling and disposing of the trash bag; and
- wash hands after handling and disposing of the trash bag (and removal of gloves).
- Contact information
- For questions about the infectious waste requirements and how they apply to COVID-19 waste, contact:
DNR Waste and Materials Management Program
COVID-19 Vaccine Waste
Requirements and best management practices for generators of COVID-19 vaccine and equipment waste
Waste syringes and sharps
Used and unused waste sharps, including syringes with needles, are required to be managed as infectious waste. To properly manage sharps, please do the following:
- Keep waste sharps separate from other wastes.
- Place waste sharps in rigid, puncture-resistant containers with secure lids or caps that are labeled with the words "biohazard," "infectious waste" or "sharps," or with the biohazard emblem.
- Do not empty or remove waste from the sharps container once added. Mechanical means are required for emptying and disinfecting reusable sharps containers.
- Store sharps containers in a safe manner and have them removed from the site as necessary and at least every 90 days.
- Transport or contract with a transporter to move the waste in a manner that prevents spills. For details, review "Transportation" below.
- Make sure the sharps are transported to a location licensed to accept infectious waste or to a sharps collection station. For more information, review "Treatment and disposal" below.
- Keep records of the amount of sharps waste generated from your location and the date and destination location of sharps that leave the generator site. For more information, review “Records” below.
COVID-19 vaccine waste vials
Empty and nonempty waste vaccine vials can be disposed of as regular solid waste. Incineration is a best management practice for many pharmaceutical wastes. If your facility wants to ensure incineration of these materials, separate them as pharmaceutical waste for incineration and confirm that incineration is the final treatment method for the pharmaceutical waste at your facility.
Other medical waste
If other medical waste, such as personal protective equipment, is generated, refer to the COVID-19 healthcare waste tab to determine if infectious waste requirements apply.
It is highly recommended that dry ice be left to sublimate safely in a well-ventilated area. Dry ice that is disposed of in the garbage or down the drain can create an unwanted pressure buildup.
Pfizer has a return system for some of its thermal packaging. Contact Pfizer for more information.
Cardboard, paper and plastic containers should be recycled in accordance with local requirements. State law requires cardboard, office paper and select plastic containers (#1 PETE and #2 HDPE) to be recycled.
Plastic film may be recycled separately with other stretchable plastic film materials at a plastic film recycling location, but should not be placed in a mixed recycle bin in most areas.
Infectious waste, such as sharps, may be self-transported or managed through a transportation service. While an infectious waste transportation license is typically required for hauling infectious waste, including sharps, in amounts of more than 50 pounds per month, that requirement is waived for emergency mass vaccination events. However, licensed infectious waste transporters will likely be the most prepared for transporting vaccine waste.
Likewise, solid waste, such as vaccine vials and packaging, may be self-transported or managed through a transportation service. A license is required for solid waste transporters hauling more than 20 tons per year.
If choosing to work with a hauler specifically for infectious waste, select "IW Transporter" when accessing the list of licensed transporters. Otherwise, select "SW Transporter- SW & Recyclables" or "SW Transporter- SW Only" to access a list of licensed waste transporters.
Generators of less than 50 pounds of sharps per month may self-transport to a sharps collection station, who will then manage the final treatment of the sharps.
See section on requirements and best management practices for transporters for information on how to safely transport infectious waste.
Treatment and disposal
Infectious waste, including sharps, must be treated prior to disposal. This includes mechanically breaking the sharps so they cannot be reused and treatment to render the sharps noninfectious. Select "SW Processing- IW" or "SW Storage-Infectious Waste" when accessing the list of infectious waste storage/transfer and processing facilities in Wisconsin.
Solid waste must be disposed of properly at a licensed solid waste facility such as a landfill.
Infectious waste generators, including generators of sharps, are required to keep records of the amount of sharps waste generated and sent off-site for treatment. Licensed infectious waste transporter provide infectious waste manifests. If sharps are transported using other means, generators may use a simple log to record the volume of infectious waste generated and the date and destination of the material leaving the site. Records should be retained for three years. All emergency mass vaccination waste is exempt from annual reporting requirements.
Specific records are not required for solid waste disposal.
- Pfizer safety data sheets [PDF]
- Centers for Disease Control and Prevention page on vaccine and equipment disposal
- Wisconsin Department of Health Services vaccine webpage
- Wisconsin administrative code reference for emergency mass vaccinations
Requirements and best management practices for transporters of COVID-19 vaccine and equipment waste
Transporters managing less than 50 pounds per month of infectious waste and/or transporting infectious waste generated from an emergency mass vaccination event are exempt from infectious waste licensing requirements, but are required to manage infectious waste, such as sharps, safely.
Transporters of infectious waste must:
- Transport only infectious waste that is properly contained. For sharps, this means rigid, puncture-resistant containers with secure lids or caps that are labeled with the words "biohazard," "infectious waste" or "sharps," or with the biohazard emblem.
- Manage infectious waste containers in a way that does not result in damage, opening or spilling of the containers.
- Transport infectious waste in a completely enclosed portion of the vehicle. The vehicle should be in good repair.
- Transport the infectious waste to a licensed infectious waste treatment facility, or transporting to a sharps collection station if generating less than 50 pounds of sharps waste per month.
- Contact information
- For questions about the infectious waste requirements and how they apply to COVID-19 waste, contact:
DNR Waste and Materials Management Program