Employee Safety in Medical Waste Management

Who is responsible for medical waste safety?

In a hospital, outpatient clinic, dental practice or medical laboratory, medical waste safety usually brings environmental legislation to mind. Yet the nurse who throws a needle into the wrong container, the cleaner who collects that bag, the employee who carries the bags to the store and the team that empties the store are all links in the same chain. A mistake at the start of the chain comes back as an injury to the employee at the very end.

Two sets of legislation govern the subject together. The Regulation on the Control of Medical Waste (Official Gazette 25.01.2017, No. 29959; last amended in the Official Gazette of 18.08.2022) sets out how waste is segregated, transported and stored. Law No. 6331 and the Regulation on the Prevention of Risks of Exposure to Biological Agents govern the protection of the employees who do this work.

If you outsource cleaning to a subcontractor, the responsibility does not disappear. Under Art. 22 of the 2026 training regulation, the principal employer checks the training certificates of the subcontractor's employees and explains the risks specific to the workplace to them before they start work.

Segregation at source: which waste goes in which container?

Segregation is done at the point where the waste is generated. Opening bags afterwards to sort them is prohibited and is one of the most dangerous jobs. Under Art. 10 of the regulation, the containers are as follows:

The most common mistake seen on site is throwing needles into the red bag. The person tying or carrying the bag is injured by a needle poking out of it. The second common mistake is household waste ending up in medical waste bags and medical waste in household waste bins. So place containers right next to the point where procedures are carried out, and put an illustrated card next to each container showing what goes in it.

The fill limit for sharps containers: the ¾ rule

A sharps container is filled to no more than ¾, its lid is closed and it is placed in a medical waste bag. Once full, it may not be compressed, opened or emptied. The same rule applies to red bags: the bag is filled to no more than ¾, its neck is tied tightly and, if necessary, it is placed in a second bag for leak-tightness. The contents of a bag are never compressed, removed from the bag or transferred to another container.

The reason for the ¾ rule is simple: a person trying to push a new needle into a container filled to the brim injures their hand while pressing the needle in. To make the rule workable:

• Choose containers with a fill line marked on them and keep the line visible.
• Fix the container close to the point of use, slightly below eye level, so that it cannot tip over.
• Decide per shift who will close the container and who will put out a new one.
• Do not allow a container whose lid has been closed to be reopened.
• Repeat in training that used needles are not recapped.

We described in detail what to do in the first minutes after an injury, the assessment of the source patient and post-exposure prophylaxis in our article on needlestick and sharps injuries.

Internal transport and temporary storage

The journey of collected waste to the store is the stage with the highest risk of injury and leakage. Art. 11 of the regulation governs this stage as follows:

• Transport is carried out by staff trained for this work.
• Lidded, orange containers, bins or buckets with no sharp edges and bearing the symbol are used.
• Bags and pathological waste containers are not carried by hand; pathological waste containers are moved on wheeled vehicles.
• Waste chutes and conveyor belts are not used; medical waste is not loaded onto the same vehicle as other waste.
• Transport containers are cleaned and disinfected every day.
• The route is chosen as far as possible away from patient and clean areas and from heavy traffic.

In practice, there are also holding points called "interim stores" on floors and wards. Make sure bags wait at these points inside orange containers with their lids closed, separate from patient and visitor traffic.

For the medical waste store (the temporary store, as the regulation calls it), Arts. 12 and 13 lay down the following rules:

If a bag tears or spills in the store, the waste is collected with suitable equipment, liquids are solidified with absorbent material and the store is disinfected immediately. The contents of a bag that tears during transport are safely transferred to a new bag and the container is disinfected.

Protecting waste staff: PPE, vaccination and health surveillance

Under Art. 27 of the regulation, medical waste collection staff use gloves, safety goggles and a mask while working, and wear boots and special orange protective clothing. This clothing and equipment are stored in a separate place; providing and cleaning them is the responsibility of the waste generator. It is important that gloves are puncture-resistant, but no glove can stop a needle that is pushed in. The real protection is the ¾ rule and keeping the bag away from the body.

The Regulation on Biological Agents complements these measures:

• Eating and drinking are prohibited in areas with a risk of contamination (Art. 10).
• Contaminated clothing and equipment are removed before leaving the work area, stored separately and decontaminated; the cost of these measures cannot be passed on to the employee.
• Employees without immunity are vaccinated where necessary (Art. 16).

At the pre-employment examination, the workplace physician assesses the employee's vaccination and immunity status and plans the health check at least every six months required by the regulation. We plan the necessary tests with authorised laboratories and health institutions. For the physician's role in this process, see our workplace physician page, and for the logic of testing, our article on periodic examinations and tests.

Entering it into the risk assessment, and common mistakes

The medical waste chain should be addressed in the risk assessment not as a single line but stage by stage: the point where waste is generated, collection, internal transport, the store and handover of waste to the licensed carrier. Write down who works at each stage; do not forget subcontractor staff.

Common gaps are:

1. Sharps containers filled to the brim or placed on the floor.
2. Bags carried by hand without their necks tied, resting against the body.
3. The store door being left open, or a water tap or grated drain being present in the store.
4. Subcontractor cleaning staff not being briefed before starting work.
5. The medical waste management plan not being up to date; Art. 22 of the regulation requires the healthcare facility to update this plan every year.
6. No records being kept of waste staff vaccinations and health checks.

For other risks specific to healthcare facilities, see our healthcare facilities page. You can check the required time of assigned health personnel according to your number of employees with the OHS obligation calculator.

Frequently Asked Questions

When is a sharps container replaced?

When it is no more than ¾ full. The container's lid is closed, it is placed in a red medical waste bag and a new one is put in its place. A full container is not compressed, opened or emptied.

What PPE should medical waste collection staff use?

Under Art. 27 of the regulation: gloves, safety goggles, a mask, boots and special orange protective clothing. Providing and cleaning this equipment is the responsibility of the waste generator, and it is stored in a separate place.

Does a practice generating little waste need a store?

A temporary store is mandatory for those generating more than 50 kg of waste a day. Those generating up to 1 kg of waste a day may keep waste in a lidded container for at most 48 hours. The provincial directorate may also require a store from smaller generators if it sees an environmental risk.

How often are waste staff given health checks?

Art. 9 of the Regulation on the Control of Medical Waste requires staff assigned to medical waste management to undergo a health check at least every six months and to be immunised. The workplace physician determines the content of the check.