UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

June 21, 1990

Mr. Richard J. Alampi

New Jersey Veterinary Medical Association

66 Morris Avenue

P.O. Box 359

Springfield, NJ 07081

Dear Mr. Alampi:

Thank you for your letter dated April 20, 1990, regarding the regulation of animal

carcasses under the Part 259 regulations. As you are aware, Section 259.10(a)

defines medical waste as "solid waste generated in the diagnosis, treatment (e.g.,

during the provision of medical services), or immunization of human beings or

animals, in research pertaining thereto, or in the production of testing of biologicals."

Regulated Medical Waste (RMW) is a subset of the medical waste stream. The

seven RMW classes are listed and described in Section 259.30(a).

Your question specifically related to the disposal of animal carcasses resulting from

the treatment and/or diagnosis of an animal which has been isolated because it is

suspected of having rabies. The regulation describes two situations where animal

carcasses would be RMW. Class 5 RMW includes contaminated animal carcasses,

body parts, and bedding of animals that were known to have been exposed to

infectious agents during research, production of biological., or testing of

pharmaceuticals. Thus, veterinarians treating or diagnosing animals which were not

intentionally exposed to infectious agents during research, testing of biological. or

pharmaceuticals, would not be regulated.

However, Class 6 RMW (Isolation wastes) are described as "biological waste and

discarded materials contaminated with blood, excretion, exudates., or secretions

from humans who are isolated to protect others from certain highly communicable

diseases, or isolated animals known to be infected with highly communicable

diseases." Therefore, specimens from animals which are isolated due to suspected

infection with rabies and are sent to a laboratory for testing would be considered

RMW upon disposal.

The carcass which is generated when the head is removed from the animal would

also be considered a RMW; however, there are several options available for the

disposal of the carcass. The generator of the waste could manage the carcass as a

RMW in accordance with all the requirements of Part 259. Alternatively, Section

259.50(c) indicates that generators who either treat and destroy or dispose of RMW

on-site through incineration, burial or sewer disposal are not subject to the tracking

requirement for that waste.

The state of New Jersey may have additional state specific requirements for this

type of waste. Please check with the New Jersey officials in regard to this matter.

If you need further assistance or have additional questions please contact Lisa

Warren 202-475-9324 or Mary Greene at 202-475-7736.

Sincerely,

Susan Bromm, Director

RCRA Enforcement Division

cc: Mary Greene

Bob Confer

George Meyers

Austine Frawley

FaxBack # 11529