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Medical and Infectious Wastes 585
need not be labeled. The outermost surface of each waste package must be marked with a water-
resistant identification tag with the following information:
● Generator name
● Generator’s state permit number or address
● Transporter’s name
● Transporter state permit number or address
● Date of shipment
● Identification of contents as medical waste

20.4.3 GENERATOR REQUIREMENTS
A facility that generates medical waste must determine whether that waste is a regulated medical
waste (40 CFR 259.50). However, a generator that treats and destroys or disposes of regulated med-
ical waste on the facility site (e.g., incineration) is not subject to any waste tracking requirements.
A generator must determine the quantity of regulated medical waste generated in a calendar month
and the quantity that is transported off facility property.
A generator that transports medical waste for off-site treatment or disposal must prepare a track-
ing form (see Figure 20.3). This form is analogous to the Universal Hazardous Waste Manifest that
is required for shipments of RCRA hazardous waste (Chapter 12). The generator is responsible for
preparing copies of the form for the generator, each transporter, any intermediate handlers, and the
destination facility. The generator is to keep a copy of the form, signed by all parties involved in
storage, transport, and disposal. This form is to be kept on file by the generator for at least 3 years
from the date that the waste was accepted by the transporter.
A generator must contact the destination facility to determine the status of any tracked waste if
a copy of the complete tracking form is not returned within 35 days. If the form is not returned after
a total of 45 days, the generator must submit an exception report to the state regulatory agency. The
exception form must include a copy of the tracking form and a letter signed by the generator
explaining the efforts taken in locating the waste shipment. A copy of the report must be kept on
file by the generator for 3 years.
Generators of 23 kg (50 lb) of regulated medical waste per month are exempt from a number
of requirements including of using a transporter who has notified EPA and the use of the tracking
form. Such small quantity generators are exempt from other transportation requirements provided
that certain provisions are met (Sec. 259.51(a)).

20.4.4 TRANSPORTER REQUIREMENTS
Transporters must notify the U.S. EPA and the state regulatory agency in writing as to their intent
to transport regulated medical wastes (40 CFR Part 259.70). Notification must include the trans-
porter’s name and address and EPA hazardous waste identification number (if applicable); name
and address of each transfer facility that the transporter will operate from; state permit to handle
medical or infectious waste; and a statement of willingness to comply with 40 CFR Part 259. The
EPA will subsequently provide each transporter with a unique identification number.
Waste that is transported by commercial haulers is often prepared for off-site transport in reusable
bins or drums or in cardboard boxes. Transport vehicles may be compactor vehicles depending on
state or local regulations. Secondary containers or additional packaging may also be required. Vehicles
that transport regulated medical waste must possess a fully enclosed, leak-resistant cargo-carrying
body, which must also be maintained in good sanitary condition. The transporter must ensure that the
waste is not subject to mechanical stress or compaction during transit, loading, or unloading.
Transport vehicles must have the following identification on both sides and the back of the
cargo body: the name of the transporter, the transporter’s state identification number, and a sign
with the words ‘Medical waste’ or ‘Regulated medical waste.’ Also, as per the ‘Mixture Rule’ for