Medical Waste Disposal & Environmental Marketing Claims

An Educational Reference for Healthcare Procurement and Sustainability Teams

INFINITUSMEDICAL.COM  2026

1. How Regulated Medical Waste Is Disposed of in the U.S.

1.1 Overview of the Regulated Medical Waste Pathway

Regulated medical waste (RMW), also called infectious waste, biohazardous waste, or red bag waste, is primarily governed at the state level. Since the federal Medical Waste Tracking Act of 1988 expired in 1991, the U.S. Environmental Protection Agency (EPA) has retained limited direct authority over RMW, and individual states set the defining rules for its classification, treatment, and disposal.¹ Federal agencies including the EPA, OSHA, CDC, and FDA each play a supporting role in aspects of safe handling.

The typical disposal pathway for single-use medical products is:

• Generation at the point of care (operating room, procedure suite, patient room)
• Segregation into appropriate waste streams (red bag RMW vs. general trash vs. sharps containers vs. hazardous waste)
• Collection and transport by a licensed medical waste hauler
• Treatment to neutralize biohazards, most commonly autoclaving (steam sterilization at approximately 135°C)
• Final disposal of the treated waste in a standard municipal solid waste (MSW) landfill

Understanding this pathway is critical for evaluating any environmental claim attached to a single-use medical product: the conditions inside a standard MSW landfill are dramatically different from optimized laboratory testing environments.

1.2 Treatment Technologies

Before most RMW can be sent to a standard landfill, it must be treated to reduce or eliminate infectious potential. The dominant treatment technology in the United States today is autoclaving.

Regardless of which treatment method is used, the vast majority of processed RMW in the U.S. ultimately enters the standard municipal solid waste landfill system. This fact is central to understanding why many biodegradability claims marketed to healthcare facilities warrant careful scrutiny.

1.3 The Dramatic Decline of Medical Waste Incineration in the U.S.

On-site hospital incineration has declined sharply since the 1990s. In 1997, the EPA promulgated stringent emission standards for Hospital/Medical/Infectious Waste Incinerators (HMIWI) under Section 129 of the Clean Air Act, regulating nine pollutants including dioxins, mercury, and particulates.² As a result:

• In the late 1980s and early 1990s, estimates put the number of active medical waste incinerators in the U.S. at approximately 4,500 to 6,200.
• Following EPA HMIWI regulations, that number fell to roughly 50 to 60 units by the early 2010s, with many being large commercial centralized facilities rather than hospital-based units.³
• The majority of U.S. hospitals (over 6,000 facilities) now use autoclaving, chemical treatment, or microwave-based technologies and ship waste off-site for treatment.
• Today, direct on-site hospital incineration is uncommon; only certain waste categories (pathological, trace chemotherapy) are routinely required by many states to be incinerated.

2. Municipal Solid Waste Landfills: Definition, Design, and Groundwater Protection

2.1 What Is a Municipal Solid Waste Landfill?

A Municipal Solid Waste Landfill (MSWLF) is a federally defined, engineered facility that receives and permanently contains non-hazardous solid waste generated by households, businesses, and institutions. Under the EPA’s definition, an MSWLF is a discrete area of land or excavation designed, constructed, operated, and monitored to safely isolate solid waste from the surrounding environment, particularly groundwater and surface water, for the long term.⁴ Because every design and operational element of these facilities is deliberately engineered to exclude moisture, entomb waste, and contain it indefinitely, MSWLFs are widely known in environmental science and engineering literature as “dry tomb” landfills. The term is not an official regulatory designation but an accurate and widely accepted technical description: waste is sealed inside as if interred, isolated from the biological and hydrological processes that would otherwise break it down. This nickname is central to understanding why biodegradability claims, almost always derived from tests run in wet, biologically active laboratory conditions, have little bearing on what actually happens to a product once it reaches its final destination.

MSWLFs are authorized to receive:

• Household solid waste (the primary waste stream)
• Commercial solid waste from businesses and institutions
• Non-hazardous industrial solid waste
• Non-hazardous sludge from water or wastewater treatment plants
• Treated regulated medical waste (RMW) that has been rendered non-infectious through autoclaving, microwave treatment, or chemical disinfection
• Construction and demolition debris (in many states)

Critically, MSWLFs are expressly prohibited from accepting hazardous wastes, untreated infectious/regulated medical waste in most states, radioactive materials, and bulk liquid wastes. This is why RMW must be treated before it can enter the MSWLF stream. The landfill system is designed and sized for dry, non-infectious solid material, not wet biohazardous waste.

2.2 The Regulatory Framework: RCRA Subtitle D and 40 CFR Part 258

All MSWLFs in the United States must comply with the federal criteria codified in Title 40 of the Code of Federal Regulations, Part 258 (40 CFR Part 258), the regulatory heart of Subtitle D of the Resource Conservation and Recovery Act (RCRA). This framework, effective for facilities operating on or after October 9, 1993, establishes six categories of requirements:^4,16

States play the lead role in implementing and enforcing Subtitle D. Many states have adopted requirements that are more stringent than the federal minimums. For example, New York requires double composite liners, Delaware applies requirements equivalent to those governing hazardous waste landfills, and Michigan mandates composite liners with secondary containment systems. The federal standards represent a floor, not a ceiling.

2.3 Understanding Leachate: The Core Threat to Groundwater

To understand why MSWLF design is so extensively engineered, it is essential to first understand leachate, the liquid that drives virtually every major groundwater protection requirement in a modern landfill.

What Is Leachate?

Leachate is a highly contaminated liquid formed when water, primarily from precipitation but also from moisture inherent in the waste itself, percolates downward through the waste mass inside a landfill. As this liquid moves through layers of buried waste, it acts as a solvent, dissolving and carrying with it a wide spectrum of chemical and biological contaminants from the decomposing material. The EPA defines leachate simply as water that has filtered through wastes and leached out chemicals or constituents from those wastes.⁴

Leachate is not a single compound but a complex, highly variable mixture. Scientific literature categorizes its contaminants into four primary groups:¹⁷

• Dissolved organic matter: Organic compounds released during microbial decomposition of waste, quantified as Chemical Oxygen Demand (COD) or Total Organic Carbon (TOC). Concentrations are highest in young, actively decomposing landfills.
• Inorganic macrocomponents: Ions including ammonia (NH₄⁺), chloride, sulfate, sodium, potassium, calcium, and magnesium. Ammonia is particularly persistent. Unlike most organic compounds, it does not decrease over time and is considered the dominant long-term pollutant in mature landfill leachate.
• Heavy metals: Arsenic, cadmium, chromium, lead, mercury, zinc, and others. Concentrations are typically highest in the early acid phase of decomposition when the leachate pH is low (increasing metal solubility) and decrease as the landfill matures.
• Xenobiotic organic compounds: Synthetic chemicals including solvents, pesticides, pharmaceutical compounds, plasticizers, flame retardants, and personal care product residues that may have entered the waste stream from household, commercial, or medical sources.

How Leachate Forms: The Role of Moisture

The rate and volume of leachate generation is governed primarily by moisture infiltration into the waste mass. Factors that increase leachate generation include:

• Rainfall and snowmelt percolating through the landfill cover
• Moisture content inherent in the waste itself (food waste, wet absorbent materials, saturated surgical products)
• Water added to the landfill from other sources

This relationship between moisture and leachate is foundational to understanding why standard Subtitle D MSWLFs are deliberately engineered to be dry. Every engineering decision in a Subtitle D landfill, from the impermeability of the liner to the design of the final cover, flows from a single governing objective: prevent moisture from entering the waste mass, and capture any that does before it can escape into the surrounding environment.

2.4 The Engineered Defense System: Liner, Cover, and Collection

A modern Subtitle D MSWLF is not simply a hole in the ground filled with waste. It is a multi-layered containment system with redundant barriers between the waste and the natural environment. The following describes each major component.

Layer 1: The Composite Liner System (Bottom and Sides)

The foundation of every Subtitle D landfill is its composite liner, a two-component barrier system that lines the floor and sidewalls of the excavated landfill cell. Federal minimum standards under 40 CFR §258.40(b) require:⁴

• Upper component (Geomembrane): A flexible membrane liner (FML) made of high-density polyethylene (HDPE) at least 60 mils (0.060 inches) thick. HDPE is selected for its chemical resistance, low permeability, and durability. The geomembrane must be installed in direct and uniform contact with the lower soil component, with no gaps, to function as designed.
• Lower component (Compacted Clay or Equivalent): A minimum two-foot (60 cm) layer of compacted soil or clay with a hydraulic conductivity (a measure of how readily water moves through it) of no more than 1 × 10⁻⁷ cm/sec, making it essentially impermeable to liquid movement under normal conditions.

Together, these two components create a composite barrier: the geomembrane prevents liquid from passing through quickly, and the compacted clay provides a secondary chemical barrier and slows any leachate that might permeate through a pinhole or seam defect in the HDPE layer. The two components work in tandem because each compensates for the limitations of the other.

Many states and many modern facilities go beyond the federal minimum and install double composite liner systems consisting of two independent composite liners separated by a leak detection layer (typically a sand or gravel drainage layer). Any leachate that penetrates the primary liner is collected in this interstitial space and detected before it can reach the secondary liner, providing an early warning system for liner integrity failures.

Layer 2: The Leachate Collection and Removal System (LCRS)

Sitting directly on top of the composite liner is the Leachate Collection and Removal System (LCRS). This system is designed to intercept any leachate that forms within the waste mass before it can build up and place hydraulic pressure on the liner. Federal regulations require that the LCRS maintain leachate head (depth of leachate above the liner surface) at less than 30 centimeters (approximately 12 inches) at all times. The higher the leachate head, the greater the pressure driving liquid through any imperfection in the liner.

A typical LCRS consists of:

• A high-permeability drainage layer of gravel or sand that allows leachate to flow freely toward collection points rather than pooling
• A network of perforated pipes embedded in the drainage layer that channel collected leachate toward a central sump or collection point
• A sump pump system that lifts collected leachate to the surface for storage and treatment
• Geosynthetic drainage composites (in some modern designs) that replace or supplement granular drainage layers

Collected leachate is typically transported off-site to a municipal wastewater treatment plant or a dedicated leachate treatment facility. It cannot simply be discharged; leachate’s high concentrations of ammonia, heavy metals, and organic compounds require specialized treatment before safe disposal.

Layer 3: The Final Cover System (Cap)

When a landfill cell reaches capacity and is closed, a final cover system is installed over the compacted waste mass. The cover’s primary function is to minimize the infiltration of precipitation into the waste, thereby minimizing the generation of new leachate. Federal minimum standards under 40 CFR §258.60 require:⁴

• An infiltration layer of at least 18 inches of earthen material with a permeability no greater than the bottom liner (no more than 1 × 10⁻⁵ cm/sec), so the cover does not allow water to pass through more readily than the bottom liner can handle
• An erosion layer of at least 6 inches of earthen material that can sustain native plant growth, which further limits erosion and water infiltration through root-zone evapotranspiration

Many modern and state-regulated covers add a geomembrane component (similar to the bottom liner), drainage layers, and gas venting infrastructure to the minimum two-layer design.

Layer 4: Groundwater Monitoring Network

Surrounding the landfill is a network of monitoring wells that provide ongoing surveillance of groundwater quality and serve as the final line of defense against undetected liner failure. Under 40 CFR Part 258 Subpart E, virtually all MSWLFs must install and maintain a groundwater monitoring system certified by a qualified groundwater scientist, consisting of:⁴

• Up-gradient wells: Positioned to capture background groundwater quality unaffected by the landfill, establishing a baseline against which contamination is measured
• Down-gradient wells: Positioned in the direction of groundwater flow from the landfill, where any escaping leachate plume would first appear

Wells must be sampled at least semiannually throughout the facility’s active life and post-closure monitoring period. Monitoring targets 62 indicator constituents listed in Appendix I of 40 CFR Part 258, covering compounds ranging from common solvents to heavy metals to volatile organic compounds. If any constituent is detected at a statistically significant level above background, the facility must notify the state agency and initiate an assessment monitoring program within 90 days. If contamination is confirmed, the facility must implement corrective action.

Post-Closure Obligations

A landfill’s obligations do not end at closure. Federal minimum standards require at least 30 years of post-closure care, including maintenance of the final cover system, continued operation and monitoring of the leachate collection system, continued groundwater monitoring, and maintenance of any gas collection and control system. Some states extend this period, and several environmental scientists have argued that given the durability of synthetic materials and the long-term nature of leachate generation, 30 years significantly underestimates the actual time that landfill waste remains a threat to groundwater quality.

2.5 From MSWLF to “Dry Tomb”: The Connection

The term dry tomb is not an official regulatory term but an accurate technical description of what Subtitle D design achieves in practice. Every engineered component described above, including the impermeable liner, the leachate collection system, the low-permeability cover, and the post-closure monitoring, serves one purpose: to keep the waste dry and isolated from the environment.

This design philosophy produces a predictable consequence for biodegradation: very little of it happens. Microbial decomposition requires moisture. In a standard MSWLF:

• The composite liner prevents groundwater from rising into the waste from below
• The low-permeability cover prevents precipitation from infiltrating the waste from above
• The LCRS removes any leachate that does form before it can saturate the waste mass
• The result is a waste mass with moisture content typically ranging from 10 to 25%, well below the 35 to 65% range required for significant microbial activity

Materials that would degrade readily in a moist, biologically active environment, such as the optimized test conditions of ASTM D5511, remain largely intact in a dry tomb for decades. This is the fundamental disconnect between laboratory biodegradability testing conducted under bioreactor-like conditions and the actual fate of products in the facilities that receive them.

2.6 Bioreactor Landfills: The Rare Exception

A bioreactor landfill takes a fundamentally different approach: rather than excluding moisture, it actively introduces liquids, primarily recirculated leachate and supplemental water, into the waste mass to maintain moisture content near field capacity (approximately 35 to 65%) and promote rapid microbial decomposition.⁵ The EPA describes three configurations: aerobic (air injected to promote aerobic bacteria), anaerobic (no air; promotes methane-producing bacteria), and hybrid.

Key facts about bioreactor landfills in the United States:

• True bioreactor landfills represent a very small fraction of active U.S. MSW sites. Most states have no specific bioreactor regulations; three states prohibit them outright, and eight additional states have indicated they would not approve one.
• The EPA has noted that bioreactor landfills remain largely at the research, demonstration, and pilot project stage nationally. Full-scale commercial bioreactor landfills are the exception, not the norm.
• Bioreactor technology requires liner systems specifically engineered for continuously saturated conditions (going beyond standard Subtitle D minimums), significant capital investment in moisture injection infrastructure, and active ongoing operational management; these factors have prevented widespread adoption.
• Bioreactor landfills produce landfill gas (primarily methane) earlier and at higher rates than dry tombs. This increased gas production can be beneficial if gas is captured for energy recovery, but harmful if it is not.
• Waste stabilization in a bioreactor can occur in 5 to 10 years rather than the 30 or more years typical of a conventional dry tomb, but this benefit exists only in facilities that maintain active moisture management, which standard MSWLFs are specifically designed to avoid.⁵

3. Biodegradability Testing Standards Explained

3.1 What Biodegradation Actually Means

True biodegradation, sometimes called mineralization, is a process in which microorganisms consume a material and convert it to gases (primarily carbon dioxide and methane), water, and biomass. It is distinctly different from:

• Fragmentation or disintegration: Physical breakdown of a material into smaller pieces without microbial consumption. This can produce microplastics without any environmental benefit.
• Oxidative degradation: Chemical breakdown from heat or UV light, again potentially producing microplastic fragments.

When evaluating a biodegradability claim, it is important to ask whether the test confirms true mineralization (measured by gas evolution data showing actual production of CO₂ and CH₄) rather than simple disintegration.

3.2 ASTM D5511: The High-Solids / Bioreactor Simulation

ASTM D5511 (Standard Test Method for Determining Anaerobic Biodegradation of Plastic Materials Under High-Solids Anaerobic-Digestion Conditions) evaluates how a material degrades when exposed to an active, high-moisture, biologically rich anaerobic environment. Key characteristics include:⁶

• Moisture content is high (typically >35%, often saturated conditions)
• An inoculated microbial sludge derived from active anaerobic digesters provides intense biological activity
• Temperature is controlled at 35–52°C
• Test duration is short, typically 30 to 60 days, and designed to observe rapid degradation rates
• Conditions simulate a biologically active bioreactor, not a standard landfill

3.3 ASTM D5526: The More Stringent Landfill Simulation

ASTM D5526 (Standard Test Method for Determining Anaerobic Biodegradation of Plastic Materials Under Accelerated Landfill Conditions) was designed to more accurately replicate the variable, lower-moisture conditions of actual landfills. Key differences from D5511:⁷

• Samples are tested across multiple conditions with varying solids content, including drier “dry tomb”-like environments
• Duration is longer, often six to twelve months or more, running until no further decomposition is measured
• Microbial activity is more moderate, reflecting aged waste layers rather than freshly active inoculated sludge
• Products often show significantly slower or lower degradation rates under D5526 than under D5511, more accurately reflecting real-world landfill performance

ASTM D5526 was withdrawn by ASTM International in July 2025 with no immediate replacement. As of early 2026, a work item (WK95881, initiated July 30, 2025) is under development to reinstate or revise the standard, with a proposed focus on two higher solids content levels (60% and 75%) that better reflect the predominantly dry conditions of U.S. Subtitle D landfills.⁷

4. The FTC Green Guides and Biodegradability Claims

4.1 What Are the Green Guides?

The Federal Trade Commission’s Guides for the Use of Environmental Marketing Claims, commonly known as the Green Guides (16 CFR Part 260), provide guidance to marketers on how to avoid making deceptive environmental claims under Section 5 of the FTC Act. Although the Guides themselves are advisory guidance rather than binding regulations, violations can expose manufacturers to significant federal enforcement action and civil penalties. The current version was issued in 2012; the FTC initiated a new review in 2022.⁸

4.2 The Biodegradable / Degradable Standard (16 CFR § 260.8)

The Green Guides state that an unqualified degradable or biodegradable claim is deceptive unless a marketer can demonstrate that the entire item will fully decompose and return to nature (break down into elements found in nature) within a reasonably short period of time after customary disposal.⁸ This is usually defined as one year when it comes to biodegradability claims.

Three elements of this standard deserve attention:

• “Entire item”: The full product must degrade, not just a surface coating or additive.
• “Reasonably short period of time”: The FTC’s own examples indicate this means approximately one year. Few, if any, plastic-based foams meet this threshold in a standard landfill.
• “Customary disposal”: This refers to how the product actually enters the waste stream. For most single-use medical products, that means a standard MSW landfill following autoclaving.

4.3 State-Level Requirements

State laws can impose additional, often stricter requirements than the federal Green Guides. For example, California’s Truth in Environmental Advertising law (Business and Professions Code § 17580 et seq.) prohibits marketing, selling, or labeling certain plastic-containing products as “biodegradable” unless they meet specific criteria. Other states have enacted similar provisions targeting unsubstantiated environmental claims. Manufacturers and purchasers should consult state-specific requirements applicable to their jurisdiction.

4.4 “Tested” vs. “Certified”: A Critical Distinction

Healthcare professionals frequently encounter marketing language emphasizing “independent laboratory tested and certified” biodegradability. It is important to understand exactly what these phrases do and do not mean:

5. The Methane Problem: When “Biodegradable” Can Increase Emissions

A counterintuitive but scientifically important point: in a dry tomb landfill, a product marketed as biodegradable may actually produce worse greenhouse gas outcomes than a stable, non-degrading alternative. Here is why.

Anaerobic decomposition is the only pathway available in oxygen-limited landfills and it produces methane (CH₄) as a primary byproduct. Methane is a potent greenhouse gas with a global warming potential 25 to 80 times greater than CO₂ over 20 to 100-year time horizons.

If a product partially degrades in a dry tomb landfill:

• It converts some of its carbon into methane during that partial decomposition.
• If the landfill lacks an effective methane capture and energy recovery system, as is common in many facilities, and that methane escapes into the atmosphere as a fugitive emission.
• Even well-designed gas capture systems collect only approximately 75% of landfill gas emissions under ideal conditions, with collection efficiency declining over time.

This does not mean biodegradable products are always worse. In a true bioreactor landfill with effective methane-to-energy recovery, biodegradation can be genuinely beneficial. However, because fewer than 5% of U.S. landfills operate as true bioreactors, this favorable scenario applies to a small minority of disposal endpoints. Sustainability claims that assume bioreactor conditions without disclosing this assumption may be materially misleading.

6. Weight and Material Considerations in Waste Economics

6.1 Why Weight Is the Primary Driver of RMW Cost

Unlike residential trash (often charged by container volume), regulated medical waste is almost universally billed by the pound or kilogram. Every gram of material added to the red bag waste stream has a direct cost implication. Key factors that affect weight-based disposal costs include:

6.2 Cost Reduction Strategies for Healthcare Facilities

Hospitals actively manage RMW costs through several strategies worth understanding:

• Suction canisters for fluid waste: Liquid waste disposed through the sanitary sewer system enters a different (and typically less costly) waste stream than solid RMW.
• On-site compaction (shred-and-steam): Compacting waste removes air volume, allowing more weight to fit in fewer containers and reducing per-container fees.
• Strict waste segregation: Keeping uncontaminated packaging, clean wrapping, and general trash out of red bag containers is one of the highest-impact cost reduction strategies. Clean packaging erroneously placed in a red bag can add $0.25–$0.50 or more per pound in unnecessary disposal costs.
• Vacuum-packed product packaging: Products packaged under vacuum occupy significantly less shipping and storage volume, reducing transportation emissions and costs. Note that certain foam formulations, particularly viscoelastic and memory foams, recover too slowly from compression to be effectively vacuum-packed.

7. A Practical Evaluation Framework for Procurement Teams

When a vendor presents environmental or biodegradability claims, the following questions help distinguish substantiated claims from unqualified marketing language. This framework can be incorporated into RFP processes, value analysis committee reviews, or vendor qualification checklists.

Question 1: What Specific Test Results Support This Claim?

Ask the manufacturer to provide the full laboratory report, not just a summary certificate or marketing brochure. A summary certificate typically shows a single final percentage figure. The full report should include:

• Biodegradation percentage at multiple time intervals (e.g., percentage at days 30, 60, 90, 180)
• A degradation curve showing whether biodegradation was still occurring at test end or had plateaued
• Gas evolution data (CO₂ and CH₄ production) confirming true mineralization rather than disintegration
• Positive and negative control results validating that test conditions were appropriate

Question 2: Which Test Standard Was Used, and Why?

Ask specifically: Was this tested under ASTM D5511, ASTM D5526, or both? If only D5511 was used, ask why D5526 testing was not conducted. As noted above:

• D5511 simulates optimized bioreactor conditions and not the dry tomb landfills that receive treated RMW.
• D5526, before its 2025 withdrawal, provided results under more realistic, lower-moisture landfill conditions. Products frequently show significantly lower degradation rates under D5526 than under D5511.
• If D5526 data exist for the same material, ASTM itself recommends that D5511 not be cited in isolation.

Question 3: Does the FTC One-Year Standard Apply?

Ask the vendor directly: Does this product fully decompose within one year in a standard (non-bioreactor) U.S. landfill? The FTC Green Guides indicate that unqualified biodegradable claims are inappropriate for products that do not meet this threshold in their customary disposal environment. If the vendor’s answer relies on laboratory conditions or bioreactor assumptions, the unqualified claim may be inconsistent with FTC guidance.⁸

Question 4: What Disposal Conditions Are Assumed?

Does the environmental benefit claimed assume the product is disposed in a bioreactor landfill with active methane capture? If so, ask what percentage of the facilities where this product is used actually send their waste to such a facility. For most U.S. healthcare institutions, the answer will be essentially none.

Question 5: Does the Claim Account for the Methane Factor?

Does the vendor’s sustainability claim acknowledge the greenhouse gas implications of partial degradation in landfills without robust methane capture? A transparent claim will address this. A claim that focuses solely on the positive potential of biodegradation without acknowledging this risk may be incomplete.

Question 6: Are There Appropriate Disclaimers?

Reputable manufacturers who have conducted legitimate biodegradability testing typically include explicit disclaimers noting that: (1) test results were obtained under specific laboratory conditions; (2) real-world landfill conditions may differ substantially; and (3) actual biodegradation rates may vary. Absence of such disclaimers on marketing materials is a meaningful red flag warranting further inquiry.

8. Summary: What Healthcare Facilities Should Know

Sustainability matters in healthcare, and procurement decisions have real environmental consequences. However, not all environmental claims accurately reflect real-world impact. The key takeaways from this document are:

Treated RMW in the United States is predominantly disposed of in standard dry tomb (Subtitle D) landfills rather than the bioreactor-like environments simulated in many biodegradability tests.

• ASTM D5511 testing occurs under high-moisture, optimized conditions that do not represent the low-moisture environment inside a typical Subtitle D landfill. Results from D5511 alone cannot reliably predict real-world landfill performance.
• The FTC Green Guides establish that unqualified biodegradable claims are inappropriate for products destined for standard landfills unless the entire item degrades within approximately one year in that environment, a threshold virtually no plastic-based foam meets.
• Partial biodegradation in a landfill without effective methane capture can increase a facility’s net greenhouse gas footprint relative to using a non-degrading inert material.
• Independent laboratory testing confirms behavior under specific test conditions only and does not constitute endorsement, certification, or a guarantee of real-world performance.
• Healthcare facilities can protect themselves from inadvertent greenwashing by requesting full lab reports, asking targeted questions about test methodology, and evaluating claims against FTC Green Guides standards.

Transparent, qualified environmental claims supported by evidence that honestly reflects customary disposal conditions are the appropriate standard, one that benefits patients, facilities, and the environment.

References

The following sources were used in the preparation of this document. URLs were verified as accessible in 2026.

1. S. EPA. Medical Waste under RCRA. https://www.epa.gov/rcra/medical-waste
2. S. EPA. Hospital, Medical, and Infectious Waste Incinerators (HMIWI): New Source Performance Standards (NSPS), Emission Guidelines, and Federal Plan Requirements. https://www.epa.gov/stationary-sources-air-pollution/hospital-medical-and-infectious-waste-incinerators-hmiwi-new
3. Health Care Without Harm. HMIWI reduction campaign documentation and EPA HMIWI overview. https://noharm-uscanada.org/
4. S. EPA. Basic Information About Landfills (Subtitle D overview). https://www.epa.gov/landfills/basic-information-about-landfills
5. S. EPA. Bioreactor Landfills. https://www.epa.gov/landfills/bioreactor-landfills
6. ASTM International. D5511-18: Standard Test Method for Determining Anaerobic Biodegradation of Plastic Materials Under High-Solids Anaerobic-Digestion Conditions. https://www.astm.org/d5511-18.html
7. ASTM International. D5526-18 (withdrawn 2025) and Work Item WK95881 (initiated July 30, 2025). https://www.astm.org/d5526-18.html ; https://www.astm.org/membership-participation/technical-committees/workitems/workitem-wk95881
8. Federal Trade Commission. Guides for the Use of Environmental Marketing Claims (Green Guides), 16 CFR Part 260 (2012, current as of 2026). https://www.ftc.gov/sites/default/files/attachments/press-releases/ftc-issues-revised-green-guides/greenguides.pdf
9. MDS Associates. Understanding the Biodegradable Standards ASTM D5511 and ASTM D5526. https://eco-mdsassociates.com/blogs/news/understanding-astm-d5511-astm-d5526-biodegradable-standards
10. Plastic-Recycled.com. ASTM D5511 vs. ASTM D5526: Certification Process for Biodegradable Products. https://plastic-recycled.com/astm-d5511-vs-astm-d5526-certification-process-for-biodegradable-products
11. Where Does Regulated Medical Waste Go After Collection? https://www.stericycle.com/en-us/resource-center/blog/where-does-medical-waste-go-after-collection
12. Red Bags. Medical Waste Disposal Regulations: A State-by-State Overview. https://redbags.com/medical-waste-regulations-by-state/
13. Environmental Claims: Summary of the Green Guides. https://www.ftc.gov/business-guidance/resources/environmental-claims-summary-green-guides
14. S. EPA. Municipal Solid Waste Landfills (Subtitle D regulations overview). https://www.epa.gov/landfills/municipal-solid-waste-landfills
15. World Health Organization. Health-care waste fact sheet. https://www.who.int/news-room/fact-sheets/detail/health-care-waste
16. S. EPA. Requirements for Municipal Solid Waste Landfills (MSWLFs). https://www.epa.gov/landfills/requirements-municipal-solid-waste-landfills-mswlfs
17. Kjeldsen P, Barlaz MA, Rooker AP, et al. Present and Long-Term Composition of MSW Landfill Leachate: A Review. Critical Reviews in Environmental Science and Technology. 2002;32(4):297–336. https://cfpub.epa.gov/si/si_public_record_Report.cfm?Lab=NCER&dirEntryID=69068

SUSTAINABILITY & BIODEGRADABILITY SCORECARD

Value Analysis Committee (VAC) / Procurement Oversight

Manufacturer:                                                                              Product Name:                                                                

Date of Review:                                                                          Reviewer:                                                                               

I.   Technical Data & Lab Validation

Critical for determining if “Green” claims translate to real-world performance.

Section Score                     / 25

II.    Disposal & Environmental Reality

Determining the impact on the hospital’s specific waste stream.

Section Score                     / 25

III.    Economic & Clinical Performance

Ensuring the “Eco-Premium” does not compromise care or budget.

Section Score                     / 25

IV.   Final Evaluation

• Total Score  / 75
• 00 – 30: High risk of greenwashing; unsubstantiated claims.
• 31 – 55: Request ASTM D5526 data and qualified disclaimers.
• 56 – 75: Real-world data aligns with facility waste stream.

Final Decision:                                                                                             

Notes:                                                                                             

Resource Links for Procurement Review

• FTC Green Guides: 16 CFR Part 260
• EPA Landfill Design: Subtitle D Regulations
• ASTM Work Item: WK95881 (Landfill Simulation Reinstatement)