Q: In the fine print of the new 2012 Life Safety Code, under sections 18/184.108.40.206.2 for containers used solely for recycling clean waste or for patient medical records awaiting destruction, the following is noted:
(4) Containers for combustibles shall be labeled and listed as meeting the requirements of FM Approval Standard 6921, Containers for Combustible Waste; however, such testing, listing, and labeling shall not be limited to FM Approvals.
My question is: Does this in reality become a hard burden to prove? Are other hospital facility managers unwilling to utilize the CMS waiver for this for fear that they will have difficulty proving compliance?
A: I have not heard of any facility manager not using the CMS categorical waiver based on the reluctance to be able to prove that the containers meet the requirements listed. It is a real possibility, but I can’t say I am aware of anyone with this concern.
It sounds like you must have checked your own containers to see if they comply with this FM Approval listing requirement. If so, I assume you found some that did not meet the requirements. I do know that some manufacturers do meet this requirement and therefore there are containers out there for clean recyclables and patient records waiting for shredding that do meet this requirement.
I would suggest you make it a condition with the shredding company to provide FM Approval listed containers if they continue to want your business.