News > Med Waste Application

Letter to the Blount County Commission

Dear Mr. Harvey,

This letter is to express opposition to Harvest Medical Waste Disposal, LLC’s application for installation of a medical waste processing facility along the banks of Gurley Creek at the community of Remlap in Blount County, Alabama.

Harvest Medical Waste Disposal’s application reads that they intend to accept “nonhazardous medical waste” for processing through a Clean Waste System 400 machine to render said waste nonhazardous. When discussing this process with local citizenry the question that most rational people ask is why would a prudent person spend a million plus dollars in building and machinery in order to convert nonhazardous medical waste into nonhazardous medical waste? Admittedly, on first read the question rings of Churchill’s riddle wrapped in an enigma. However, upon close review of OSHA, EPA and ADEM’s definition of hazardous waste one discovers that the “hazardous waste” term only applies to substances that are flammable, corrosive, reactive or toxic. As Harvest Medical Waste is well aware, the Clean Waste System 400 is not designed to handle hazardous waste as thus defined. Therefore, Harvest Waste’s application is both deceptive, disingenuous, and lacking in the details necessary for a conscientious and thorough review. It fails to clearly declare what they will be processing and only states what they will not be processing; that being substances that are not flammable, corrosive, reactive or toxic. They could have just as easily stated they intended to process non-nuclear waste materials.

What Harvest Medical Waste’s application craftily fails to divulge is that they intend to process a waste far more threatening to both people and the environment: That being infectious and biohazardous medical waste. A fact confirmed by Harvest Medical Waste Disposal’s Chairman and Corporate Officer David Dyer in an interview of 17 July with ABC 33/40 in which he called the material “infectious”. Infectious/biohazardous medical waste is defined as any solid or liquid waste contaminated with infectious or potentially infectious agents, substances, or other materials that pose a significant health risk to humans or the environment by potentially spreading infection or disease. The EPA and OSHA under their Blood-borne Pathogens Standard uses the term “regulated waste” to refer to biohazardous waste. Examples include:

• Blood Soaked Materials: Gauze, bandages, or personal protective equipment saturated with human or animal blood.
• Contaminated items that would release blood or other potentially infectious materials in a liquid or semi-liquid state if compressed.
• Sharps: Used needles, syringes, scalpel blades or other other used instruments that could puncture skin.
• Pathological Waste: Tissues or bodily fluids removed during medical procedures.
• Microbiological Waste: Culture dishes, test tubes, and other lab materials containing blood, body fluids or other potentially infectious materials that might harbor pathogens.

Due to the hazards involved in even handling these materials, the EPA, OSHA and ADEM mandate that the items detailed must be shipped in leak-proof, puncture resistant containers labeled with the universal biohazard symbol. Containers are generally red and are shown in photographs and videos of the Clean Waste System 400 in operation. Harvest Waste has requested from BCC approval for an procedure using ozone to disinfect biohazardous waste that is currently not even approved by ADEM for used in Alabama. In Alabama, the only approved methods for processing infectious medical waste are incineration and steam sterilization (autoclaving); which must be performed to render the waste non-recognizable and suitable for disposal. Chemical disinfection is also an acceptable treatment method, but after treatment additional steps like shredding, grinding, or other processes may be necessary to ensure the waste is no longer generally recognizable as medical waste. All are explicitly outlined in ADEM’s administrative code. As ozone treatment is currently not an approved method Harvest Waste will need to acquire approval of the process from ADEM before proceeding. Steps for obtaining approval requires completion of the following steps and I strongly suggest the BCC review ADEM Form 323 (attached) for thoroughness of this review and information you may want to consider when rendering your decision:

• Submit a formal request to ADEM's Land Division for approval of an alternative treatment method.
• Provide documentation showing the effectiveness of the ozone treatment technology, including its ability to decontaminate waste and destroy pathogens.
• Explain how the proposed method will protect public health and the environment, including details on the storage, transportation, and disposal of treated waste.
• Submit a completed Form 323 (Copy Attached) to initiate the review process with ADEM.

Additional items of concern and submittal information that I would hope the BCC will require from Harvest Waste prior to voting on their application:

• Submittal of a Site Safety Plan to include an Emergency Evacuation Plan
• Answer to what environmental, occupational, and/or public health hazards would be associated with a malfunction of the treatment process?
• If the treatment process includes the use of water, steam, or other liquid or gases, how will this waste discharge be handled?
• What training will the waste transporters, equipment operators and site workers receive and what frequency will update training be provided?
• Will there be a Site Safety Officer present while work is being performed to confirm and document compliance with all OSHA, EPA and ADEM rules and regulations?
• As Remlap is currently under the watch of a volunteer fire department that does not have the extensive training or equipment necessary to deal with a biohazards accident, what emergency measures would be required in the event of an accident, biohazard spill or malfunction? Should there be a vehicular accident at the delivery site involving biohazardous waste or a spill of the same on facility grounds, properly trained and equipped response personnel would have to travel at protracted delay from either Birmingham or Huntsville to clean up the spill. A delay that could potentially endanger the community as well as the environment.

In closing, drawing from the evidence presented above and coupled with the comprehensive analysis put forth by Dr. Gene Gousoulin in his letter to you of 15 August 2025, it appears quite clear that the risks to the community, as well as the environment with its protected and endangered species, far out weigh the few pieces of silver received from a biohazardous medical waste processing facility. Consequently, I strongly encourage the BCC to concur and vote NO to Harvest Medical Waste’s application.

Respectfully,
Michael Wesson, Remlap