Hazardous Waste

"Hazardous waste" is a term with a specific legal meaning that applies to certain materials that have been generated as wastes from activities carried out at your veterinary facility. 

This section provides information on how to comply with hazardous waste regulations. The first step is to determine if the wastes you generate are hazardous. There is a logical sequence of steps that can be used for this determination.

If you generate hazardous waste, then you must follow specific rules for management and disposal of the waste. You may also have reporting and recordkeeping responsibilities, depending on which state you are located and the quantity of hazardous waste you generate.

Because hazardous waste rules can vary from state to state, a VetCA hazardous waste state locator has also been included in the section.

Finally, there is a discussion about a category of hazardous waste, termed Universal Waste, for which special rules exist to encourage recycling of common hazardous wastes such as fluorescent bulbs and batteries.

• 15 Most Common Hazardous Waste Violations and Problems Found at Hospitals (This summary is for human hospitals, however, veterinary facilities would be expected to have similar compliance issues.) Improper or lack of hazardous waste (HW) labeling (go to HW labeling). No or infrequent weekly inspections of HW storage/satellite areas (go to for inspections requirements). Open containers of HW (go to container sealing requirement). Improper disposal of chemotherapy drugs (go to hazardous waste determinations and see information for U-list waste). Failure to perform or improper hazardous waste determinations (go to hazardous waste determinations). No or inadequate HW manifests (go to hazardous waste manifest). Throwing HW down the drain. Improper management of mercury-containing wastes, including but not limited to, fluorescent light bulbs, mercury vapor lights, thermometers, sphygmomanometer, gastric tubes, thermostats, etc. (go to mercury in healthcare facilities) Improper management of expired pharmaceuticals, paints, etc. (go to pharmaceuticals in healthcare facilities) Lack of a contingency plan (go to emergency planning). Lack of or inadequate training of employees in HW management (go to personnel training). Failure to ensure that HW meets Land Disposal Restrictions (go to shipping wastes off-site). Failure to upgrade/close underground storage tanks (USTs) (go to UST inspection protocol). Malfunctioning leak detection systems. Improper consolidation of wastes from nearby facilities. Source: EPA Region 2.

  Hazardous Waste Determinations
• Managing Hazardous (RCRA) Wastes
  • Generator Status, EPA ID
  • Biennial Reports
  • Quantity Limits
  • Time Limits
  • Storage Requirements
  • Inspections
  • Emergency Planning
  • Personnel Training
  • Hazardous Waste Minimization
  • Shipping Waste Off-site
  • Hazardous Waste Manifest
  • Recordkeeping and Reporting
• State Hazardous Waste Regulations
• Universal Wastes
• State Universal Waste Regulations