Veterinary Compliance Assistance

American Veterinary Medical Association Guidelines for Practice or Workplace

Hazardous Materials—Overview

This website provides comprehensive information on how to handle hazardous materials from the point at which they enter to the point at which they exit your facility.

It is important to understand the difference between the general term "hazardous materials" and the more specific term "hazardous wastes".

  • "Hazardous materials" generally applies to certain raw materials or products, purchased from outside suppliers, that are stored and used at your facility.
  • "Hazardous wastes" is a term with a specific legal meaning that applies to certain materials that have been generated as wastes from processes carried out at your facility. 

This page provides some basic background information on the rules -- where they come from, what their purpose is, and who enforces them.  You will also find links to additional pages with more detailed discussions of specific hazardous materials commonly found in veterinary facilities, and to information on specific management issues.

What is a hazardous material?

In general terms, materials are designated as "hazardous materials" when they pose a significant risk to people or property.  The specific definitions depend on the agencies that write the rules.

Hazardous materials are of particular concern for:

Worker Health and Safety

The federal Occupational Safety and Health Agency (OSHA), and its counterpart agencies at the state level, are responsible for developing and enforcing the rules for hazardous materials that relate to worker health and safety issues.

The rules cover two main topics:

  • Determining whether a particular material poses a risk to workers
  • Informing workers when they need to take appropriate precautions

A material's manufacturer (or the importer, if it is manufactured in another country) is responsible for determining whether or not a material is hazardous from a worker safety standpoint.  OSHA provides detailed guidance for how this determination is to be carried out.

If a material is determined to be hazardous, the manufacturer or importer must provide a Safety Data Sheet [SDS and formally known as Material Safety Data Sheet (MSDS)] to its customers.  Any company that uses these chemicals in the workplace must communicate information on the hazards and provide appropriate training to any worker who might be affected by the material.


The federal Department of Transportation and its state counterparts write the rules for determining whether or not a material is hazardous from a transportation safety standpoint.  The determination generally involves a somewhat different set of criteria from worker health and safety concerns.

The Federal Motor Carrier Safety Administration's page on complying with Federal Hazardous Materials Regulations contains descriptions of what types of materials are considered hazardous under federal transportation regulations, and summarizes the responsibilities of transporters that carry those materials.

More information on hazardous materials

The VetCA website provides specific information on the following common hazardous materials in veterinary facilities:

You can also find guidance for managing hazardous materials onsite covering the following topics:

What is a hazardous waste?

The term "hazardous waste" is reserved for materials that meet very specific criteria spelled out in the federal Resource Conservation and Recovery Act (RCRA) and the regulations associated with it.

Hazardous waste regulations are developed and enforced by the Environmental Protection Agency (EPA), and by state and local environmental agencies.

Any facility that generates hazardous wastes is subject to detailed rules concerning topics such as

  • How the wastes must be stored on site
  • How long they may be stored
  • Who is allowed to transport and receive them
  • What kinds of records have to be maintained

The basic regulatory approach taken by RCRA is to separate the responsibilities of those who generate hazardous waste from those who treat and dispose of it.  It is easy to qualify as a generator of hazardous waste, and much harder to qualify as a "treatment, storage, and disposal", or "TSD" site.

If your veterinary facility generates hazardous waste, you are required to obtain an EPA Identification Number.  (You may be exempt in some states if the quantity you generate is small enough.)  EPA provides a useful booklet with details on the procedure to follow.

More information on hazardous waste

More information on hazardous waste management and disposal is available on the VetCA website, covering the following topics:

How does a material become a hazardous waste?

There are two primary ways that a waste material can become classified as a hazardous waste, subject to the RCRA requirements:

  1. Listed wastes:  Wastes from certain industrial processes are automatically classified as hazardous.  Each waste of this type is given a code number.  The full list of hazardous waste codes appears in the Code of Federal Regulations, 40 CFR 261.

  2. Characteristic wastes:  Wastes that do not appear on the CFR lists may nevertheless be classified as hazardous if they have one of four properties:

    • Ignitability
    • Corrosivity
    • Reactivity
    • Toxicity

In addition, materials can acquire hazardous waste status if they are mixed with, or contaminated with, or are derived from, other wastes that are themselves hazardous.

The generator of the waste is responsible for determining if the waste is hazardous.  The rules can get complicated.

In addition to determining whether a waste is hazardous, you will need to know how each particular waste is classified.  The rules that apply to your facility will depend on how much waste, and what type of waste, you generate.  Misclassifications can (and do) lead to citations and penalties.

The Hazardous Waste Determination page provides more detailed information on this critical topic.


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