Veterinary Compliance Assistance

Reducing Hazardous Materials

The quantity of hazardous waste generated at a healthcare facility is related to the quantity of hazardous materials purchased.  Also, it is affected by how those materials are used.  This section of VetCA lists pollution prevention (P2) ideas that can impact the quantities of hazardous materials and wastes at your facility.  They are categorized into purchasing procedures and raw material use and handling suggestions.


Purchasing/Receiving/Inventory

Purchasing Procedures

Good purchasing procedures will identify and reduce potential waste before it enters your business:

  • Material Review:  Evaluate the materials used by your business, look for less- or non-toxic substitutes. Purchase those that:
    • Are the least toxic and least costly-to-handle products that work
    • Contain higher-purity raw materials
    • Contain noncorrosive raw materials
  • Container Review:  Consider your intended use and standard operating practices, and purchase materials in the size and type of container which will minimize material losses and costs:
    • Buy in smaller containers if transfer from large to smaller containers is generally required before use. There will be less potential for spills, material evaporation, contamination from unused material returned to the original container, and expiration of unused materials.
    • Buy in pre-weighed packages to reduce handling losses (if applicable)
    • Buy materials used often in larger containers. Buying in bulk can reduce the number of containers requiring disposal, especially if refillable containers are used.
    • Buy containers that are wider than tall. They have less "cling," resulting in greater material use and less container residue.
    • Buy containers which minimize disposal problems (e.g.  fillable pressurized spray cans in place of single use aerosol spray cans)
  • Chemical Samples:  Establish a policy for accepting samples so they do not accumulate and add to waste disposal load:
    • Designate one person responsible for acceptance of chemical samples
    • Test on a bench scale basis to reduce volume needing disposal
    • Require that suppliers accept back the unused samples they provide
  • Equipment Evaluation:  Prior to purchase, ensure that new equipment:
    • Generates the least amount of hazardous waste possible
    • Can be easily maintained. Preventive maintenance can save 3-4 times the equipment cost by reducing breakdowns and malfunctions.
    • Complies with applicable environmental and safety standards. Check with regulating agencies.  Use suppliers knowledgeable in these areas.
  • Centralized Purchasing:  Channel material purchases through a central person or department to:
    • Eliminate unnecessary purchases
    • Ensure that all waste reduction purchasing policies are followed
  • SDSs:  Make certain that distributors supply you with Safety Data Sheets for all purchased hazardous materials in order to:
    • Know material hazards, proper safety precautions, and handling and emergency response procedures
    • Comply with OSHA worker and EPA community Right-to-Know laws
    • Help you determine the nature of your wastes
  • Evaluate Facility Design:  Consider waste reduction when planning expansions, and evaluate potential building purchases/leases to determine whether the building design is amenable to waste reduction.  Make sure that:
    • Hazardous materials storage areas exist or can be easily installed
    • Space and utilities are available for proper recycling and treatment needs, etc.

Receiving Procedures

Good receiving procedures will prevent acceptance of shipments which are off-spec, incorrect, or improperly packaged, and reduce unnecessary waste generation, returns, and spills:

  • Control all incoming materials by:
    • Receiving them in a specific, designated area
    • Designing the area to prevent and control release of materials
  • Train employees receiving shipments on proper handling of package to prevent property losses, injuries, and costly waste disposal
  • Inspect shipments prior to acceptance:
    • Check for opened, damaged, or leaking containers
    • Check expiration dates and ensure proper labeling
    • Test for off-spec materials
    • Obtain SDS if product is new. Employers must maintain a SDS for any hazardous chemical stored or used in the work place.
  • Use quality suppliers (quality and reliability are as important as cost):
    • Supplier should deliver goods intact and according to your specifications
    • Check the track record of your supplier with other companies or references
  • Review or create purchase agreements:
    • Specify terms and conditions for receiving material orders
    • Include provisions which allow you to inspect materials prior to acceptance
    • Address responsibility in the event of a release. Specify terms under which each party is responsible for cleanup or other expenses incurred to control an incident.
  • Document agreements to ensure that specified procedures are followed. Remember, suppliers want your business and should be willing to ship on your terms.  If not, try to find another supplier or change products.
  • Comply with Emergency Planning and Community Right-To-Know Act (EPCRA) Section 311 requirements. Healthcare facilities must submit copies of hazardous chemical safety data sheets (SDS) or a list of SDS chemicals to the LEPC, SERC, and local fire department).

Inventory Control Procedures

Inventory control procedures are important for reducing management costs and potential hazards associated with excess, off-spec, and expired materials:

  • Set Inventory Limits:  Set according to emergency response capacity. How large an inventory can your spill/emergency response equipment and personnel handle? The more inventory of hazardous materials, the greater the chance for overcrowding storage areas and resulting safety problems such as spills, exposures and fires.
  • Minimize Inventory:  Buy and stock only what you need. Costs associated with hazard risks, hazardous materials fees, and disposal of excess or expired stock may outweigh the costs of waiting for resupply shipments:
    • Carefully consider large purchases (especially if only to get a discount)
    • Time deliveries to coincide with production needs ( "just-in-time" system)
  • Track Materials:  Effectively track the shelf-life of time-sensitive materials and use the oldest stock first ("first-in, first-out"):
    • Label, date, and inspect new materials as they are received
    • Keep records of dates of receipt and usage to help reduce overstock and material degradation
    • Inventory raw materials at least once per year
    • Consider computerizing your tracking system
  • Storage Conditions:  Maintain proper temperature, humidity, etc.  to reduce material degradation
  • Reduce the Number of Similar Products:  If you use several types of solvents, could fewer do the job? Reducing the number of solvents would improve inventory control and enhance recycling opportunities.
    • Look for substitutes with longer shelf lives
    • Use waste exchanges for overstock, off-spec, or expired materials

Raw Material Use and Handling

More efficient utilization of raw materials will reduce losses and unnecessary waste generation:

  • Ensure that employees:
    • Use supplies only for their intended purpose
    • Use only the amount necessary
    • Have access to SDS as required by OSHA rules.
  • Keep frequently used hazardous materials near the site of use to minimize spills/accidents
  • Provide transfer methods which prevent spills and quality problems
    • Pipelines for intermediate transfer
    • Gravity spigot or pump to dispense bulk liquid materials
    • A spout and funnel for transferring liquids to different containers
    • Proper connection/disconnection of hoses and lines
  • Control access to hazardous raw materials
    • Designate central personnel to distribute materials
    • Limit access to employees trained in hazardous materials handling and who understand the importance of first-in first-out policy
  • Keep records of when and why larger spills occurred in order to identify spill prevention opportunities and document related costs
  • Work with vendors to accept back excess, off-spec, or expired materials

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