Veterinary Compliance Assistance

Waste Reduction—Hazardous Waste

There are several good reasons to find ways to reduce the quantity of hazardous waste generated at healthcare facilities wherever possible. They include:

  • Potential for significant cost savings
  • Reducing the time and effort needed to comply with regulations
  • Reducing worker exposure and potential liability

This page covers regulatory considerations related to waste reduction, and lists examples of hazardous waste reduction methods that have been successfully implemented by healthcare facilities.  The More Resources section provides links to a selection of more detailed information.


Regulatory Considerations

The more waste your facility generates, the more stringent the rules that apply to you become. Reducing the quantity of wastes you generate can significantly ease your regulatory burden.

Here is a brief summary of the way a facility's regulatory responsibilities depend on the quantity of waste that it generates. You can find more information on the VetCA page on Managing Hazardous Wastes.

The quantity of hazardous waste that a facility generates every month determines its so-called generator status, which in turn relates to regulatory burden. EPA has established three categories of generators:

  • Conditionally-Exempt Small Quantity Generators (CE-SQG), who generate less than 100 kg of non-acute hazardous waste a month, less than 1 kg of acute hazardous waste a month (e.g. P-listed wastes such as arsenic trioxide) and less than 100 kg of residues or contaminated soil, waste, and other debris from the spill cleanup of acute hazardous waste;
  • Small Quantity Generators (SQG), who generate between 100 kg and 1000 kg of non-acute hazardous waste a month, less than 1 kg of acute hazardous waste a month, and less than 100 kg of spill residue from acute hazardous waste; and
  • Large Quantity Generators (LQG), who generate 1000 kg or more of non-acute hazardous waste a month, 1 kg or more of acute hazardous waste a month, and 100 kg or more of spill residue from acute hazardous waste.

The rules applying to hazardous waste generators appear in the Code of Federal Regulations, Chapter 40, Part 262. Here is a brief summary of which rules apply to which category:

  • A CE-SQG is exempt from the Part 262 hazardous waste regulations as long as it complies with the set of regulations described in Section 261.5.
  • An SQG must meet limited requirements in Part 262. These reduced requirements for SQGs are to ensure that while some tracking of and accountability for the waste is placed on the small quantity generator, the requirements are not so burdensome as to prevent compliance.
  • An LQG, of course, must meet the full set of Part 262 requirements.

(Note: Some states rules regarding generator status and requirements vary from federal regulations.  Use the Hazardous Waste State Resources Locator to check on the rules in your state.)

The waste reduction rules actually require most generators to take steps to reduce their wastes .  Under RCRA:

  • Small quantity generators (SQG) must make a good faith effort to minimize waste generation and to select the best available waste management method that they can afford.
  • Large quantity generators (LQG), on the other hand, are required to have a formal hazardous waste minimization program in place to reduce the volume and toxicity of waste generated to the degree economically practicable, and must select a currently available treatment, storage, or disposal method that minimizes present or future threats.

Please remember that when one signs a hazardous waste manifest, one is stating to EPA that one's facility has a hazardous waste minimization program. (Conditionally-exempt small quantity generators are exempt from this requirement.)


Getting Started

Experience has shown that healthcare facilities can reduce hazardous waste most effectively by instituting a formal program. This typically involves:

  • Organizing a team to work on waste reduction
  • Conducting an initial audit your facility to identity sources/quantities of hazardous materials and points of waste generation (There are free checklists available for this purpose from state agencies and non-government organizations.)
  • Developing an action plan
  • Implementing waste reduction
  • Monitoring progress (tracking hazardous waste generation by department and waste type)
  • Conducting worker training and education


Purchasing and Use

Most hazardous wastes shipped off-site were originally expensive chemicals or products.  Shipping these materials offsite as hazardous waste is like paying for them twice.  This double-cost can be reduced by implementing some procedures:

  • Establish a system to ensure that you only buy the amount needed of any chemical that will require hazardous waste disposal.  Avoid purchasing in bulk to get better unit-pricing since the disposal of unused material will negate any up-front savings.
  • Purchase less toxic materials and products.  There are many opportunities for substituting materials and products that are not subject to hazardous waste disposal regulations at the end of their life.  Examples include:
    • non-solvent paints (e.g., latex)
    • mercury-free products
    • pump dispensed products instead of aerosol can products
    • non-chromic acid products for cleaning glassware
    • non-hazardous reagent or fixative substitutes used in the laboratory
    • replacing ethylene oxide with other sterilization methods
    • non-isotopic reagents used for gene rearrangement studies
    • use less-toxic alternatives instead of high-level disinfectants like glutaraldehyde, formaldehyde, Bouin's solution, or formalin.
  • Inventory pharmaceutical and chemical stores frequently.  Implement first in – first out system to avoid generating outdated materials.
  • Purchase analytical devices and other equipment that operate with less or without hazardous reagents.  Examples include:
    • processors used in electron microscopy that decrease the amount of alcohol, osmium tetroxide, tannic acid, cacodylic acid, propylene oxide wastes, and
    • stainers that use less uranyl acetate and lead citrate.
  • Use single-dose, not multiple-dose vials of chemotherapy drugs. Don't purchase and prepare chemotherapy drugs in excess when pre-formulated, pre-mixed preparations are available.
  • Establish take-back contracts for solvents, reagents, fixatives and other chemicals that the supplier can recycle.
  • Contract for pest control rather than having your staff treat your buildings and grounds. Also, adopt an Integrated Pest Management (IPM) program that focuses on chemical-free management.


Segregation

Hazardous waste is much more expensive to manage and dispose of than common solid waste, or even regulated medical waste.  Add a little hazardous waste to a lot of what would otherwise be non-hazardous waste, and you have turned a small problem into a big one.

By properly segregating wastes, you can avoid having to pay premium prices needlessly. This may require:

  • Establishing an identification protocol and educating workers on identification of wastes

  • Clearly marking waste disposal containers

  • Posting signage to prevent misuse of containers, and conducting regular inspections of waste containers

  • Having proper hazardous waste cleanup equipment available (e.g., mercury spill kits), and cleaning up spills only with proper materials and equipment

Wastestream Identification Chart
This chart helps to categorize veterinary wastes.

Other potential mixtures of hazardous and non-hazardous waste to avoid whenever possible include

  • "mixed-waste" -- contains both radioactive and hazardous waste. As a result, both treatment and regulation are complex. Two different regulatory frameworks and three federal agencies are involved: EPA, the Nuclear Regulatory Commission (NRC), and the Department of Energy (DOE). These agencies have largely resolved the administrative, regulatory, and technical issues that have faced government and private sector mixed-waste generators. Mixed waste requires additional labeling and special disposal. Not all hazardous waste brokers are authorized to handle mixed waste.

  • "dual wastes" -- a combination of hazardous waste and regulated medical waste (infectious, potentially infectious, or sharps depending on state regulations). Examples include non-empty syringes or IV lines containing hazardous waste pharmaceuticals with needles attached. Additionally, if someone mistakenly disposes of hazardous waste into the RMW container, the entire container is now dual waste. Dual waste requires additional labeling and special disposal. Not all hazardous waste brokers are authorized to handle dual waste.


For more information, see Hazardous Waste Determinations/Mixtures.


Recycling

Recycling opportunities exist at healthcare facilities that can reduce the volume of hazardous waste sent off-site for disposal.  Examples include:

  • Alcohol and xylene distillation recovery units. These devices are capable of recovering up to 99% of used solvent.
  • Universal wastes including batteries, fluorescent lights, mercury-containing devices, and pesticides. Universal waste rules vary from state to state; check on your state's universal waste regulations.
  • Chemicals no longer in use can be offered to other hospitals or labs that may use them before they are disposed of.


More Resources

California Integrated Waste Management Board. Provides colorful posters (e.g., "Know Where to Throw" poster) and stickers to help coordinate and promote waste reduction efforts.

Best Management Practices for Hospital Waste. Prepared by Washington State Department of Ecology (Oct. 2005).  Presents a comprehensive department by department review of common wastes and best management practices.

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