Hazardous waste management at healthcare facilities
Healthcare providers generate many types of wastes, including pharmaceutical, medical, infectious, solid and hazardous waste. While hazardous waste can be a relatively small percentage of the waste generated by healthcare providers, it must be identified and managed appropriately.
Hazardous wastes potentially generated at healthcare facilities include:
- Hazardous waste pharmaceuticals
- Discarded and unused chemical products and formulations
- Waste alcohols
- Mercury-containing wastes, such as vaccines preserved with thimerosal
- Strong acids and bases
- Picric acid or ethyl ether
- Leaded aprons
- Universal wastes and used oil
Health Care Initiative Fact Sheet: Table of Common Wastes in Health Care (WA-1259) provides guidance on common healthcare wastes.
Determining generator status
The quantity and types of waste generated each month determines a facility’s generator classification or status and the requirements that apply.
If the facility is a small quantity generator or large quantity generator, the facility will be required to notify the Department of Natural Resources and operate under the Subchapter P pharmaceutical rules. Under Subchapter P requirements, the facility’s generator classification may potentially be reduced. This reduced generator classification would be part of the notification to the DNR.
- Information on generator classifications, notification to the DNR, manifesting and EPA ID requirements
To determine generator status:
- Count all hazardous waste generated or stored by all departments in the healthcare facility, including pharmaceutical waste, and determine generator classification.
- Count all non-pharmaceutical hazardous waste and determine the generator classification.
A large quantity generator may potentially reduce to a small quantity generator or a very small quantity generator classification and manage its non-pharmaceutical hazardous waste under this new generator classification. A small quantity generator may potentially reduce to a very small quantity generator classification and manage its non-pharmaceutical hazardous waste under this new generator classification.
The pharmaceutical waste is managed under Subchapter P requirements.
Limitations on sewering pharmaceutical waste
In 2020, the Pharmaceutical Rule was adopted into Wisconsin Administrative Code. To the extent possible, the content and format follow federal regulations.
- Subchapter P of ch. NR 666, Wis. Adm. Code
- U.S. Environmental Protection Agency resources on the federal Pharmaceutical Rule
Under s. NR 666.505, Wis. Adm. Code., all healthcare facilities are banned from discharging hazardous waste pharmaceuticals into a sewer system (i.e., disposing of them down a sink or toilet drain). The DNR s recommends all facilities avoid sewering any pharmaceuticals, regardless of their solid or hazardous waste classification.
- Pharmaceutical waste at non-hospital health care facilities (WA-1214) (under revision)
- Quick Reference Guide for Hazardous Waste Generators (WA-1821)
- Waste Determinations and Recordkeeping (WA-1152)
- Managing Chemotherapy Waste (WA-1258)
- Self-Audit Checklist (LQGs) (WA-1263)
- Self-Audit Checklist (SQGs) (WA-1264)
- Self-Audit Checklist (VSQGs) (WA-1265)
- Table of Common Wastes in Healthcare (WA-1259)