Hazardous waste management at healthcare facilities
Hazardous waste is a waste with properties that make it dangerous or potentially harmful to human health or the environment. Under state and federal law, a waste is hazardous if it is specifically listed as a hazardous waste or if it exhibits a hazardous characteristic.
New rules effective Sept. 1
On Sept. 1, several changes to Wisconsin’s hazardous waste management rules took effect. The changes affect most healthcare facilities and reverse distributors that generate or handle hazardous waste in the state and are intended to streamline aspects of the rules while making them more protective of public health and the environment. The rule revisions implemented three major federal initiatives:
- Generator Improvement Rule;
- Pharmaceutical Rule (Subpart P); and
- Definition of Solid Waste Rule.
To the extent possible, the DNR adopted equivalent content and format of the federal regulations.
As defined by the U.S. Environmental Protection Agency, the list of hazardous wastes are:
- "F-listed" wastes that come from common industrial and manufacturing processes, including such spent solvents as xylene and acetone;
- "K-listed" wastes that come from specific industry processes; and
- "P- and U-listed wastes" are discarded and unused chemical products and formulations. Some drugs are P-listed acute hazardous waste, which means they pose a severe risk to human health and the environment. Some unused chemotherapy drugs are listed as P- or U- waste. Because of the increased hazards, more stringent standards apply to P-listed wastes and containers or packaging that held P-listed pharmaceuticals.
Characteristics of hazardous waste include ignitability, corrosivity, reactivity and toxicity. Other wastes that can also be hazardous include:
- waste alcohol, which may exhibit the hazardous waste characteristic of ignitability;
- aerosols, which may be ignitable hazardous waste because of the contents or the propellant used;
- mercury-containing wastes, such as vaccines preserved with thimerosal, which generally exhibit the toxicity characteristic;
- strong acids and bases, which are hazardous waste because of corrosivity; and
- picric acid or ethyl ether, which may exhibit the characteristic of reactivity.
For more information, see hazardous waste rules, ch. NR 661, Wis. Adm. Code.
Proper hazardous waste management at healthcare facilities
Hazardous waste can be a relatively small percentage of the waste generated by healthcare providers. However, hazardous waste must be managed appropriately. There are three steps to the proper management of hazardous waste.
- Make a waste determination. Identify which wastes are hazardous and why – are they listed or do they have one or more of the characteristics?
- Determine the generator classification. Count the hazardous waste generated by all of the different departments in the healthcare facility. The quantity and types of waste generated during each month determine the generator classification and the requirements that apply to your facility. For example, generating even small quantities of P-listed acute hazardous wastes can mean more stringent requirements.
- Manage hazardous waste according to the requirements, which are based on your facility's hazardous waste generator classification. The specific requirements for very small, small and large quantity generators are stated in Wisconsin hazardous waste rules, ch. NR 662, Wis. Adm. Code.
The three hazardous waste generator classifications are as follows:
- Very Small Quantity Generator (VSQG): generates 220 pounds or less per month non-acute hazardous waste and less than 2.2 pounds per month acute hazardous waste.
- Small Quantity Generator (SQG): generates between 220 pounds and 2,205 pounds per month non-acute hazardous waste and less than 2.2 pounds per month P-listed acute hazardous waste.
- Large Quantity Generator (LQG): generates 2,205 pounds per month or more non-acute hazardous waste or 2.2 pounds per month or more acute hazardous waste.
Large quantity and small quantity generators, very small quantity generators that choose to manifest their waste, and hazardous waste treatment and storage facilities must notify the DNR of their hazardous waste activity and obtain an EPA ID number.
To apply for an EPA ID number, you must file a Notification of Regulated Waste Activity (EPA Form 8700-12). For assistance with the form, or to submit completed applications, contact your DNR regional environmental program associate.
Used oil is an additional type of hazardous waste that healthcare facilities may generate. Used oil, including lubricating oil, penetrating oil and turbine oil, is regulated under ch. NR 679, Wis. Adm. Code. For more information, visit Managing universal waste in Wisconsin.
The following guidance document has more information on the requirements:
- Waste Determinations and Recordkeeping (WA-1152)
- Evaluating and Managing Pharmaceutical Waste (WA-1257) (under revision)
- Managing Chemotherapy Waste (WA-1258)
- Managing Empty Containers (WA-1256) (under revision)
- 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)