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Hazardous Waste Hazardous Waste Regulatory UpdateRegulatory Update
Lisa Papetti, Environmental Lisa Papetti, Environmental EngineerEngineerU.S EPA – New EnglandU.S EPA – New EnglandRCRA Compliance UnitRCRA Compliance Unit617-918-1756617-918-1756
Things to think aboutThings to think about
Most small to mid-sized hospitals should be
operating as at least Small Quantity Generators. However, the proper category can only be confirmed through a full chemical and waste inventory from cradle
to grave.
Waste identification is critical for all areas of the hospital -- train technicians in waste determination and satellite storage.
Things to think aboutThings to think about
Greater than 1 kg or 2.2 lbs. of Greater than 1 kg or 2.2 lbs. of acutely hazardous waste makes acutely hazardous waste makes you a Large Quantity Generator!!you a Large Quantity Generator!!
P-listed wastes = acutely toxicP-listed wastes = acutely toxic
Things to think aboutThings to think about
Use the Universal Waste Rule, whereapplicable.
Check web pages and ask questions ofregulatory agencies, trade groups, andprofessional societies.
Always anticipate inspections, performself-audits, and keep records.
Most Common RCRA Most Common RCRA Violation in HealthcareViolation in HealthcareHazardous waste determinationsHazardous waste determinationsImproper disposal, including chemotherapy wasteImproper disposal, including chemotherapy wasteImproper management of expired pharmaceuticalsImproper management of expired pharmaceuticalsOpen containersOpen containersUnmarked/unlabeled containersUnmarked/unlabeled containersSatellite accumulationSatellite accumulationHazardous waste trainingHazardous waste trainingContingency planContingency planImproper consolidation of waste from nearby Improper consolidation of waste from nearby
facilitiesfacilities
Note: Don’t forget contractors and consultantsNote: Don’t forget contractors and consultants
Locations Where Locations Where Wastes Can Be FoundWastes Can Be Found
Laboratories Operating roomsLaboratories Operating rooms
Nursing units Haz. waste areasNursing units Haz. waste areas
Construction Satellite acc. Construction Satellite acc. areas areas
Laundry Dental clinics Laundry Dental clinics
Maintenance X-rays units Maintenance X-rays units
Pharmacy MorguePharmacy Morgue
Typical Hospital Hazardous Typical Hospital Hazardous WasteWaste
Mercury and mercury-containing Mercury and mercury-containing items items
Includes whole items and spill Includes whole items and spill residue residue
Photographic/X-Ray fixer solutions Photographic/X-Ray fixer solutions Silver recovered from fixer, if not Silver recovered from fixer, if not recycledrecycled
Typical Hospital Hazardous Typical Hospital Hazardous WasteWaste
X-Ray Film containing silver or other X-Ray Film containing silver or other metalsmetals
Ethanol and formaldehyde/ethanol Ethanol and formaldehyde/ethanol solutionssolutions
Spent, off-spec, or excess laboratory Spent, off-spec, or excess laboratory chemicals (solvents, acids, bases, chemicals (solvents, acids, bases, etc.)etc.)
Chemotherapy drugsChemotherapy drugs
Typical Hospital Hazardous Typical Hospital Hazardous WasteWaste
Waste, excess, and off-spec paints and Waste, excess, and off-spec paints and cleaning productscleaning products
Fluorescent light bulbs, if not managed Fluorescent light bulbs, if not managed as Universal Wastes - Other types as Universal Wastes - Other types include high-intensity discharge (HID), include high-intensity discharge (HID), neon, mercury vapor, high pressure neon, mercury vapor, high pressure sodium, and metal halide lampssodium, and metal halide lamps
Batteries, if not managed as Universal Batteries, if not managed as Universal WastesWastes
Typical Hospital Hazardous Typical Hospital Hazardous WasteWaste
Computers/monitors, circuit boards, and Computers/monitors, circuit boards, and other lead-bearing electronicsother lead-bearing electronics
Lead aprons and shieldingLead aprons and shielding
Includes all cathode ray tube (CRT) Includes all cathode ray tube (CRT) screensscreens
Compressed gases (generally, any that Compressed gases (generally, any that areare
ignitable)ignitable)
Waste pesticides, fungicides, etc.Waste pesticides, fungicides, etc.
Specific Hospital HazardousSpecific Hospital HazardousWastesWastes
CerrobendCerrobend
X-ray shielding putty used to protect X-ray shielding putty used to protect patients from damage to adjacent patients from damage to adjacent healthy tissue during irradiation of healthy tissue during irradiation of tumors and other confined areastumors and other confined areas
Contains Lead and CadmiumContains Lead and Cadmium
Discarded material and shavings can Discarded material and shavings can be characteristic toxic HW when be characteristic toxic HW when disposeddisposed
Specific Hospital Specific Hospital HazardousHazardousWastesWastesChemotherapy DrugsChemotherapy Drugs
Several chemotherapy drugs Several chemotherapy drugs (antineoplastics) are listed in 40 CFR (antineoplastics) are listed in 40 CFR 261.33(f) (U-listed HW)261.33(f) (U-listed HW)
Listing includes: discarded Listing includes: discarded commercial chemical products, off-commercial chemical products, off-specification species,container specification species,container residues, and spill residuesresidues, and spill residues
Specific Hospital Specific Hospital HazardousHazardousWastesWastesIV BAGS AND ASSOCIATED IV BAGS AND ASSOCIATED
EQUIPMENTEQUIPMENT
Empty bags and equipment that are Empty bags and equipment that are not acutely hazardous may be not acutely hazardous may be disposed as empty containersdisposed as empty containers
Bags and equipment with regulated Bags and equipment with regulated material remaining must be material remaining must be managed as hazardous waste managed as hazardous waste
Specific Hospital Specific Hospital HazardousHazardousWastesWastes Some Examples:Some Examples:
– – chlorambucil (U035)chlorambucil (U035)– – cyclophosphamide (U058)cyclophosphamide (U058)– – daunomycin (U059)daunomycin (U059)– – melphalan (U150)melphalan (U150)– – mitomycin C (U010)mitomycin C (U010)– – streptozotocin (U206)streptozotocin (U206)– – uracil mustard (U237)uracil mustard (U237)- arsenic trioxide (P012!!!)- arsenic trioxide (P012!!!)
Specific Hospital Specific Hospital HazardousHazardousWastesWastes Mercury Containing Devices & Mercury Containing Devices &
Products In Patient RoomsProducts In Patient Rooms
Temperature MeasurementTemperature Measurement
Blood PressureBlood Pressure
Nursing IncubatorsNursing Incubators
Room Temperature ControllersRoom Temperature Controllers
BatteriesBatteries
Specific Hospital Specific Hospital HazardousHazardousWastesWastes Mercury Containing Devices & Mercury Containing Devices &
Products In Storage & Products In Storage & Maintenance RoomsMaintenance Rooms
Antifouling agentsAntifouling agents
Cleaning ChemicalsCleaning Chemicals
DegreasersDegreasers
Specific Hospital Specific Hospital HazardousHazardousWastesWastes Mercury Containing Devices & Mercury Containing Devices &
Products In Storage & Maintenance Products In Storage & Maintenance RoomsRooms
PreservativesPreservatives
SolventsSolvents
Outdated mercury-containing Outdated mercury-containing equipmentequipment
PaintsPaints
Specific Hospital Specific Hospital HazardousHazardousWastesWastes Mercury Containing Devices & Mercury Containing Devices &
Products In Treatment & Surgery Products In Treatment & Surgery RoomsRooms
MerthiolateMerthiolate
Mercury NitrateMercury Nitrate
Mercury IodideMercury Iodide
MercurochromeMercurochrome
ThimerosalThimerosal
Specific Hospital Specific Hospital HazardousHazardousWastesWastes Mercury Containing Devices & Mercury Containing Devices &
Products in Treatment & Surgery Products in Treatment & Surgery RoomsRooms
Esophageal DilatorsEsophageal Dilators
Cantor TubesCantor Tubes
Miller Abbot TubesMiller Abbot Tubes
Feeding TubesFeeding Tubes
Dental AmalgamDental Amalgam
Specific Hospital Specific Hospital HazardousHazardousWastesWastesSodium Azide – P105Sodium Azide – P105
Also found in Enterococcus agarsAlso found in Enterococcus agars
Listed in 40 CFR 261.33(e) (P-listed HW)Listed in 40 CFR 261.33(e) (P-listed HW)
Listing includes: discarded commercial Listing includes: discarded commercial chemical products, off-specification chemical products, off-specification species, container residues, and spill species, container residues, and spill residuesresidues
Specific Hospital HazardousSpecific Hospital HazardousWastesWastes
Picric AcidPicric Acid
2,4,6-trinitrophenol, picronitric acid, 2,4,6-trinitrophenol, picronitric acid, melinitemelinite
Sometimes used in histology labsSometimes used in histology labs
A component of Bouin’s Solution– tissueA component of Bouin’s Solution– tissue
preservativepreservative
Dry picric acid is explosive and disposal Dry picric acid is explosive and disposal is very costly and disruptiveis very costly and disruptive
EPA New England’s Most EPA New England’s Most Recent Enforcement Recent Enforcement ActionAction Veterans Administration-New Veterans Administration-New
England England Healthcare Healthcare SystemSystem
White River Junction, VTWhite River Junction, VT
Total Penalty = $372,254Total Penalty = $372,254
EPA New England’s Most EPA New England’s Most Recent Enforcement Recent Enforcement ActionActionViolationsViolationsFailure to conduct waste determinationFailure to conduct waste determinationFailure to have fire suppression equipmentFailure to have fire suppression equipmentFailure to labelFailure to labelFailure to close containersFailure to close containersFailure to date containersFailure to date containersUnauthorized treatment and disposalUnauthorized treatment and disposalFailure to minimize potential for releaseFailure to minimize potential for releaseFailure to conduct hazardous waste trainingFailure to conduct hazardous waste trainingUniversal Waste datingUniversal Waste datingFailure to separate incompatiblesFailure to separate incompatibles
EPA –New England EPA –New England Compliance AssistanceCompliance Assistance
Janet BowenJanet Bowen
[email protected]@epa.gov
617-918-1795617-918-1795
www.epa.gov/region1/healthcarewww.epa.gov/region1/healthcare