Hazardous Waste Regulatory Update

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Hazardous Waste Regulatory Update

• Lisa Papetti, Environmental Engineer
• U.S EPA New England
• RCRA Compliance Unit
• 617-918-1756

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Things 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.

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Things to think about

• Greater than 1 kg or 2.2 lbs. of acutely
  hazardous waste makes you a Large Quantity
  Generator!!
• P-listed wastes acutely toxic

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Things to think about

• Use the Universal Waste Rule, where
• applicable.
• Check web pages and ask questions of
• regulatory agencies, trade groups, and
• professional societies.
• Always anticipate inspections, perform
• self-audits, and keep records.

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Most Common RCRA Violation in Healthcare

• Hazardous waste determinations
• Improper disposal, including chemotherapy waste
• Improper management of expired pharmaceuticals
• Open containers
• Unmarked/unlabeled containers
• Satellite accumulation
• Hazardous waste training
• Contingency plan
• Improper consolidation of waste from nearby
  facilities
• Note Dont forget contractors and consultants

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Locations Where Wastes Can Be Found

• Laboratories Operating rooms
• Nursing units Haz. waste areas
• Construction Satellite acc. areas
• Laundry Dental clinics
• Maintenance X-rays units
• Pharmacy Morgue

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Typical Hospital Hazardous Waste

• Mercury and mercury-containing items
• Includes whole items and spill residue
• Photographic/X-Ray fixer solutions Silver
  recovered from fixer, if not recycled

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Typical Hospital Hazardous Waste

• X-Ray Film containing silver or other metals
• Ethanol and formaldehyde/ethanol solutions
• Spent, off-spec, or excess laboratory chemicals
  (solvents, acids, bases, etc.)
• Chemotherapy drugs

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Typical Hospital Hazardous Waste

• Waste, excess, and off-spec paints and cleaning
  products
• Fluorescent light bulbs, if not managed as
  Universal Wastes - Other types include
  high-intensity discharge (HID), neon, mercury
  vapor, high pressure sodium, and metal halide
  lamps
• Batteries, if not managed as Universal Wastes

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Typical Hospital Hazardous Waste

• Computers/monitors, circuit boards, and other
  lead-bearing electronics
• Lead aprons and shielding
• Includes all cathode ray tube (CRT) screens
• Compressed gases (generally, any that are
• ignitable)
• Waste pesticides, fungicides, etc.

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Specific Hospital HazardousWastes

• Cerrobend
• X-ray shielding putty used to protect patients
  from damage to adjacent healthy tissue during
  irradiation of tumors and other confined areas
• Contains Lead and Cadmium
• Discarded material and shavings can be
  characteristic toxic HW when disposed

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Specific Hospital HazardousWastes

• Chemotherapy Drugs
• Several chemotherapy drugs (antineoplastics)
  are listed in 40 CFR 261.33(f) (U-listed HW)
• Listing includes discarded commercial
  chemical products, off-specification
  species,container residues, and spill residues

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Specific Hospital HazardousWastes

• IV BAGS AND ASSOCIATED EQUIPMENT
• Empty bags and equipment that are not acutely
  hazardous may be disposed as empty containers
• Bags and equipment with regulated material
  remaining must be managed as hazardous waste

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Specific Hospital HazardousWastes

• Some Examples
• chlorambucil (U035)
• cyclophosphamide (U058)
• daunomycin (U059)
• melphalan (U150)
• mitomycin C (U010)
• streptozotocin (U206)
• uracil mustard (U237)
• - arsenic trioxide (P012!!!)

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Specific Hospital HazardousWastes

• Mercury Containing Devices Products In Patient
  Rooms
• Temperature Measurement
• Blood Pressure
• Nursing Incubators
• Room Temperature Controllers
• Batteries

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Specific Hospital HazardousWastes

• Mercury Containing Devices Products In Storage
  Maintenance Rooms
• Antifouling agents
• Cleaning Chemicals
• Degreasers

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Specific Hospital HazardousWastes

• Mercury Containing Devices Products In Storage
  Maintenance Rooms
• Preservatives
• Solvents
• Outdated mercury-containing equipment
• Paints

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Specific Hospital HazardousWastes

• Mercury Containing Devices Products In
  Treatment Surgery Rooms
• Merthiolate
• Mercury Nitrate
• Mercury Iodide
• Mercurochrome
• Thimerosal

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Specific Hospital HazardousWastes

• Mercury Containing Devices Products in
  Treatment Surgery Rooms
• Esophageal Dilators
• Cantor Tubes
• Miller Abbot Tubes
• Feeding Tubes
• Dental Amalgam

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Specific Hospital HazardousWastes

• Sodium Azide P105
• Also found in Enterococcus agars
• Listed in 40 CFR 261.33(e) (P-listed HW)
• Listing includes discarded commercial chemical
  products, off-specification species, container
  residues, and spill residues

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Specific Hospital HazardousWastes

• Picric Acid
• 2,4,6-trinitrophenol, picronitric acid, melinite
• Sometimes used in histology labs
• A component of Bouins Solution tissue
• preservative
• Dry picric acid is explosive and disposal is very
  costly and disruptive

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EPA New Englands Most Recent Enforcement Action

• Veterans Administration-New England
  Healthcare System
• White River Junction, VT
• Total Penalty 372,254

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EPA New Englands Most Recent Enforcement Action

• Violations
• Failure to conduct waste determination
• Failure to have fire suppression equipment
• Failure to label
• Failure to close containers
• Failure to date containers
• Unauthorized treatment and disposal
• Failure to minimize potential for release
• Failure to conduct hazardous waste training
• Universal Waste dating
• Failure to separate incompatibles

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EPA New England Compliance Assistance

• Janet Bowen
• Bowen.janet_at_epa.gov
• 617-918-1795
• www.epa.gov/region1/healthcare