EPA910-R-08-002 I November 2008
United States
Environmental Protection
Agency
A Guide to Hazardous Waste
Care Clinics
Office of Air, Waste and Toxics
United States Environmental Protection Agency, Region 10
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Disclaimer
This document was developed to provide information on hazardous waste management to out-
patient health care facilities operated by Tribes and/or the U. S. Indian Health Service, The information
provided may be useful to other facilities that generate hazardous waste. This document is an
outline of requirements. It is not intended to establish requirements or create rights for any party,
nor does it replace the RCRA regulations or statutory requirements. It does not identify all of the
requirements in the waste management regulations and should not be relied upon to determine full
compliance with the regulations. Please consult the actual regulations for additional information.
These regulations can be found on the RCRA web site afwww.epa.gov/lawsregs/laws/rcra.html.
For waste managed outside of a reservation, state rules would apply and may be more stringent
than the federal rules. In some cases a Tribe may have rules that apply on a specific reservation.
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Hazardous Waste
Health care facilities generate a wide variety of wastes.
Some of these wastes are regulated as hazardous waste
by federal law under the Resource Conservation and
Recovery Act (RCRA). This law requires waste generators
to determine whether any of their wastes are considered
hazardous waste. Once identified as a hazardous waste,
the waste must be handled in a manner that conforms to all
EPA regulations regarding hazardous waste (Title 40 of the
Code of Federal Regulations (CFR) Parts 260 through
279). To determine if your waste is regulated as a
hazardous waste you must answer six questions.
Is it a solid waste?
Only a "solid waste" can be a hazardous waste. The
regulation defines solid waste as any material that is
discarded by being either abandoned, inherently waste-
like, or recycled (by being applied to the ground, burned
for energy recovery, reclaimed or speculatively
accumulated). It can be a solid, liquid or contained gas.
For more details on this definition see 40 C.F.R. Parts 260
and 261
Is it excluded?
Certain wastes are excluded from the definitions of solid
waste or hazardous waste. For example, wastes being
recycled or reused (e.g. by being used as an ingredient in a
process to make a product or returned to the original
manufacturing process as a substitute for feedstock) may
be excluded. To determine if your waste is excluded refer
to the regulations at 40 CFR Part 261 Subpart E or contact
EPA.
Is it a listed waste?
There are four categories of hazardous waste. Each
category includes a list of specific wastes that are always
considered to be hazardous waste. The four categories
found in 40 C.F.R. Part 261 are described below:
F- listed - Includes certain listed wastes generated from
general production and maintenance processes.
Examples of these wastes from the healthcare
industry include but are not limited to acetone,
toluene, methanol, xylene, methylene chloride, and
carbon tetrachloride. These chemicals are usually
used in maintenance or laboratory activities.
K- listed - Includes certain listed wastes that are
generated from specific industrial processes.
Typically, these wastes are not generated at
healthcare facilities
P-listed - Includes certain listed chemical products that
are being discarded for a variety of reasons. These
wastes are considered 'acute hazardous waste'.
Some common P listed wastes that may be
generated in healthcare clinics appear in
Appendix A.
U-listed - Includes certain listed chemical products that
are being discarded for a variety of reasons but are
not 'acute hazardous waste'. Some common U
listed wastes that may be generated in healthcare
clinics appear in Appendix A.
Is it characteristic?
If a waste is not a listed hazardous waste, then the
generator must determine if it exhibits one of the four
hazardous waste characteristics described below.
Ignitability - In general, a waste that easily catches fire
(i.e. a liquid that is <24%alcohol with a flash point
less than 140°F). For example some degreasing
solvents are ignitable.
Corrosivity - In general, liquids with a pH <2 or >12.5,
or liquids that corrode steel at a faster rate than a
!4 inch per year at 55°C. Examples are muriatic
acid and caustic solutions.
Reactivity - In general, wastes that generate toxic
gases or are capable of exploding when exposed
to water. Wastes that, when heated under
confinement or exposed to a strong initiating
source, may ignite or explode. Wastes that
generate toxic levels of sulfide or cyanide gas
when exposed to pH between 2 and 12.5. Waste
that is a forbidden, class A or class B explosive
under DOT regulations found in 49 CFR.
Examples are sodium metal and dynamite.
Toxicity - In general, wastes that contain high enough
levels of one or more of the 40 toxic substances
identified in the regulation at 40 CFR Part 261.24
that, when exposed to water in the environment,
produce a leachate with toxic constituent
concentrations above the limits in the regulation.
Examples are heavy metals and some pesticides.
Is it a mixture?
A mixture of any hazardous and non-hazardous wastes
may be a hazardous waste. Proper disposal depends on
the type of hazardous waste in the mix.
Mixtures that contain listed hazardous waste in any amount
are alwaysconsidered listed hazardous waste.
A mixture that contains hazardous waste that has one of
the four characteristics of a hazardous waste but is not a
listed waste is considered hazardous waste only if the
mixture exhibits one or more of the hazardous waste
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Hazardous Waste
Generator Classification
characteristics. It is illegal to simply dilute a hazardous
waste for the purpose of removing a hazardous waste
characteristic.
Is it derived from a hazardous waste?
Residues that accumulate from waste treatment processes
for treatment of a listed hazardous waste are listed
hazardous waste. For example the residue from a
distillation unit used to reclaim listed hazardous waste
solvents is a listed hazardous waste.
If you determine that any of your wastes are hazardous
waste, then you are a "hazardous waste generator". If so,
you must determine how much hazardous waste you
generate in one month to determine your "generator
classification". Generator class is an EPA designation that
is based on the amount of hazardous waste your facility
has generated. It is used to determine the level of
regulation you are subject to. The three classifications are:
Conditionally-Exempt Small Quantity Generators
(CESQG)
Small Quantity Generators (SQG), and
Large Quantity Generators (LOG)
Health clinics operated on Tribal lands typically are
Conditionally-Exempt Small Quantity or Small Quantity
Generators. Both classifications limit the amount of
hazardous waste that may be accumulated on-site, require
identification of all hazardous wastes, and specify the
requirements for proper treatment or disposal of the
hazardous waste from your facility. A full explanation of
generator classification and how it applies to your clinic
may be found online in the EPA publication Resources for
Hazardous Waste Generators (see yellow box above).
This user friendly document allows the reader to easily
navigate the web-links to answer hazardous waste
questions about size and storage requirements.
Resources for Hazardous Waste Generators
www.epa.gov/epawaste/hazard/generation/index.htm
This table contains the specific quantity and time limits for each generator classification. It also identifies
management standards for each classification.
Note: The numbers at the bottom of each box are citations from federal regulations 40 C.F.R. Parts 261 and 262.
Quantity Limits
EPA ID Number
On-Site Accumulation
Quantity
Accumulation Time Limits
Storage Requirements
CESQGs
< 220 Ib/month
< 2.2 Ib/month of acute hazardous
waste
< 220 Ib/month of acute spill residue or
soil
§261.5(a) and (e)
Not required
§261.5
< 2,200 Ib
< 2.2 Ib acute
< 220 Ib of acute spill residue or soil
§§261.5(f)(2) and (g)(2)
None
§261.5
None
§261.5
SQGs
220 - 2,200 Ib/ month
< 2.2lb/month of acute hazardous
waste
< 220 Ib/month of acute spill residue or
soil
§262.34(d)
Required
§262.12
< 13,227 Ib (6,000 kg)
< 2.2 Ib acute
< 220 Ib of acute spill residue or soil
§262.34(d)
< 180 days or
< 270 days (if greater than 200 miles
fromTSD)
§§262.34(d), (e)and(f)
Basic requirements with technical
standards for tanks or containers
§§262.34(d)(2) and (3)
LQGs
> 2,200 Ib/month
> 2.2 Ib/month of acute hazardous
waste
> 220 Ib/month of acute spill residue or
soil
§262.34 and §261.5(e)
Required
§262.12
No limit
< 90 days
<180 days (if greater than 200 miles
from TSD)
§262.34(a)
Full compliance with requirements for
tanks, containers, drip pads, or
containment buildings
§262.34(a)
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Waste Accumulation
Transportation
If your clinic is a hazardous waste generator it is important
to understand the accumulation requirements that apply to
hazardous waste before it leaves your clinic. As seen in the
"Generator Standards" table above, which management
standards apply depends on how much hazardous waste
you generate. Hazardous waste may be accumulated
without a permit in designated accumulation areas. These
areas are subject to all applicable requirements (e.g.
containers of waste are labeled with the words "hazardous
waste" and an accumulation start date for when waste was
first placed in the container, and the area is inspected
weekly).
A generator may also manage waste in a satellite
accumulation area. This is an area at or near the point of
hazardous waste generation and under the control of the
operator of the process generating the hazardous wastes.
Hazardous wastes may be accumulated here until 55
gallons have been collected. Container labels must either
identify the contents or say "hazardous waste". Once you
have accumulated 55 gallons you may temporarily hold the
waste for 3 days before moving to your designated
accumulation area or shipping it offsite.
Accumulation Recommendations
Use high quality, resealable containers to prevent
spills, evaporative losses, and contamination; and
keep the lids/seals closed when not in use
Keep hazardous waste storage area aisles clear of
obstructions:
Allow elbow room to access all containers easily and
minimize spills
Space containers to allow inspection for corrosion
and leaks
Maintain clear, even surfaces on pathways used by
workers or equipment
Keep accumulation areas clean and well-lit
Stack containers no higher than recommended by
manufacturer, in a way which minimizes the potential
for tipping, tearing, puncture, or breakage
Don't stack equipment against containers
Make sure containers and shelving or storage areas
are earthquake safe
Insulate electrical circuitry and check frequently for
corrosion and potential sparking
Raise drums off floor to prevent corrosion from
concrete "sweating"
Provide secondary containment and maintain proper
distance between different materials
Install sloped concrete floors and curbs or berms for
spill containment in areas such as vehicle
maintenance
Cover outdoor waste accumulation areas to prevent
contamination of storm water
Secure waste accumulation areas to minimize liability
and hazards of intrusion or dumping
All facilities that generate hazardous waste must ensure
that any hazardous waste that is shipped off-site is sent to
an appropriate facility. Only a registered hazardous waste
transporter can transport hazardous wastes. Hazardous
waste cannot be shipped to landfills or incinerators that do
not have a permit for managing hazardous waste. The U.
S. Department of Transportation (USDOT) has
specifications that require some loads to be labeled and
shipped in a particular manner to ensure on-road safety.
Individual states determine the hazardous waste
management requirements outside of Indian Country, so
check with your state for local requirements.
LQGs and SQGs are required to ship hazardous waste to a
designated facility (e.g. a Treatment, Storage or Disposal
Facility (TSDF) that has a RCRA permit or an immediate
recycler). They must prepare a manifest for each shipment
of hazardous waste that leaves their facility. EPA has
developed a standard manifest form that must be used
nationwide. (For more information on obtaining this form
go to the EPA website.) The manifest allows for consistent
documentation of all hazardous waste shipments.
Manifests must include the name of the transporter, the
name of the designated facility receiving the shipment, your
EPA ID number, and a description of the waste based on
USDOT hazardous materials requirements such as proper
shipping name and hazard class. It also must include
quantities of waste shipped, the number and types of
containers used, and the hazardous waste codes that
describe the type of hazardous waste included in the
shipment.
For LQGs and SQGs, all paperwork that details the
transportation of hazardous waste from your facility must
be kept on-site for a minimum of 3 years. This includes a
copy of the manifest signed by the transporter, as well as a
copy of the manifest signed by the receiving designated
facility confirming receipt of the waste by the facility.
CESQGs are also encouraged to maintain accurate
records of off-site transportation but this is not required.
CESQGs must ensure their hazardous waste is delivered
to an appropriate disposal or treatment facility. If a
CESQG's hazardous waste is improperly disposed of in a
landfill that does not have an appropriate permit, then the
CESQG may lose its conditionally-exempt status.
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Examples of Health Care Clinic Hazardous Waste
Dental Amalgam
The constituent of concern in dental amalgam is mercury.
If a clinic is a LOG or SQG and the amalgam contains
mercury at or above the regulatory levels for characteristic
hazardous waste established in 40 C.F.R. Part 261.24 then
it must be managed as a hazardous waste in compliance
with all applicable hazardous waste regulations.
If the clinic is a CESQG, EPA strongly recommends that
waste amalgam be managed in an environmentally safe
manner. Although mercury is stable in the amalgam form,
improper disposal may cause the release of mercury into
the environment. If the amalgam is incinerated the high
temperatures may volatilize the mercury, releasing it into
the atmosphere. Since some municipal waste
management facilities incinerate, EPA strongly
recommends against throwing away amalgam with the
regular garbage. Some waste water treatment plants
incinerate the sludge resulting after treatment, so EPA
strongly recommends against washing amalgam down
the drain. Likewise, EPA strongly recommends against
cleaning amalgam filters in the sink.
EPA recommends that dental amalgam be recycled in
plastic covered containers labeled "Amalgam for
Recycling." Here are some questions that you may want
to ask the recycler before you give them your waste:
What kind of amalgam wastes do you accept? (Non-
contact, contact, traps, filters or sludge, etc.)
Do you provide packaging for storage or shipping ?
If you do not provide packaging, how should the waste
be packaged?
What waste can be packaged together?
Is disinfecting of amalgam waste required?
How should the waste be shipped to your facility?
How much does it cost?
Can we deliver this waste to your facility ourselves?
Another word of caution: avoid disposing of dental
amalgam with "red bag" waste. Similar to some sludge
and garbage, red bag waste may be incinerated and
therefore mercury may be released into the environment. If
no amalgam recyclers are available in your area EPA
recommends disposing of amalgam as a hazardous waste.
Pharmaceuticals
Unused, expired, or unneeded Pharmaceuticals may be
considered a hazardous waste. Risks which may make
Pharmaceuticals hazardous waste include but are not
limited to the following:
The main active ingredient may be toxic
Preservatives and other ingredients can pose a toxicity
hazard over and above the effect of the main active
ingredient
Some common solvents can pose a fire hazard (i.e.
they are ignitable)
A few compounding agents are corrosive, including
strong acids with pH less than 2 (such as glacial acetic
and carbolic acids) and strong bases with pH greater
than 12.5 (such as sodium hydroxide)
Some compounds are radioactive, including certain
chemotherapy drugs, and certain agents that are used
as tracers or markers.
Beyond reverse distribution Pharmaceuticals are handled
based on whether they are a hazardous waste. This can be
determined by answering the '6 questions for identifying
hazardous waste' on pages 1 and 2 above. Washington State
Department of Ecology has devised a comprehensive web-
site to help you determine if a pharmaceutical is a hazardous
waste, www.ecy.wa.gov/programs/hwtr/pharmaceuticals/
index.html
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Examples of Health Care Clinic Hazardous Waste
Since Pharmaceuticals have the potential to be hazardous
waste their disposal is particularly difficult to manage. One
resource that is available to manage unused
Pharmaceuticals is the use of reverse distribution. This
option allows the facility to send back the unused but
potentially usable portions of the pharmaceutical to the
manufacturer for a 'credit'. Pharmaceuticals sent back to
the manufacturer are not hazardous waste and therefore
do not count when calculating the volume of hazardous
waste generated by the facility.
Universal Waste
This category of waste is a category of hazardous waste
that is subject to less stringent regulations, e.g. longer
accumulation times, and reduced transportation
requirements, in order to facilitate recycling. These
regulations are found in the Code of Federal Regulations
(40 CFR Part 273). There are four main types of Universal
Waste:
Hazardous Waste Batteries
Hazardous Waste Pesticides
Hazardous Waste Lamps
Mercury Containing Equipment
Most clinics generate waste in all four universal waste
categories, including the mercury containing equipment
category. For example, mercury thermometers and
mercury sphygmomanometers may be universal waste.
Containers of universal waste must be labeled with the
words "universal waste" and a description of the contents
such as "lamps" or "batteries".
Under the regulations there are four categories of entities
that deal with universal waste:
Universal Waste Handlers
Small Quantity Handlers of Universal Waste
(SQHUW) - accumulate less than 5,000 kg
(approximately 11,000 Ibs) of all universal waste
categories; basic training on proper handling and
emergency procedures is required.
Large Quantity Handlers of Universal Waste
(LQHUW) -accumulate 5,000 kg (approximately 11,000
Ibs) or more of all universal waste categories;
documentation of shipments to and from the LQHUW, an
EPA ID number, and stricter employee training
requirements are required.
Universal Waste Transporters -transport does not
require an EPA manifest during transport but
transporters must comply with applicable DOT
requirements.
Universal Waste Destination Facilities -treat, dispose
of, or recycle a particular category of universal waste;
requirements are the same as fully regulated hazardous
waste Treatment, Storage, or Disposal Facility (TSDF).
Individual states may choose to add other hazardous waste to
their universal waste program to facilitate recycling. To be
included the waste must be generated by a wide variety of
generators, cannot be exclusive to a specific industry, and it
must be hazardous. To find out more about what your
individual states regulations on universal waste are visit:
www.epa.gov/epaoswer/hazwaste/id/univwast/
statespf.htm
Used Oil
A complete overview of the universal waste regulations can be
found at www.epa.gov/epaoswer/hazwaste/id/univwast/
index.htm
Some clinics have maintenance shops that generate used
lubricating oils. If these oils are sent off for recycling or
burned onsite in a space heater, they are regulated under
the used oil regulations found at 40 CFR Part 279.
Generators of used oil are required to collect the oil in
containers or tanks that are labeled with the words "used
oil." A used oil generator may burn the oil it generates
without a permit in a space heater at the facility where it is
generated. A generator must make sure that used oil
shipped offsite is transported by a registered used oil
transporter and is sent to a registered used oil processor or
burner. If the oil is being sent offsite to be burned at a
facility that does not have a permit to burn it, then the
generator, the transporter, or the burner must first
determine that the used oil meets the specifications in the
regulations for burning without a permit.
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Appendix A:
Common EPA- Listed Hazardous Wastes in Healthcare
Material
Benzyl Chloride
Arsenic (trioxide)
Arsenic Trioxide
Chloropropionitrile(3-chloropropionitrile)
Cyanide Salts
Epinephrine
Nicotine
Nitroglycerin
Phentermine
(Alpha, alpha-Dimethylphenethylamine)
Phenylmercuric acetate
Physotigmine
Physotigmine Salicylate
Potassium Silver Cyanide
Sodium Azide
Strychnine
Acetone
Acetyl Chloride
Acrylonitrile
Aniline
Azaserine
Benzidine dichloride (Hexachloropropene)
Bromoform
Cacody lie Acid
Carbon Tetrachloride
Chloral Hydrate (Chloral)
Chlorambucil
Chlornaphazin
Chloroform
Creosote
Cresols
Cyclophosphamide
Daunomycin
o-Dichlorobenzene
m-Dichlorobenzene
p-Dichlorobenzene
Diethylstilbestrol
Ethyl Acetate
Ethyl Carbamate
Ethyl Ether
Ethylene Oxide
Formaldehyde
Formic Acid
Hexachloroethane
Hexachlorophene
Hexachloropropene
Lindane
Code
P028
P012
P012
P027
P030
P042
P075
P081
P046
P092
P204
P188
P099
P105
P108
U002
U006
U009
U012
U015
U243
U225
U136
U211
U034
U035
U026
U044
U051
U052
U058
U059
U070
U071
U072
U089
U112
U238
U117
U115
U122
U123
U131
U132
U243
U129
Use
pharmaceutical manufacturing
veterinary medicine, severe parasitic diseases
chemotherapy
pharmaceutical synthesis
laboratory
emergency allergy kits, certain types of glaucoma, eye surgery,
cardiac arrest
smoking cessation, nicotine patches, etc.
coronary vasodilator in angina treatment
appetite suppressant
bactericide, pharmaceutic aid in contact lens solutions and
nasal sprays
acholinergenics (liberates/acts like acetylcholine)
acholinergenics (liberates/acts like acetylcholine)
bactericide
chemical preservative in hospitals, laboratories
veterinary tonic and stimulant
solvent in pharmaceutical formulations
cholesterol testing
pharmaceutical manufacturing
pharmaceutical manufacturing
antifungal, antineoplastic
pathology laboratory
sedative, hypnotic, antitussive
dermatologic
anthelmintic, pharmaceutical formulations
cough syrups, sleeping pills
chemotherapy
antineoplastic
anesthetic
antiseptic, expectorant
antiseptics, disinfectants
chemotherapy
chemotherapy
germicides, pharmaceutical manufacturing
germicides, pharmaceutical manufacturing
germicides, pharmaceutical manufacturing
anticancer agent, contraceptive
drug flavoring agent, topical anesthetic
antineoplastic
disinfectant, anesthetic
high level sterilant for surgical instruments
antiseptic, disinfectant, preservative
diuretic, heart and muscle treatment
anthelmintic (anti-worm treatment)
skin treatment (pHisoHex", Septisol")
dialysis, pesticide (Septisol foam?)
[note ref to Septisol as hexachlorophene -no hits on
"hexachloropropene Septisol"]
scabicide
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Appendix A:
Common EPA- Listed Hazardous Wastes in Healthcare (cont.)
Material
Melphalan
MaleicAnyhydride
Mercury
Methanol
Methylpyrilene
Methylthiouracil
Mitomycin
Naphthalene
N-butyl alcohol
P-Chloro-m-Cresol
Paraldehyde
Phenacetin
Phenol
Reserpine
Resorcinol
Saccharin
Selenium sulfide
Streptozotocin
Tetrachloroethylene
Uracil mustard
Thiram
Trichloroethylene
Warfarin < 0.3%
2-Chloroethyl Vinyl Ether
3-Methylchloranthrene
Code
U150
U147
U151
U154
U155
U164
U010
U165
U031
U039
U182
U187
U188
U200
U201
U202
U205
U206
U210
U237
U244
U228
U248
U042
U157
Use
chemotherapy
pharmaceutical manufacture
preservatives (thimerosal), antiseptics (mercurochrome),
devices (thermometers, sphygmomanometers, others)
solvent in pharmaceutical manufacture
antihistamine
thyroid inhibitor
chemotherapy
antiseptic, anthelmintic
bactericide, pharmaceutical manufacture, pain control,
anti-hemorrhagic
antiseptic
sedative, hypnotic
analgesic, antipyretic
antiseptic, anesthetic, antipruritic (relieves itching)
hypertension, insanity, snakebite, cholera, horse tranquilizer
acne, dandruff treatment, intermediate in
pharmaceutical synthesis
sugar substitute, food preparation
shampoos
chemotherapy
anthelmintic
chemotherapy
antiseptic
inhalation anesthetic, pharmaceutical manufacture
anticoagulant
anesthetics and sedatives manufacture
cancer research
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Appendix B:
Hazardous Waste
Hazardous Wastes and
Substances
Acids, caustics,
pesticides
Air emissions from
spraying pesticides
Department Commonly
Found
Maintenance
Grounds Keeping
Batteries: Mercury, lead All Departments
acid, cadmium, nickel
Biomedical/infectious 'Sterile Reprocessing
waste Dental Services
Housekeeping
Maintenance
Caustics, ions, cat ions Maintenance
Chemotherapy and Out-Patient Care
antineoplastics Pharmacy
ChromiumChromic Acid Dental Services
Radiology
Cleaning Chemicals, Administration &
Waxes Purchasing
Housekeeping
Contaminated pesticide Grounds Keeping
containers
Disinfectants, sulfuric Maintenance
acid, sodium hydroxide
Electronic waste / All Departments
Computer waste (lead,
mercury-containing
waste)
Ethylene oxide (EtO) Sterile Reprocessing
with 88% Freon-based Out-Patient Care
carrier
Use or Source
Janitorial supplies
Chemical pesticide
spraying or evaporation
Available Alternatives
Minimize use of volatile
organic pesticides. Use
integrated pest
management.
Hearing aids and
pacemakers
PDAs and digital
cameras
Communication devices
Sharps
Body fluid saturated
materials
Specimens/tissue
Boilers
Water treatment
Patient treatment
X-ray developer
Glassware
Tank cleaners
Waste water
Cleaning Disinfecting
Maintaining surfaces
Pesticides
Fertilizers
Water treatment systems
Cathode Ray Tubes
(CRTs)
Monitors
Hard drives
Sterilization (heated)
Rechargeable batteries
Lithium or alkaline
Zinc air
Additional Management
Comments
Hazardous waste;
neutralize acids/ bases
Avoid creating dust and
don't allow material to
blow around
Cover containers to
avoid evaporation
Manage as hazardous or
universal waste
Separate municipal solid Store/dispose biomedical
waste (sharps in separate waste in red bags or
container) puncture-resistant
containers. Use
biomedical waste hauler
and facility
Use ozonation or filtration Segregate reactive and
systems incompatible chemicals
Reduce volumes used.
Centralize chemo
compounding
Use non-chromium
cleaners.
Used precharged slides
or silane
Eliminate strippers and
waxes containing zinc
Use pre-made
compounds. Bulk chemo
wastes are hazardous
wastes.
Hazardous waste
Rinse / wash
Return for recycling
Use sodium hypochlorite
systems, bromine,
peracetic acid
Recycle
Send for re-use
Use vendor take-back
program
Consider using steam or
sonic sterilization
Use least-toxic products,
avoid spills, prepare only
needed amount. Store in
secondary containment.
Never discharge
concentrated disinfectant
into sewer
Hazardous waste:
manage properly
Waste treatment
chemicals may be
hazardous waste
EPA regulates Freon.
Recover and dispose of
EtO and Freon as
hazardous waste
Filter air and dispose of
spent filters as
hazardous waste
Steris, Sterad, Sterilox
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Appendix B:
Hazardous Waste (cont.)
Hazardous Wastes and
Substances
Glutaraldehyde,
formaldehyde, xylene,
and alcohols
Department Commonly
Found
Sterile Reprocessing
Dental Services
Out-Patient Care
Glutarldehyde, Cidex, Sterile Reprocessing
Glutarex, Sonacide Dental Services
Phenolic disinfectants Housekeeping
Green waste
Hazardous waste
Pharmaceuticals
Lead
Mercury
Mercury
Mercury
Grounds Keeping
1 Dental Services
Out-Patient Care
1 Pharmacy
Dental Services
Out-Patient Care
Radiology
All Departments
Out-Patient Care
All Departments
Use or Source
Cleaning and sanitizing
1 Disinfecting
1 Sterilizing
1 Chemiclaves
1 Cold Sterilization
1 Preservation
1 Disinfection
Grounds maintenance
Available Alternatives
Autoclaves/ sonic
sterilization, Microwave,
electron beam, gas
plasma, hydrogen
peroxide
Cresols and Lindane
Mercury based
preservatives
Unused/ outdated
medications, controlled
substances
Lead boxes and foil
packets
Aprons
Autoclave indicator tape
Thermometers
Barometers
Sphygmomanometers
Monitoring devices
Miller-Abbot tubing
1 Light bulbs, lamps, and
older microwaves
1 Mercury thermostats
1 Mop water from
cleaning floors
Use non-hazardous
substance or non-
inhalation hazard
sterilization equipment
Nitrile gloves and
personal protection
equipment
Consider quaternary
amine disinfectants,
Cidex OPA, peracitic
acid
Reduce waste by using
Integrated Pest
Management
Return to manufacturer
Use reverse distribution
Additional Management
Comments
Aldehydes can be
neutralized by using
glycine or other
neutralizes.
Never discharge to septic
system. Use proper
ventilation and staff
medical monitoring.
Count as treated
hazardous waste. Note:
Cidex OPA is not
recommended for use in
chemiclaves.
Use gloves and personal
protection equipment.
Use proper ventilation.
Never discharge into
septic system, even if
neutralized. Can be
neutralized and
discharged to sewer.
Count as treated
hazardous waste.
Recycle
Use non-lead autoclave
tape
Compost green waste.
Inventory often
Use first in -first out
system
Hazardous waste; do
not discharge to sewer
Manage as Hazardous
waste
Alcohol thermometers
1 Digital equipment
1 Digital equipment
Tungsten-filled G.I.
tubing and bougies
Anderson tubes
Can be recycled as
Universal or hazardous
waste
Phase out mercury-
containing devices or
equipment. Hurst and
Malone have mercury-/
PVC-free tubing
Low-mercury or energy- Check Universal Waste
efficient lamps
Newer microwaves
Digital thermostats
Mercury-free switches
and batteries
regulations to find out
which can be disposed
under the Universal
Waste Rules and which
ones must be managed
as hazardous waste.
Keep bulbs and lamps
intact; recycle. Clean up
mercury spills properly
and keep spill kits readily
available.
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Appendix B:
Hazardous Waste (cont.)
Hazardous Wastes and
Substances
Department Commonly
Found
Use or Source
Mercury (thimerosal) Pharmacy
and mercury-containing
items and monitoring
devices
Municipal Solid Waste
(MSW)
All Departments
Organophos-phates,
chlorinated or heavy
metals, other chemicals
Pesticide or fertilizers
contaminated storm
drain runoff
Grounds Keeping
1 Grounds Keeping
1 Housekeeping
Pressurized canisters
and containers
Selenium
Silver
Grounds Keeping
1 Pharmacy
1 Radiology
Dental Services
Radiology
Silver nitrate
Pharmacy
Solvents (alcohols, Medical Equipment
ketones and chlorinated Maintenance
compounds)
Solvents, paints,
turpentine, strippers,
oils, decalcifiers,
disinfectants, hydraulic
fluids, pesticides
Maintenance
Toner cartridges
Administration &
Purchasing
Pharmaceuticals
Mercurochrome,
ophthalmic products,
nasal sprays, vaccines,
preservatives
Packaging
Paper
Disposable Items
Available Alternatives
Use non-mercury
containing medications,
devices and equipment
Additional Management
Comments
Hazardous waste.
Collect, recycle, reuse, or
dispose of as hazardous
or universal waste.
Pesticides and fertilizers
for pest and weed
control, ground
maintenance
1 Request less packaging
1 Segregate wastes
1 Minimize by purchasing
in bulk
1 Use vendor take-back
program
Use Intrgrated Pest
Management practices
1 The application of Use pest resistant native
pesticides and fertilizers vegetation species that
1 Vegetation watering require less use of
pesticides and watering
Recycle, reuse.
Follow hauler's waste
separation
specifications. Recycle
glass, cardboard,
aluminum cans, scrap
wood and metal, etc.,
whenever possible.
Use pest-resistant and
native species. Use non-
chemical/ least toxic
alternatives. Minimize
use of dangerous waste
chemicals.
Do not allow runoff of
pesticides and fertilizers.
Minimize the use of water
pesticides and fertilizers
by using IPM and
Xeriscape techniques.
1 Sprayers
1 Pesticide containers
1 Fertilizer containers
Toners
Dandruff shampoos
1 Spent X-ray fixer
1 Processor solution
Use refillable containers Rinsates may designate
(always triple rinse before as hazardous waste.
using another product) Return pressurized
canisters or containers
for refill or reuse to
distributor.
Use sodium selenate, not Replace with selenium-
cysteine broth-Apple free version.
cider vinegar rinse Minimize use of
medicated shampoo.
1 Use digital systems
1 Recycle on- or off- site
Burn medicines
Use alternative anti-
bacterial creams
1 Equipment maintenance Aqueous-based cleaners
1 Cleaning or non-chlorinated
solvents
1 Cleaning
1 Painting
1 Pest Management
Copiers
Printers
Eco Safe
BioKleen
Manage as hazardous
waste or recycle. Don't
discharge waste water.
Use cation exchange,
electrolytic recovery,
steel wool filtration for
silver recovery. Recycle
x-ray film.
Manage silver
concentrations of 5 ppm
or more as hazardous
waste.
Segregate solvent
wastes, distill, reuse or
dispose of as hazardous
waste.
Don't use chlorinated
products. Use reusable
or recyclable tote drums.
Manage used oils,
sludges, and other
hazardous wastes
appropriately.
1 Recycle
1 Use vendor take-back
programs
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Appendix B:
Hazardous Waste (cont.)
Hazardous Wastes and
Substances
Tributylin (chloride,
neoeconate, bis
tributylin oxide,
benzoate, etc.)
Waste water containing
hazardous wastes
Department Commonly Use or Source
Found
Available Alternatives
Housekeeping
Medical Equipment
Maintenance
Sterile Reprocessing
Grounds Keeping
Pharmacy
Zinc-based compounds Dental Services
Mildew control in
shampoos, lavatory and
germicidal cleaners
Hazardous wastes
Reduce generation of
hazardous waste
Cements
Additional Management
Comments
Pesticide wastes are
hazardous wastes,
manage properly.
Do not dispose untreated
hazardous waste into the
sewer system. Contact
Ecology or local
wastewater facility for
exact disposal
regulations for your area.
Don't discharge into
sewer. May be disposed
as a solid waste.
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Printed on 100% recycled/recyclable paper
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fiber using vegetable-based ink.
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