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 ------- 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. ------- 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 ------- 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) ------- 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. ------- 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 ------- 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. ------- ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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. ------- Printed on 100% recycled/recyclable paper with a minimum 50% post-consumer fiber using vegetable-based ink. ------- ------- |