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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