Many healthcare facilities produce hazardous waste. The mostly widely accepted definition of hazardous waste (at least in the US), is "RCRA hazardous waste" - that is, waste that meets the criteria laid out in the Resource Conservation and Recovery Act. State and local governments can have their own definitions and regulate waste in their own ways, but when you say “hazardous waste” to a waste management professional, he or she thinks RCRA waste.
This page talks about what makes healthcare waste hazardous. If it is also infectious, that is another issue. Sometimes healthcare waste is both hazardous and infectious, or hazardous and radioactive, and must be managed to meet the requirements for more than one type of waste.
Some medical waste meets the definition of RCRA waste. There are four lists of enumerated hazards (F, K, P and U) and medicines appear on two of the lists (P and U). Further, some waste streams are highly (1) corrosive, (2) reactive, (3) ignitable, and (4) toxic, either with or without the characteristics that make them medical waste. For instance, blood soaked up by rag soaked in flammable solvents could be both medical and hazardous waste. Some chemotherapy drugs are included on the P and U lists and other chemotherapy drugs developed after the lists were written still qualify for RCRA hazardous status because of their toxicity.
Flammability or inflammability (same thing) does not make a waste hazardous or necessarily of special concern. Many wastes will burn (that’s why incineration is an appealing treatment). Indeed, most waste generated in the typical office, or even industrial setting, will burn. But burnable or flammable is not the same as ignitable. RCRA says that ignitable waste is hazardous. That is, the waste must be liable to being set on fire with a spark. The metric used to quantify ignitability is the flashpoint.
The flashpoint of a liquid is the temperature at which a vapor above the waste ignites when exposed to a spark. The lower the flashpoint, the more flammable the material. If a waste has a flashpoint below 140 degree F (60 degrees C), it is hazardous. Powders and other solids may be ignitable, too. There is a process for measuring ignitability.
Highly acidic or corrosive liquids are considered corrosive. Aqueous wastes with a pH below 2 or above 12.5 are classified as hazardous. If the liquid is demonstrated as being corrosive to steel coupons in a controlled test, it is also classified as corrosive as aggined waste code D002. Corrosive materials at health care facilities include acids (e.g. acetic, chromic, hydrochloric, nitric, sulfuric) and bases (ammonium hydroxide, potassium hydroxide, sodium hydroxide). Physically solid, nonaqueous wastes are not considered corrosive under RCRA.
The EPA spells out a standard test to measure if a waste is corrosive on steel. https://www.epa.gov/hw-sw846/sw-846-test-method-1110a-corrosivity-toward-steel
Reactive refers to chemical reactivity and the potential of a material to rapidly breakdown or react in a manner that releases a lot of heat or gases and vapors. It is difficult to quantify how reactive something is and whether it passes a threshold to become hazardous. It’s mostly a judgment that comes out of a conversation with the regulatory authority. A waste that is liable to chemically breakdown spontaneously at ambient temperatures is considered reactive. So is anything that reacts with water. Context matters, too, as two materials present in the same facility that might react with each other could be considered reactive waste while each material by itself might not. Reactive materials at health care facilities include oxidizers (bleach, hydrogen peroxide, potassium dichromate, potassium permanganate) and reducers (sodium bisulfite, sodium sulfite). Paints and cleaning solvents often become ignitable waste. Anaesthetic gases and ethylene oxide are hazardous materials used at many hospitals. If a waste meets the Department of Transportation’s definition of oxidizer, it is considered ignitable waste. Solid waste is classified as ignitable if it can spontaneously catch fire or ignite through friction.
A waste is toxic if it is harmful to a human (or similar animals) after it enters the body. Toxicity here is a chemical property. Bacteria and other pathogens can be harmful, but they are not considered toxic. Heavy metal waste is often toxic. Used batteries often have heavy metals. Some facilities (often older ones) have lead built into the walls and ceiling of areas where X-rays and CT scans are done. Medical treatment chemicals are often toxic. Medicines can be harmful, in addition to being helpful to target patients. Some chemotherapy drugs are genotoxic.
The waste management community uses the Toxicity Characteristic Leaching Procedure (TCLP) to determine if a material is toxic.
Do I have to measure these characteristics for every batch of waste we produce?
No. The regulatory agencies could force you to test every batch, but as a practical matter your operating permit will allow you test the waste stream periodically. If your waste characteristics are stable over time, you shouldn’t have to measure the toxicity, flashpoint, and pH all that often. If in doubt, apply the precautionary principle and regard waste you might suspect might be hazardous as actually hazardous.
Other materials that may produce hazardous waste are not unique to the healthcare industry, but might be found at any large facility with diverse activities: herbicides, paints, pesticides, and waste oils.
You have to get a hazardous waste permit if you treat hazardous waste or if you store it on site. This might sound daunting but the administrative burden of applying for and maintaining a permit depends on how complex your operations are. Large quantities of waste and diversity of waste means a more complex permit.
Decades ago hazardous waste permits were more onerous but as society and the regulatory agencies have become more comfortable with them, they are not as scary as they once were. Getting a permit will help protect you in case of lawsuits so they provide something on an insurance policy.
Every facility’s permit is different. You will have to monitor, test, and file reports about the waste you generate and store.
Waste management pros worry about metals specifically named in RCRA. The so-called RCRA 8 metals are not allowed in MSW at high concentrations. Above the stipulated limits, the waste becomes hazardous RCRA waste.
The limits are:
Arsenic 5 ppm (mg/l), D004
Barium 100 ppm (mg/l), D005
Cadmium 1 ppm (mg/l), D006
Chromium 5 ppm (mg/l), D007
Lead 5 ppm (mg/l), D008
Mercury 0.2 ppm (mg/l), D009
Selenium 5 ppm (mg/l), D010
Silver 5 ppm (mg/l), D011
Don’t think you can get out of this requirement by diluting your waste so the concentration is lower. If authorities figure that out, they will punish you.
The EPA has published a useful guide: https://www.epa.gov/sites/production/files/2016-01/documents/hw-char.pdf
Materials and tools used to clean up a spill of hazardous waste must be treated as hazardous waste. When you register your facility with the EPA as a hazardous waste generator (and you should), you will get an identification number. This number should be printed on the outside of every container of RCRA waste shipped off site and included on the shipping manifest.
In the United States the federal government regulates hazardous waste and facilities that generate waste on a regular basis are classified by size of waste stream
Large Quantity Generators (LQGs) = facilities that generate more than 1,000 kg of hazardous waste per month
Small Quantity Generators (SQGs) = facilities that generate between 100 kg (approximately 220 lbs) and 1,000 kg of hazardous waste per
Conditionally Exempt Small Quantity Generators (CESQGs) = facilities that generate less than 100 kg of hazardous waste per month
Most US hospitals are CESQGs or SQGs.
Hazardous waste should be stored in a dedicated area. This should be under a roof - and preferably inside a building with four walls. It doesn’t have to be air conditioned but it should have a sprinkler/fire suppression system. It should not be in an area where people frequent. If hazardous waste must be stored in an area that is used for other activities, be sure to have plenty of personnel protection equipment (e.g. eye washes) nearby. If you have a federal permit to keep hazardous waste on site, you must inspect the containers at least once a week. We recommend inspection of all waste containers once a week whether you have a permit or not and even if the waste is benign. The EPA requires hazardous waste inspection logs include the date and time of observance, the name of the person doing the inspection, and any abnormalities or risks observed. Corrective actions recommended and performed should also be noted.
Generating facilities need to get an EPA Identification (EPA ID) number using EPA Form 8700-12. You will need this number when submitting reports and for putting on shipment manifests and markings.
As a condition of your permit, the EPA requires you report every two years how much waste you made and what you are doing to reduce it.
Healthcare facilities almost always have a waste management contractor that takes away hazardous waste for treatment and disposal.
For hazardous waste shipments, the EPA distinguishes between bulk and non-bulk containers. Bulk containers are larger than 119 gallons (450 liters) in volume and 882 lbs (400 kg) in weight. The EPA calls the external sign on bulk containers “placards” and the one on non-bulk containers “labels”. Labels have this specific definition and they must be diamond shaped. Additional information on the containers is called “markings”. Non-bulk containers must include an external marking that says: “HAZARDOUS WASTE: Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.” Each shipment must also have an EPA tracking number.
The healthcare facility must write up a manifest for every shipment that leaves the facility. If there is a treatment facility that receives the waste, it will sign off and you - the generator - should get a copy so you know the waste has been responsibly transferred. Further, when the waste goes to preparation for disposal, the generator again gets notice. The EPA allows electronic manifests (e-manifests).
If you do not get notice of that your waste shipment has gone to final disposal, you should follow up and pester those responsible. You are always responsible for that waste, so you want to make sure it gets to disposal.
If you ship hazardous waste off-site, you still need to submit a report to the EPA every two years. The report states how much hazardous waste you produced, where it went, and how you are planning to reduce the quantity and severity of waste in the future.