There has been increased scrutiny of the generation of hazardous waste in the retail industry – especially in the pharmacy area of stores. The importance of correctly managing the disposal of pharmaceuticals has become a critical issue. There is a category of waste that describes chemicals and constituents that are harmful to the environment – and these materials are classified as hazardous wastes under the Resource Conservation and Recovery Act (RCRA). A number of drugs and pharmaceutical formulations meet the definition of hazardous waste when discarded – and in some cases the empty containers that these pharmaceuticals came in may also need to be managed as hazardous waste.
What exactly does the word hazardous mean? It is used quite often in the regulatory world as a descriptor of another significant word. The word “hazardous” is an adjective, meaning full of risk; perilous; risky.
If you live in the Northern US, I am sure that you know what hazardous driving conditions signify. If you are a golfer, I am positive that you recognize the word “hazards” when on the course. So, you can easily see what using the term hazard or hazardous connotes.
We need to make certain that the regulatory definitions using the key word hazardous are understood – and that we use the terms correctly. Let’s look at the use of the word hazardous in the regulations.
In Part 1 of Hazardous Waste in Healthcare, we defined hazardous wastes. In Part 2, we will discuss identifying hazardous waste in your facility, as well as proper containment, transport, treatment, recordkeeping, and training.
Hazardous Waste Determination
Proper hazardous waste determination is essential to the success of the healthcare facility’s hazardous waste management program. The RCRA regulations at 40 CFR §262.11 require that any person who produces or generates a waste must determine if that waste is hazardous. These same regulations present the steps in the hazardous waste identification process. All healthcare facilities should have a program in place that manages hazardous waste according to not only federal RCRA regulations but also any local, city, and state regulations that may apply.
One of the biggest challenges for today’s healthcare workers is defining the different categories of waste streams they manage on a daily basis. Even the names can be confusing. There’s hazardous, biohazardous, RCRA, universal, pharmaceutical, regulated medical, red bag, pathological, chemo, infectious, isolation, and the list goes on. Perhaps the most confusing and dangerous wastes facilities deal with is hazardous waste. Hazardous waste in healthcare is much more complicated than biohazardous waste and more often than not, improperly recognized and categorized by healthcare professionals. So, what is hazardous waste?
What is Hazardous Waste?
The first step in identifying hazardous waste is learning to recognize products that will be considered hazardous wastes when discarded or as the U.S. Environmental Protection Agency (EPA) defines it, “no longer of value.”1 This could occur when the material has expired, e.g., drugs or when it is no longer needed, e.g. mercury-containing thermostats. The EPA developed four lists of specific hazardous wastes (Listed Wastes) and four hazardous waste types with defining characteristics (Characteristic Wastes) to help determine specific hazards.