The Resource Conservation and Recovery Act is commonly referred to as RCRA (reck-rah). It is much better to pronounce the acronym as “reck-rah.” Spelling it out as “R-C-R-A” conjures images of the Village People with their famous song.
If you work in the healthcare environment, you know that you must carefully dispose of hazardous waste. First, you must decide if the waste that you are managing is a hazardous waste (HW), and then you must make certain that you dispose of the HW properly. With so many types of hazardous waste, it can get confusing. This blog will discuss the types of listed hazardous wastes found in healthcare, with an emphasis on hazardous waste pharmaceuticals (HWP), the most common type managed in healthcare.
NIOSH vs RCRA
Are you confused by the terms “hazardous drug” and “hazardous waste pharmaceutical” (HWP)? Well, you are not alone. At first glance, it would appear they are the same, but they are not. Knowing the difference can save your facility money and potential regulatory citations. So, let’s clear the confusion.
What exactly is a non-conforming hazardous waste (HW) stream at a permitted TSDF? Let’s take a look at the process of how a HW stream is managed at a TSDF.
So, you want to ship some material that has been determined to be a hazardous waste, do ya. You followed the EPA regulations to make your determination that you have a hazardous waste, and you will ship the waste to an EPA permitted and authorized Treatment, Storage and Disposal Facility (TSDF) for the proper treatment. But — another Federal Agency, the US Department of Transportation (USDOT or just DOT) will take precedence over the manner that the waste is shipped over the road. So you started by following EPA regulations in the determination and while the waste is on your site, then when you offer the waste for transport, the DOT regulations kick in. Once the waste is received at the TSDF, the EPA regulations govern the treatment of the waste.