Hazardous Waste in Healthcare, Part 1: DEFINING HARDOUS WASTE

Last updated on October 30, 2019

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.

Listed Wastes

  • K-Listed wastes are generally not found in healthcare facilities.
  • F-Listed wastes may be present in the healthcare facility if the facility has departments such as a morgue or a maintenance shop.
  • P-Listed wastes are acutely toxic and include multiple pharmaceuticals and other materials found in healthcare facilities. Warfarin is an example of a P-listed waste when at a concentration of >0.3%.
  • U-Listed wastes are toxic and include many pharmaceuticals, including chemotherapy wastes, and other materials such as commercial chemical products used in healthcare facilities.

Examples of U-Listed wastes in the healthcare setting include, but are not limited to:

  • Azaserine
  • Reserpine
  • Warfarin (concentration ≤0.3%)
  • Acetyl Chloride
  • Chloral Hydrate
  • Selenium sulfide- used in certain shampoos
  • Ethyl Ether

Characteristic Wastes (called D-coded)

but that exhibit the characteristics of:

  • Ignitability (D001)
  • Corrosivity (D002)
  • Reactivity (D003)
  • Toxicity (D004 through D043)

While some materials may not exhibit these characteristics on their own, when mixed with another material, the mixture may produce a chemical reaction resulting in one or more of the described characteristics.

What is Universal Waste?

Universal wastes are hazardous wastes that can be recycled, such as batteries, pesticides, mercury-containing equipment like thermostats, and mercury-containing lamps, such as fluorescents, in addition to dental amalgam and some radiological wastes like fixer and lead aprons. If thrown into the trash, these wastes can contaminate the environment. Since these wastes are recyclable, they can be handled as universal wastes instead of hazardous wastes. This results in fewer restrictions on the generator. Even if an organization contracts a maintenance company to manage this waste, it is important to know that the  and is responsible to ensure these wastes are managed properly. For more details on Universal Waste, see WHEN LIGHTING GOES DARK – FLUORESCENT BULB RECYCLING.

What is Mixed and Dual Waste?

Mixed wastes are wastes that contain both radioactive and hazardous waste components. These wastes must be allowed to decay and then for the most part can be managed as hazardous waste.

Dual wastes are wastes that contain both infectious waste (regulated medical waste) as well as hazardous waste. For example, blood-soaked gauze that is also soaked with a chemotherapeutic drug; or a used syringe containing excess thimerosal-preserved vaccine.

This waste must be handled by a company permitted to handle dual waste.

Now that we have defined hazardous wastes, the next steps include identifying hazardous wastes in your facility, and then segregating and properly managing them. This includes proper containment, transport, treatment, recordkeeping, and training. We will cover these topics in Part 2 of this blog.

1) 40 CFR Part 261 Electronic Code of Federal Regulations Accessed 10/20/2014

Joe Jordan has a Bachelors of Arts degree in Chemistry from Washington and Jefferson College. He is certified in RCRA and DOT as well as 40 Hour HAZWOPER certified. Joe has been in the hazardous waste industry since 1990 and has managed industrial, healthcare, retail, and governmental clients, both large and small.

published in Hazardous Waste