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.
When the discussion turns to hazardous waste within the healthcare environment, it is in most cases associated with RCRA pharmaceuticals. RCRA (Resource Conservation and Recovery Act) is the regulation that defines hazardous waste per the EPA, and outlines the proper methods for managing hazardous waste, as well as proper treatment and disposal. An example of a RCRA pharmaceutical is the drug warfarin. The most efficient method to identify medicines that will be considered hazardous wastes when discarded is to reference the organization’s drug formulary and classify the drugs on that formulary based on their NCD number or previously identified drug hazard classification. In addition, some drug packaging identifies the medication as hazardous.
Containing and Transporting Your Hazardous Waste
Clinicians often place unused medications in sharps containers for disposal. It is crucial to train employees never to put drugs, including hazardous drugs, or other hazardous wastes into sharps containers or red bags. Sharps and other medical waste, as well as hazardous waste must all be segregated into separate properly-labeled containers since they are all transported and treated differently. U-listed pharmaceutical waste drugs must be handled as hazardous waste. However, the packaging it came in can be place into the trash. However, P-listed pharmaceuticals such as warfarin as well as the container or packaging in which they came need to all be handled as hazardous waste. Once identified as hazardous, the medications as well as P-listed waste packaging should be placed in a labeled container for hazardous drugs, often colored black. This container can also be used for other listed or characteristic hazardous wastes. Having proper containers for hazardous wastes will help keep those wastes out of sharps containers, red bags, and the trash.
Hazardous wastes are removed from the facility by transporters that manage hazardous waste pickup or ship-back programs. Not all medical waste disposal companies can manage these types of wastes.
Treating Your Hazardous Waste
Hazardous wastes are transported to facilities that are permitted to treat those types of waste. Hazardous wastes are typically be incinerated. Universal wastes are sent to a retort facility where the materials can be safely separated and recycled.
Hazardous Waste Recordkeeping and Training
Hazardous wastes, similarly to medical waste, must have a manifest accompany the waste from the facility from which it was generated to the treatment/disposal facility. Even though universal wastes do not require a manifest, it is important to understand how that waste is being managed.
Once the types of hazardous wastes are identified and a management program is in place, healthcare personnel can be trained to identify, segregate, collect, and manage for proper disposal those wastes. Placing a waste segregation chart or a list of formulary drugs above the appropriate container can be a constant reminder for current and new employees.
How Do I Get A Program Started?
Working with trained professionals such as those with Sharps Compliance to build a program is a healthcare facility’s best option. Sharps Compliance can help identify the waste types and characteristics of the waste generated, help with the segregation process, provide containment and disposal or recycling options; as well as training and proper recordkeeping. Sharps Compliance offers a simple-to-use and cost-effective ship-back program for most universal wastes as well as pickup programs for hazardous and duel wastes.