It was common years ago for health care facilities to flush unused pharmaceuticals down the toilet or dump it down the drain. The Environmental Protection Agency (EPA) conducted studies and identified numerous pharmaceutical compounds in our nation’s rivers, lakes, streams and drinking waters.
Despite the complexity of waste management, dental offices must evaluate the types of wastes generated and dispose of such waste properly. According to Universal Waste and Hazardous management at Healthcare Facilities in Tennessee, “the lack of a viable environmental compliance program can obviously be used as evidence of a lack of intent to comply.
First, we must determine whether the waste is a hazardous waste regulated by Resource Conservation and Recovery Act’s (RCRA). According to EPA, the proper waste identification process involves determination of
a) whether the waste is a “solid waste,”
b) if the waste is specifically excluded from the RCRA regulations,
c) is the waste is a “listed” hazardous waste and,
d) if the waste exhibits a characteristic of hazardous waste.
Next we determine if the waste poses a chemical and physical hazard to merit regulation such as ignitable, corrosive, reactive and toxic.
RCRA defines hazardous pharmaceutical waste as the P list (acutely hazardous) and the U list (toxic). P and U-listed chemicals are unused including those that exceeded shelf life (expired), spill residue or residue remaining in the product container. Thus, P and U-listed chemicals apply to unused chemicals do not apply to manufacturing process wastes.
Any facility that generates a hazardous waste is subject to the RCRA generator regulations at 40 CFR 262. There are three generator categories:
- Conditionally Exempt Small Quantity Generators
- Small Quantity Generators
- Large Quantity Generators
A facility that generates 1000 kilograms (kg) (2204.62 pounds) or more of hazardous waste in a month or greater than 1 kg or acute (P list) hazardous waste in a month is alarge quantity generator (LQG). LQGs are subject to the full RCRA generator regulations. This includes obtaining an EPA identification number, storing waste for only 90 days or otherwise obtaining a RCRA permit; meeting manifest and reporting requirements; and compliance with training requirements.
A facility that generates more than 100 kg (220.46 pounds) but less than 1000 kg (2204.62 pounds) of hazardous waste in a month is a small quantity generator(SQG). SQGs are subject to less requirements such as not having to complete the biennial report, less personnel training and contingency planning requirements and the allowance of 180 days rather than 90 days for waste accumulation.
A facility that generates no more than 100 kg of hazardous waste in a month, or no more than 1 kg (2.205 pounds) of acutely hazardous (P list) in a month, is aconditionally exempt small quantity generator (CESQG) under the federal program. CESQGs have the least stringent requirements. They are not required to obtain an EPA identification number, manifest waste sent off-site for disposal, or meet any storage time limits. CESQGs can send hazardous waste to either a state-approved solid waste facility or to a hazardous waste disposal facility.
Most average dental offices are likely considered conditionally exempt small quantity generators.
Hazardous waste in dentistry includes:
Dental amalgam should not be disposed of in the sharps container or red bags. Red bags and sharps containers are sterilized and placed in solid waste landfills. Hazardous waste pharmaceuticals are treated by hazardous waste incineration and the incinerator ash is disposed of in a permitted hazardous waste landfill.
Fluorescent lamps must be recycled. Store the used lamps in universal waste compliant containers and maintain documentation. Check with the store where the lamps were purchased to determine if a take-back program is available.
Assess the batteries in use. With the exception of alkaline batteries, batteries may be considered hazardous waste. Properly package, store, recycle and maintain documentation.
Certain chemical sterilants and disinfectant waste may be considered hazardous. Consult the Safety Data Sheet (SDS) to determine special disposal instructions.
Pharmaceuticals that are classified hazardous waste must be disposed of as such, not as medical or solid waste. Pharmaceutical waste may include expired drugs, open drugs that cannot be used, drugs that are intended to be discarded, waster materials containing excess drugs, and contaminated absorbents used for spill clean up material. Although the color of the waste receptacle is not regulated, choose a color that clearly communicates the type of waste contained.
P-listed medications are acutely hazardous including epinephrine (not epinephrine salts). If you generated more than 2.2 pounds or more of acutely hazardous waste in a single calendar month, you may be designated as a “large quantity waste generator.” Therefore, it is very important to segregate such waste properly.
Medical supplies and containers that are “RCRA empty” means that all of the criteria is met:
- All material that can be removed by normal means has been removed and
- Less than 3% by weight of the total container capacity remains and
- Supplies and containers do not contain residue from a P-listed waste.
Unused anesthetic carpules and used carpules with more than 3% anesthetic residue must be treated as pharmaceutical waste. Perform ongoing inventory control and stock rotation to avoid expired anesthetic. Tennessee supports EPA’s recommendation on the reverse distribution process for unused pharmaceuticals to the manufacturer for evaluation, possible credit and proper disposal.
Always place the latest shipment of anesthetic toward the back of the stock so that you are utilizing the oldest product first to avoid expiration. Write the expiration on the outside of the box as a visual reminder.
Most dental offices have a relationship with a waste hauler or service provider for biohazardous waste (red bags and sharps containers). Consult with the provider to determine if the waste company is capable of handling hazardous waste to include pharmaceutical waste. Based on the limited amount of waste generated, it may be advantageous to pay by pick up rather than a year-long contract. Determine your options prior to signing a contract.
Unlike other types of wastes generated, hazardous waste must be transported to a permitted treatment, storage, and disposable facility.
The most cost effective way to manage waste is to reduce the amount of waste generated. Never mix non-hazardous waste with hazardous waste. Recycle materials where appropriate. Store hazardous products safely in containers to avoid costly clean up costs.
Dental offices that meet the EPA’s definition of a Conditionally Exempt Small Quantity Generator may opt to ship hazardous waste rather than utilize a fuel service. Keep in mind that offices are required to be a DEA-registrant to ship controlled substances.
Some of the waste management companies offer both mail in and pick up services. The following companies represent a partial list:
Telephone: (615) 431-2966
XMED Disposal, Inc.
Telephone: (866) 735-9709
Telephone: (847) 367-5910
Hazardous Waste Experts
Telephone: (888) 681-8923
Handle your waste properly and maintain documentation. For more information about Modern Practice Solutions’ training programs and policy development, please contact (931) 232-7738 or visit www.DentalComplianceTN.com.
Introduction to Hazardous Waste Identification, 40 CFR Parts 261, EPA, September 2005
40 CFR 261
40 CFR 261.33
Evaluating Pharmaceutical Waste, Kentucky Division of Compliance Assistance, 2009
Handbook for Hazardous Waste Generators, July 2002, Kentucky Division of Waste Management. www.kyenvironment.org/nrepc/dep/waste/dwmhome.htm