Resource Conservation and Recovery Act

1
Resource Conservation and Recovery Act

• Vermont Hospital Association Conference
• 23 February 2004
• Victoria Jas
• Vjas_at_sover.net

2
RCRA

• Manages hazardous waste from cradle to grave
• Hospitals are required to identify two aspects of
  their waste generation
• Generator status (volume of waste generated each
  year)
• Determination of all waste streams

3
Determination of Waste Streams

• Hospitals, as generators of waste, must determine
  the risk of their waste by type
• Radioactive
• Biological
• Chemical
• Hybrid

4
Hazardous Chemical Waste

• Includes but is not limited to
• Fuel oils and Facility Maintenance Materials
• Hazardous Drugs and Chemotherapy Agents
• Cleaners, disinfectants, sterilants
• Laboratory chemicals

5
More Hospital RCRA Wastes

• Diagnostic materials
• Laboratory waste solvents and other solutions
• Used medical devices
• Universal Wastes
• Batteries
• Fluorescent light bulbs
• Electronics

6
Universal Wastes

• Regulations allow for recycling of hazardous
  materials, such as mercury containing fluorescent
  light bulbs WHEN done correctly

7
Hazardous Wastes

• Control at the Source prevent it from becoming
  waste whenever possible
• Store and label waste appropriately
• Check it frequently and keep it moving out on a
  regular basis
• Hire reputable vendors
• Staff training
• Documentation

8
Staff Training

• For large quantity generators, staff need to
  check physical locations where waste is generated
  and/or stored every seven days.
• Smaller facilities have similar requirements,
  less often
• These staff members need special training on
  hazardous wastes.

9
Hazard Determination

• Know what you are buying
• Vendor
• Material Safety Data Sheets
• Test the product (mercury elimination)
• Require the Vendor to provide third party
  verification

10
Vendors

• Require that they take back their hazardous
  wastes, or they will be charged double the
  disposal of wastes left behind on a job.
• Write the appropriate language in contracts.

11
Employees

• Love to bring in their own hazardous materials
  (which may become waste)
• Lysol spray and other odor-killing aerosols
• May use the hospital as a household-hazardous
  waste drop-off
• Engineering rats (paint from 1930, etc.)

12
Expired Drugs

• Inventory control on hazardous drugs is a must
• Returns kept separately
• Assume house-wide usage of hazardous drugs, not
  just chemotherapy use
• Manufacturing materials in pharmacy

13
Other Controls

• No tolerance policy on accepting free samples
  (whether paint or drugs)
• Physical inventories completed annually in every
  location
• Control vendor selection based on hazard (we
  want non-hazardous whenever possible)

14
Generator Status

• Describes the volume of waste generated by a
  hospital large to very small
• Requirements are built on knowing where your
  facility fits into these descriptions
• Exemptions for very small generations, provides
  some incentive to generate as little waste as
  possible

15
Waste Storage

• Hazardous waste requires segregation in areas
  appropriate to their inherent hazards.
• Keep the National Fire Prevention Association
  (NFPA) and local fire codes in mind they are
  also very specific as to types and locations of
  storage areas for hazardous wastes.

16
Moving waste to another home

• All hazardous waste must stay at a facility for a
  maximum storage time
• Lengths of time vary from 90 to 180 days, may be
  exceptions (depending on generator size)
• After those dates, it must leave the facility and
  go for treatment or disposal

17
Waste Disposal Vendors

• Hire reputable vendors
• Visit their facilities and call the regulators
  that the vendor must answer to.
• Understand exactly what the vendor will do to
  your waste, it is still your responsibility

18
Vendors May

• Refuse access to their facility
• Refuse waste diversion from a facility or
  technology that you wish to avoid
• Find someone else to do business with your
  facility will still be responsible for the safe
  final disposition of the waste

19
Documentation

• Some of the specialized training that Hazardous
  Waste Workers must receive covers the completion
  of waste manifests and document tracking.
• Includes tracking forms
• Includes taxation and reporting to state and
  federal agencies

20
In Conclusion

• Avoid generating hazardous waste whenever
  possible
• Recycle what universal wastes that are possible
  in your facility
• Keep materials separate to avoid cross
  contamination

21
Website Information

• RCRA On-Line
• http//www.epa.gov/rcraonline/
• Universal Wastes (federal EPA)
• http//www.epa.gov/epaoswer/hazwaste/id/univwaste
  .htm.