Hazardous Waste

• Hazardous Waste Determinations

• Managing Hazardous (RCRA) Wastes

• Generator Status, EPA ID

• Labeling

• Storage

• Internal Transportation

• Time Limits

• Inspections

• State Hazardous Waste Regulations

• Universal Wastes

• State Universal Waste Regulations

15 Most Common Hazardous Waste Violations and Problems Found at Hospitals

1. Improper or lack of hazardous waste (HW) labeling (see HW labeling)

1. No or infrequent weekly inspections of HW storage/satellite areas (see inspections)

1. Open containers of HW (go to container sealing requirement)

1. Improper disposal of chemotherapy drugs (go to hazardous waste determinations and see information for U-list waste)

1. Failure to perform or improper hazardous waste determinations (go to hazardous waste determinations)

1. No or inadequate HW manifests (go to hazardous waste manifest)

1. Throwing HW down the drain

1. Improper management of mercury-containing wastes, including but not limited to, fluorescent light bulbs, mercury vapor lights, thermometers, sphygmomanometer, gastric tubes, thermostats, etc. (go to mercury in healthcare facilities)

1. Improper management of expired pharmaceuticals, paints, etc. (go to pharmaceuticals in healthcare facilities)

1. Lack of a contingency plan (go to emergency planning)

1. Lack of or inadequate training of employees in HW management (go to personnel training)

1. Failure to ensure that HW meets Land Disposal Restrictions (go to shipping wastes off-site)

1. Failure to upgrade/close underground storage tanks (USTs) by 12/22/98 (go to UST inspection protocol)

1. Malfunctioning leak detection systems

1. Improper consolidation of wastes from nearby facilities

Source: EPA Region 2.