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Preparing for a Hazardous Waste Inspection at your Medical Facility

Preparing for a Hazardous Waste Inspection at your Medical Facility. What to expect when a SCDHEC Inspector comes to your door. Clyde Buchanan. What is a hazardous waste inspection? What are the hazardous waste rules? What are the common RCRA problems at medical facilities?.

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Preparing for a Hazardous Waste Inspection at your Medical Facility

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  1. Preparing for a Hazardous Waste Inspection at your Medical Facility What to expect when a SCDHEC Inspector comes to your door Clyde Buchanan

  2. What is a hazardous waste inspection? • What are the hazardous waste rules? • What are the common RCRA problems at medical facilities?

  3. What is a Hazardous Waste Inspection? • SCDHEC inspectors look at “all”processes and procedures performed on a contiguous piece of property. • The inspectors are looking at what chemicals are used, how they are used, and what waste streams are expected from each process. • Inspections at Medical facilities are generally viewed as Easter Egg Hunts

  4. What is a Waste? Solid Waste - any solid, liquid, or containerized gas SPENT, INHERENTLY WASTE LIKE, CAN’T BE USED AGAIN, OR ABANDONDED

  5. Other wastes we regulate…. • Universal Wastes – fluorescent lamps, pesticides, batteries

  6. UNIVERSAL WASTE • Light Bulbs • Certain Pesticides • Batteries

  7. Solid wastes which are not hazardous waste…. Household Waste Bio-Medical Waste Nuclear wastes Laboratory Samples (stored in Lab.)

  8. Step 1:Hazardous Waste Identification What is a Hazardous Waste?

  9. Hazardous Wastes • Listed • Non Specific Sources • Specific Sources • Commercial Chemicals • Characteristic • Ignitability • Corrosivity • Reactivity • Toxicity

  10. Characteristic Hazardous Waste (D-List) Ignitibility – D001 (40 CFR 261.21): Flash point less than 140oF or greater than 24% alcohol; Solid which will ignite through friction, absorption of moisture, or spontaneous combustion; Ignitable compressed gas Corrosivity – D002 (40 CFR 261.22): pH less than or equal to 2 or greater than or equal to 12.5 Reactivity – D003 (40 CFR 261.23): In contact with water, shock, heat or pressure, the material may undergo a rapid or violent chemical change

  11. Characteristic Hazardous Waste (D-List) continued…. Toxicity -D004-D043 (40 CFR 261.24): toxicity levels must be over TCLP concentrations NOTE: Toxicity is determined by TCLP test for presence of 40 chemicals.

  12. TCLP CONCENTRATIONS 40 CFR 261.24 (TABLE 1)

  13. Hazardous Wastes Common Characteristic Wastes: • Photographic Fixer waste (silver-D011) • Spent solvents from labs (ignitability-D001) • Caustic/acid solutions (corrosivity-D002) • Fluorescent lamps (mercury-D009)

  14. Listed Hazardous Waste • F List – F001-F028 (40 CFR 261.31): Wastes from • non-specific sources, i.e. spent solvents. • K List – K001-K172 (40 CFR 261.32): - Wastes from specific sources i.e. sludges and distillation bottoms from wood preserving and petroleum refining. • P (acutely toxic) or U (toxic)List (40 CFR 261.33): Pure chemical or sole active ingredient that is discarded, spilled, off specification or container residue.

  15. Hazardous Wastes Common Listed Wastes: • Paint/debris related wastes (F001-F005) • Spent solvents (F001-F005) • Off-spec chemicals (laboratory) (P & U list) • Rags contaminated with listed solvents (F001-F005) • Expired Pharmaceuticals (P & U list) • Plating sludges (F001-F005)

  16. Waste Codes • Walk through the entire process to determine the proper waste codes • Codes must be included on the manifest • Codes indicate the type of treatment for proper disposal of the waste. U019-Benzene F003-listed solvents D002-Corrosive D018-Benzene 0.5mg/l P075-Nicotine D008-Lead 5mg/L F007-Cyanide plating bath

  17. Waste DeterminationsSummary • Is it Listed? • Is it Characteristically Hazardous? • Testing • Product or Process Knowledge (backed with documentation) • MSDS May be usefull

  18. WHO CAN HELP? • Material Suppliers - MSDS's • Trade Associations and Publications • Hazardous Waste Transporters / Brokers • Government Agencies and Publications

  19. Step 2: • Hazardous Waste Generators • Determining Size • Classifications • Management Standards

  20. Status by Month • Counts for calendar month it was generated in • Unless you keep specific records, got to go by ship out dates • Meet standards of generator status for current month

  21. Determine Generator Size Count Hazardous Waste That: • Is Transported Off-Site for Treatment, Storage, or Disposal • Is Treated or Disposed of On-Site(unless exempt) • Is Accumulated Prior to Recycling, Long-Term Storage, Transporting, Treatment or Disposal

  22. To Determine Generator Size (cont) Don’t Count: • Spent Lead Acid Batteries that Will Be Sent for Reclamation • Used Oil That Has Not Been Mixed with Hazardous Waste and Is Recycled • Fluorescent Bulbs Sent for Recycling

  23. Laboratories Dental Clinics X-rays Units Nuclear Medicine Areas Pharmacy Maintenance Areas Physical therapy Vehicle/Fleet Maintenance Laundry Morgue Operating Rooms Nursing Units Medical Technology Unit Construction Areas Grounds Keeping Hazardous Waste (40 CFR Parts 260-282)

  24. Generator categories SCDHEC Recognizes three categories of generators: Conditional exempt small quantity generator Small Quantity Generator Large Quantity Generator

  25. CONDITIONALLY EXEMPT SMALL QUANTITY GENERATOR • Generates no more than 100 kg (220 lbs) of hazardous waste per month. *Approximately ½ a 55-gallon drum, or about 25 gallons based on weight of a gallon of water. • Generates less than 1kg (2.2 lbs) of acutely toxic hazardous waste (P-listed) per month • Never accumulates on site more than 1000 kg (2200 lbs) of hazardous waste at any time. CESQG

  26. CESQG Requirements • Perform Hazardous Waste Determination • Ensure Delivery of Hazardous Wastes to Proper Handling Facility.

  27. SMALL QUANTITY GENERATOR • Generates less than 1kg (2.2 lbs) of acutely toxic hazardous wastes per month. • Generates more than 100 kg (220 lbs), but less than 1000 kg (220 lbs) of hazardous waste per month. • Never exceeds the 6000 kg (13,200 lbs)/180 day storage time limit. SQG

  28. SQG Requirements • Obtain EPA ID Number • Use Manifest System Unless Reclamation Agreement Is Established • Keep Records for 3 Years • Label & Date Hazardous Wastes Properly • Have a Modified Contingency Plan • Train Personnel About Proper HW Handling & Emergency Response • Meet Tank Requirements • Meet Satellite Accumulation Requirements • Notification of Local Emergency Authorities

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