Managing Waste in a Health Care Setting

Pharmaceutical collection
Photo courtesy Milwaukee Metropolitan Sewerage District

Health care facilities generate a number of different types of waste, some of which pose risks to human health or the environment if not managed properly. Different types of waste should be separated and managed according to the instructions below. It is your facility's responsibility to properly identify and manage all the types of waste you generate.

Hazardous Waste

Hazardous waste is a waste with properties that make it dangerous or potentially harmful to human health or the environment. By state and federal law, a waste is hazardous if it is specifically listed as a hazardous waste or if it exhibits a hazardous characteristic.

The list of hazardous wastes are:

  • F-listed wastes are from common industrial and manufacturing processes;
  • K-listed wastes are from specific industry processes; and
  • P- and U-listed wastes are discarded, unused chemical products and formulations.

Examples of F-listed wastes include spent solvents, such as xylene and acetone. Some drugs are P-listed acute hazardous waste which means they pose severe risk to human health and the environment. Some unused chemotherapy drugs are listed as P- or U waste. Because of the increased hazards, more stringent standards apply to P-listed wastes and containers or packaging that held P-listed pharmaceuticals.

Characteristics of hazardous waste include ignitability, corrosivity, reactivity and toxicity. Waste alcohol may exhibit the hazardous waste characteristic of ignitability. Aerosols may also be ignitable hazardous waste because of the contents or the propellant used. Mercury-containing wastes, such as vaccines preserved with thimerosal, generally exhibit the toxicity characteristic. Strong acids and bases are hazardous waste because of corrosivity. Picric acid or ethyl ether may exhibit the characteristic of reactivity. For more information, see hazardous waste rules, ch. NR 661, Wis. Adm. Code.

Proper Hazardous Waste Management

Hazardous waste can be a relatively small percentage of the waste generated by health care providers; however, all hazardous waste must be managed appropriately. There are three steps to the proper management of hazardous waste.

  1. Identify which wastes are hazardous and why (are they listed or do they have one or more of the characteristics?). This is called "making a waste determination."
  2. Determine the generator classification by counting the hazardous waste generated by all of the different departments in the health care facility. The quantity and types of waste generated determine the generator classification and the requirements that apply to your facility. For example, generating even small quantities of P-listed acute hazardous wastes can mean more stringent requirements.
  3. Manage the hazardous waste according to the requirements, which are based on your facility's hazardous waste generator classification. The specific requirements for very small, small and large quantity generators are stated in Wisconsin hazardous waste rules, ch. NR 662, Wis. Adm. Code, [PDF 138KB, exit DNR].

The three hazardous waste generator classifications are:

  1. Very Small Quantity Generator (VSQG): generates 220 pounds or less per month non-acute hazardous waste and less than 2.2 pounds per month acute hazardous waste.
  2. Small Quantity Generator (SQG): generates between 220 pounds and 2,205 pounds per month non-acute hazardous waste and less than 2.2 pounds per month P-listed acute hazardous waste.
  3. Large Quantity Generator (LQG): generates 2,205 pounds per month or more non-acute hazardous waste or 2.2 pounds per month or more acute hazardous waste.

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Universal Waste

Universal wastes are specific hazardous wastes that many types of businesses generate. To encourage the recycling of these wastes, a special set of regulations reduces requirements for collection and transportation while still ensuring proper management of the waste.

Examples of universal wastes include fluorescent lamps, batteries, mercury containing devices (sphygmometers and thermometers), certain pesticides and in Wisconsin, antifreeze.

Facilities can send universal wastes to recyclers that reclaim materials from the waste, such as mercury from thermometers or nickel and cadmium from batteries. For information regarding the management of universal waste, see Wisconsin universal waste rules, ch. NR 673, Wis. Adm. Code, [PDF 82KB, exit DNR].

The requirements for managing universal waste depend on whether you are a small or large quantity handler. Small quantity handlers of universal waste are those facilities that accumulate less than 11,025 pounds (5,000 kg) of universal waste at any time. Large quantity handlers accumulate 11,025 pounds or more of universal waste. To determine if you are a small or large quantity handler of universal waste, count the amount of all universal wastes accumulating at your facility.

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Solid Waste

Solid wastes include all wastes that are not classified as hazardous or universal waste and include wastes generated by industrial, manufacturing or non-manufacturing activities. Solid waste can be in a liquid, gas or "solid" state. Most solid waste generated in Wisconsin is disposed of in landfills or recycled. An example of solid wastes is food packaging material.

Proper Disposal is Important

Nonhazardous pharmaceuticals, including most hormones, antibiotics, antidepressants and chemotherapy drugs, should be disposed of by appropriately authorized incineration regardless of their classification as hazardous or solid waste.

Send non-hazardous solid waste to a solid waste landfill that is approved to accept it. Some landfills can accept only certain types of waste, such as construction and demolition debris. Work closely with your waste hauler and disposal facility to determine how to evaluate, profile and deliver each solid waste generated at your facility.

To minimize environmental contamination, Wisconsin law prohibits the disposal of liquids in solid waste landfills. Nonhazardous liquid waste, such as latex paint, can be solidified, either on-site or off-site, before it is landfilled.

When evaluating a waste, take into account the known environmental and health effects of the waste. If the material is not a hazardous waste, but the Material Safety Data Sheet (MSDS) or container label warns of aquatic toxicity, carcinogenic, mutagenic, or teratagenic properties, the material should be sent to a hazardous waste, medical waste or solid waste incinerator approved to take the waste.

Recyclable Materials

Wisconsin businesses and institutions cannot dispose of recyclable materials such as paper, newspaper, magazines, cardboard, aluminum cans, plastic bottles, steel ("tin") containers and glass containers in a solid waste landfill. Your facility should have collection and recycling programs in place for these materials, including procedures for ensuring that recyclables are not contaminated with hazardous or infectious materials. Keep in mind that you may also be able to recycle other wastes generated at your facility, such as empty containers and electronic equipment. For additional information on establishing recycling programs and managing recyclables in a health care setting, see the links below.

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Infectious Waste

Infectious waste is solid waste that has the potential to transmit disease and includes:

  • sharps;
  • human tissue, blood and body fluids;
  • microbiological laboratory waste; and
  • tissue, blood or body fluids from animals carrying a zoonotic infectious agent.

Infectious waste, also known as biohazardous or red bag waste, must be segregated from other waste types and disinfected before it is disposed of in a solid waste landfill. For more information, see Infectious Waste vs Medical Waste.

Some wastes can be both hazardous waste and infectious waste. For example, laboratory samples of blood mixed with a reagent containing mercury is both an infectious waste and a characteristic hazardous waste. Send wastes that are both hazardous and infectious waste to a hazardous waste facility that can also handle infectious waste.

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Medical Waste

Medical waste is defined in Wisconsin statutes as "infectious waste and other wastes that are contaminated or mixed with infectious waste". Unless exempt, medical facilities, including hospitals, clinics and nursing homes, must develop and implement a medical waste reduction plan to reduce the amount of medical waste generated, prevent the mixing of infectious waste with non-infectious waste and promote practical alternatives to using disposable items. To ensure waste reduction, a facility must conduct audits of its solid waste management practices at least every five years. Provide information on the implementation of the waste reduction plan by submitting the Infectious Waste Annual Report to the DNR.

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Chemotherapy Waste

Chemotherapy waste is waste contaminated with chemotherapy drugs, such as drug dispensing devices, gloves and other items that have come into contact with chemotherapy drugs. Trace chemotherapy wastes are items contaminated with residual amounts of chemotherapy drugs, such as gloves and gowns. Bulk chemotherapy waste is any waste contaminated with more than residual amounts of chemotherapy drugs. Manage trace chemotherapy waste separately from other waste types. If chemotherapy waste is mixed with nonhazardous solid waste or infectious waste, manage the mixture as trace chemotherapy waste. Evaluate trace and bulk chemotherapy waste to determine if it may be listed or characteristic hazardous waste. Properly containerize, label and incinerate all trace chemotherapy waste. The rules for trace chemotherapy waste are found in s. NR 526.055 (see link to ch. NR 526 above).

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Radioactive Waste

Radioactive wastes contain radioactive materials and can be solids, liquids or gases. Radioactive waste can be generated in nuclear medicine, nuclear cardiology, radiation oncology, blood banks, clinical laboratories and research laboratories. For information on the management of radioactive materials, see Wisconsin Department of Health Services (DHS) [exit DNR].

For radioactive wastes generated by health care facilities, there are four primary management options:

  1. decay in storage;
  2. discharge to a sanitary sewer with permission from sewer authority;
  3. ship to a radioactive waste disposal facility; and
  4. return to vendor.

Occasionally, facilities will generate "mixed waste." Mixed waste is waste that contains both hazardous waste and radioactive material and must be managed in accordance with both U.S. Nuclear Regulatory Commission (NRC) and DNR or U.S. EPA rules. For information on the regulation of mixed wastes, see subch. N of ch. NR 666, Wis. Adm. Code, [PDF 266KB, exit DNR].

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Other Wastes Commonly Generated at Health Care Facilities

Some additional types of wastes that health care facilities may generate include the following:

  • Asbestos containing wastes, such as some floor tiles, glues, mastics, acoustical ceiling tiles and pipe insulation, are subject to air management and solid waste regulations. For information on asbestos abatement and disposal requirements, see DNR Asbestos Program.
  • Electronic waste, commonly called "e-waste," includes electronic devices such as cell phones, TVs, computer equipment and diagnostic equipment. Electronic devices can contain heavy metals such as lead, cadmium, chromium, nickel and mercury. Businesses must either recycle electronics or manage them as hazardous waste, unless they can show that the devices are not hazardous waste. For more information about recycling electronics, see Managing Used or Discarded Electronics.
  • Used oil, including lubricating oil, penetrating oil and turbine oil, is regulated under ch. NR 679, Wis. Adm. Code, [PDF 127KB, exit DNR]. Store used oil in containers or tanks that are in good condition and labeled with the words "used oil." Do not mix used oil and hazardous waste; the mixture may need to be disposed of as hazardous waste rather than recycled as used oil. Used oil above-ground or underground storage tanks are regulated by the Wisconsin Department of Commerce. For information on storing used oil in tanks, see Commerce's Web page on the topic [exit DNR]. If used oil is burned in an on-site space heater, see the DNR fact sheet Burning Used Oil in a Space Heater (PUB WA1003) [PDF 72KB].
  • Pharmaceutical Waste

Contact Information

For questions and comments about managing waste in a health care setting, please contact:

DNR Waste Materials@Wisconsin.gov

Last Revised: Thursday January 22 2009