Managing Hazardous Waste: Cradle to Grave. Matthew Huray, CHMM, HEM

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2 Managing Hazardous Waste: Cradle to Grave Matthew Huray, CHMM, HEM

3 Purpose Provide an understanding of strategies to manage and reduce risks associated with hazardous waste.

4 Agenda Review the risks associated with being a hazardous waste generator. Characterizing and managing hazardous waste. Strategies for managing current and future risk as a hazardous waste generator.

5 Healthcare hazardous waste management challenges Staff handle lots of different regulated waste streams. Getting support from departments that infrequently generate small volumes of hazardous waste. Program focus is too limited to on-site hazardous waste management activities and costs.

6 The life of hazardous waste Identify Manage Cradle To Accumulate Transport Disposal Treatment Grave

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9 Hazardous waste generator responsibilities Identifying operations that generate hazardous waste. Properly characterizing wastes. Establishing a process to manage hazardous waste activities.

10 Hazardous waste identification Review department chemical inventory. Determine if materials used are characteristically or listed hazardous waste. Determine how the materials are used and if the waste is hazardous waste.

11 Hazardous waste management strategies Are there regulatory letters of interpretation? Are there regulatory exemptions or exclusions? Are there alternative management methods available? Universal waste Environmental Stewardship Program Reverse Distribution Elementary Neutralization

12 Hazardous waste characterization Be sure your evaluating the waste not the virgin product. Use generator knowledge or laboratory testing.

13 Common hazardous wastes generated by healthcare in California Silver Nitrate Sticks Spent Solvents Oncology Drugs Corrosives Mercury Preservatives M-Cresol Aerosol cans P-listed Warfarin Arsenic Trioxide Nicotine Wrappers Physostigmine

14 Healthcare specific hazardous waste management EPA has issued a letter of interpretation on determining p-listed waste volume. The residual volume of the active ingredient is counted, not the weight of the container. If residual volume is unknown, consider using the total active ingredient volume for the container.

15 Managing otherwise regulated wastes Wastes that are not hazardous waste but cannot be drain disposed or landfilled. Examples: glutaraldehyde, formalin Important to determine proper treatment and disposal and not over-characterize

16 Hazardous waste management Generator Status Counting how much hazardous waste is generated every calendar month. Implementing program requirements. On-site storage timeline. Contingency planning and training.

17 Hazardous waste training What are employees trained on? Regulations or function specific information? Who develops training content? How is the training delivered? Are manifest signers DOT trained?

18 Hazardous waste transportation It is important to know how your waste gets to the treatment and disposal facility Is your waste properly profiled? Who is transporting your waste? What modes of transportation are used? What routes are used to transport your waste?

19 Hazardous waste profiling Communicates physical and chemical hazards to transporter and treatment disposal facility Inaccurate profiling could result in improper treatment Opportunity to reduces risks by specifying treatment method for the wastes

20 Hazardous waste treatment and disposal Where is your waste going? Does your vendor own multiple facilities? What treatment method is being used for your hazardous waste? Is the facility permitted for the treatment method being used?

21 Using data to learn about your waste and your hazardous waste vendor Hazardous waste manifests Land Disposal Restrictions (LDR) Profiling documents Vendor waste data reports May provide additional levels of detail

22 Hazardous waste management vendor Are you dealing directly with a hazardous waste company or are you working with a broker? Do you know if you vendor subcontracts waste management functions to other vendors?

23 Benefits of vendor due diligence reviews To develop an understanding of: Compliance status Operational management Financial viability Community impact

24 Strategies to perform due diligence Establish a self-audit process Hire a consultant Join a consortium of other companies (i.e. CHWMEG)

25 Resources to perform due diligence Hazardous waste manifests Talk with state or federal regulators Site visits Securities Exchange Commission financial filings (10 K Reports) Electronic review using on-line databases EPA: ECHO RCRA Info California HWTS

26 Vendor due diligence considerations Scope of review Limited to treatment and disposal sites or include transporters? Review frequency? What will be done with the data? Who are the internal stakeholders?

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