PURPOSE:

The New Hampshire Department of Environmental Services (Department) receives many inquiries concerning the regulatory status of veterinary chemicals/materials that are considered hazardous waste. The purpose of this fact sheet is to clarify the Department's position regarding the management of wastes generated by veterinary facilities.

GENERAL GENERATOR REQUIREMENTS:

1. What is a hazardous waste?

   A hazardous waste is any waste which, because of its chemical or physical makeup or because of its potential for mismanagement, may pose a threat to human health or the environment. How do you know if your waste is hazardous or whether it can be managed simply as a solid waste? First, you determine whether the waste is exempt from the rules, which can be done by viewing the specific exemptions found at Env-Wm 401 of the NH Hazardous Waste Rules. Secondly, if the waste is not exempt, you should look at the lists of wastes found at Env-Wm 402.04 through 402.07. If you find your waste listed, it is automatically a hazardous waste. If not listed, then you have to determine whether the waste exhibits any of the hazardous waste characteristics described in Env-Wm 403.03 through Env-Wm 403.06 (ignitability, corrosivity, reactivity, or toxicity). Finally, be aware that your waste may be a "hazardous waste mixture" per Env-Wm 404.01. This occurs when a solid waste is mixed with a hazardous waste. Additional information on hazardous waste mixtures or characteristics may be found on DES Fact Sheet WMD-HW-11 which will guide you through the hazardous waste determination process.

2. What is a Hazardous Waste Generator?

   A "generator" is any person who owns or operates a facility where hazardous waste is generated. Generators in New Hampshire are classified as either Small Quantity Generators (SQGs) or Full Quantity Generators (FQGs).

   1. Small Quantity Generator (SQG): A generator who produces less than 100 kgs. of hazardous waste per month, or who produces less than 1 kg. of acutely hazardous waste per month.

   2. Full Quantity Generators (FQG): A generator who produces greater than 100 kgs. of hazardous waste per month or greater than 1 kg. of acutely hazardous waste per month.

3. Are veterinarian chemicals/materials considered hazardous waste?

   Some spent veterinarian chemicals/materials are considered hazardous wastes and some are not. Persons generating such wastes should contact the supplier to obtain material safety data sheets (MSDS) pertaining to the products they use. The MSDS should list any hazardous constituents and hazardous characteristics of the product. The MSDS should also indicate the waste disposal method under Section VII - "Spill or Leak Procedures - Waste Disposal Method". Most MSDSs also include a number to call to obtain more information from the manufacturer. In addition, wastes may require testing to determine if they are hazardous wastes. All analyses should be performed on the spent material (i.e., the waste).

4. How must hazardous waste be managed?
   1. If a waste is hazardous and must be transported to a treatment, storage, or disposal facility, the generator must first obtain an EPA identification number. This number can be obtained by calling the Department's Reporting Section ((603) 271-2900). Prior to transport, hazardous wastes may generally be stored on-site without a permit for up to ninety (90) days from the date that waste is first deposited in the container. Specific guidelines must be met during this ninety (90) day storage period.

   2. Generators must use the federal/state manifest form when shipping hazardous waste.

   3. The hazardous waste must be transported to an authorized facility via a New Hampshire registered Hazardous Waste Transporter.

   PHOTOPROCESSING WASTE:

5. Are waste photoprocessing solutions considered hazardous wastes?

   Some spent photoprocessing solutions are considered hazardous wastes, and some are not. Persons generating photoprocessing wastes that are hazardous should follow the same procedure as described in question #4. For more information on the proper management of photoprocessing wastes, please refer to DES Fact Sheet WMD-HW-2.

   INFECTIOUS WASTE:

6. How should infectious waste be handled?

   All infectious wastes that do not also meet the definition of hazardous wastes must be adequately treated before disposal to meet the standards in Section Env-Wm 2604.03(a) of the NH Solid Waste Rules. Those wastes include needles, syringes, vaccines and laboratory cultures.

   For more information on the regulatory requirements for managing infectious wastes, contact the Department's Solid Waste Compliance Section at (603) 271-2925.

   CHEMOTHERAPY WASTES:

7. How should chemotherapy wastes be handled?

   Medications, containers, etc. may be hazardous or acutely hazardous wastes depending on constituents. Contents should be checked against the listed wastes found in Ch. Env-Wm 400. Chemotherapy wastes containing listed hazardous constituents should be managed as a hazardous waste as discussed in question #4.

This summary provides general information only. Other fact sheets that may be of interest to veterinarians include information on photoprocessing wastes and general information on small quantity generator hazardous waste management requirements. To receive a copy of any other available fact sheets or to receive other information, please contact the Department's Waste Management Division at (603) 271-2942. For a complete description of the requirements, refer to New Hampshire's Hazardous Waste Rules, Env-Wm 100-1000, which may be obtained by contacting the Department's Public Information and Permitting Office at 29 Hazen Drive, Concord, New Hampshire 03301. Telephone: (603) 271-2975.