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New Hampshire Department of Environmental Services
PUBLIC GOVERNMENT BUSINESS A to Z LIST

Frequently Asked Questions

Healthcare facilities generate a variety of waste that can be classified as hazardous, solid and/or infectious. Sometimes managing a particular waste appropriately can be confusing. Is it an infectious waste? Maybe it should be disposed as a solid waste? How are other New Hampshire facilities managing the waste?

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Guidelines for disposal are based on New Hampshire’s Administrative Rules.

 
  • Antibiotics

    Dispose of as a solid waste. It is not recommended to discharge to sewer.

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  • Arsenic Trioxide
    Several New York hospitals have been fined recently for mismanagement of arsenic trioxide, a pharmaceutical waste listed as P012. The violations included improper storage or disposal of the waste. Specifically, storage containers were unclearly labeled, storage of the waste was unpermitted, and emergency response information was not posted. P-listed contaminants are considered by the Environmental Protection Agency (EPA) to be "acutely hazardous", the worst of the worst. Just 1 kilogram, or 2.2 pounds, of P-listed waste generated per month classifies a facility as a full quantity generator. Containers that formerly contained P-listed waste are not considered empty by RCRA standards until they have been triple-rinsed with solvent and the rinsate has been discarded as hazardous waste.

    For more information: Management of P-listed chemicals.

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  • Barium Sulfate
    Barium sulfate is not a listed RCRA hazardous waste, but depending on the concentration of barium, it may exhibit a toxic characteristic of hazardous waste. Do not incinerate; barium sulfate (CAS # 7727-43-7) is a listed air toxic. Do not discharge to sewer; barium sulfate is insoluble in water. It is not recommended to dispose of barium sulfate with "red" bag waste.

    Options include disposing barium sulfate as a:

    1. Hazardous Waste (D005) - If barium concentration is greater than 100.0 mg/L.
    2. Solid Waste – If barium concentration is less than 100.0 mg/L.

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  • Cerrobend also known as Lipowitz Alloy
    Cerrobend, also known as lipowitz alloy, is used to protect vital-critical organs inside the radiated area during radiotheraphy applications. Cerrobend contains approximately 27 percent of lead (D008) and 10 percent of cadmium (D006) by weight. Lead and cadmium are both listed hazardous wastes.

    Suggested guidelines for cerrobend:

    1. Reclaim alloy for reuse. Contact a scrap metal dealer for more information.
    2. Dispose of as a hazardous waste.

    Other disposal methods of cerrobend that are not an option:

    1. Do not incinerate; lead and cadmium are listed air toxic pollutants.
    2. Do not dispose of in solid waste or with infectious waste.
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  • Chemotherapy Spills on Carpet
    Some chemotherapy products are classified as hazardous materials. The list of chemotherapy products that are considered hazardous are found on Management and Disposal Guidelines for U-Listed Antineoplastic (chemotherapy) Waste Adobe Acrobat Reader Symbol. If a hazardous waste product spills on the carpet, it must be managed according to the Hazardous Waste Rules.

    Suggested guidelines for proper management of chemotherapy spills on carpet include:

    1. If a powder or other substance is used to clean the area, the cleaning powder would then be considered hazardous waste and would need to be disposed of appropriately.
    2. A carpet that has come in contact with chemotherapy waste should be managed as a hazardous waste.
    3. Do not vacuum a chemo-contaminated carpet. If a chemo-contaminated carpet is vacuumed, the vacuum cleaner would then need to be tested to determine if it has become contaminated; thus, hazardous waste. If so, it would need to be disposed of appropriately.
    4. Do not dispose of powder, carpet, or other substances used to clean chemo-contaminated waste in yellow chemo containers. These items are not considered chemo waste, but hazardous waste and should be treated as such.
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  • Cooking Oil and/or Grease Waste
    Cooking oil is included under the definition of "oil" by the US Environmental Protection Agency (EPA). Cooking oil is also described as a potential contamination source under the New Hampshire Department of Environmental Services Env-Wq 401 Best Management Practices for Groundwater Protection. Based on EPA’s definition and as a potential contamination source, cooking oil should be managed to reduce spillage to the ground or water.

    Cooking Oil and/or Grease Waste Storage
    Containers with a capacity of greater than or equal to 5 gallons shall be:

    • Stored in an area having an impervious surface.
    • Secured against unauthorized entry.
    • Inspected weekly for leaks and/or spills.
    • Labeled.
    • Aisle space between containers should have ample size to allow an inspector to determine the condition of containers.
    • In outdoor storage areas, containers;
      • Should be kept undercover.
      • Have secondary containment.
      • No closer than 50 feet to a storm drain, unless there is secondary containment.
    • Spill control and containment equipment readily available.

    Since cooking oil is included under the definition of "oil" by EPA, containers that have a capacity of 55-gallon or greater will count to the threshold limit of the Spill Prevention, Control and Countermeasure (SPCC) Rule. If the facility stores oil in aboveground tank(s)/container(s) with a total aggregate volume over 1,320 gallons, the facility is required to have a SPCC plan.

    Consider recycling your cooking oil waste through a rendering and/or grease trap company. Adobe Acrobat Reader Symbol

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  • Duragesic (Fentanyl) Patches and Injections

    According to environmental rules, fentanyl can be disposed of as a solid waste. However, fentanyl is a controlled substance and healthcare providers should manage fentanyl in accordance with DEA rules.

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  • Formaldehyde/Formalin
    Unused formaldehyde is a listed hazardous waste (U122) and must be managed according to the hazardous waste rules.

    Suggested guidelines for used formaldehyde:

    1. Dispose of as a non-hazardous waste through a hazardous waste transporter.
    2. Do not incinerate; formaldehyde is a listed air toxic pollutant.
    3. Discharge to sewer, after verifying discharge permit and authorization from wastewater treatment facility.

    For alternative formaldehyde-free products, go to Sustainable Hospitals.

    For formalin recovery in health care labs, go to the Minnesota Technical Assistance Program.

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  • Glutaraldehyde
    Although not a listed hazardous waste, glutaraldehyde (D002) may exhibit a hazardous waste characteristic (e.g., D002 corrosive if pH is <2). Suggested guidelines for glutaraldehyde disposal:
    1. If it exhibits hazardous waste characteristics, dispose as a hazardous waste.
    2. If it does not exhibit hazardous waste characteristic:
      • Do not incinerate; glutaraldehyde is a listed air toxic pollutant.
      • Do not dispose of as an infectious waste.
      • Dispose of as a non-hazardous waste through a hazardous waste transporter.
      • Discharge to sewer, after verifying discharge permit and authorization from wastewater treatment facility.
    For alternatives to glutaraldehyde, go to Sustainable Hospitals.
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  • Hazardous Waste Mixture Rule
    A hazardous waste mixture is defined in section Env-Wm 404.01 of the New Hampshire Hazardous Waste Rules.

    A hazardous waste mixture is a combination of a hazardous waste and another waste or material. One of the components of the mixture must be determined to be a hazardous waste before mixing occurs.

    Mixtures that are regulated as hazardous waste:

    1. Any waste or material that is mixed with any listed waste. A listed waste is identified by the P-, U-, F-, or K- waste numbers. Typically, healthcare facilities generate P- or U- listed wastes, such as epinephrine (P042) or mitomycin C (U010); or
    2. Any waste or material that is mixed with a waste that exhibits a hazardous waste characteristic, and after being combined, the mixture continues to exhibit a hazardous waste characteristic. A characteristic waste is identified with a D- waste number and includes the hazardous waste characteristics of ignitability, corrosivity, reactivity and toxicity.

    When two wastes are mixed and one of them is a hazardous waste, then follow guidelines from the hazardous waste mixture rule.

    Waste A + Hazardous Waste B = Hazardous Waste Mixture AB

    The quantity of listed waste mixed with another waste or material is not a factor in determining whether that mixture is a hazardous waste. The entire mixture becomes a listed hazardous waste even if the mixture only contains a small percentage of the listed waste.

    Do not confuse the hazardous waste mixture rule with unused pharmaceutical formulations. These pharmaceutical formulations are prepared before any of the components of the formulation becomes a waste. The waste in a partially used IV bag is its "own" waste. The generator determines the waste classification.

    Product A + Product B = Product C

    Unused Product C is not a hazardous waste mixture. When unused Product C becomes a waste, it will need a hazardous waste determination.

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  • Instant Hand Sanitizers Containers and Residues
    Although not a listed hazardous waste, instant hand sanitizer residues (ethyl alcohol/ethanol D001) may exhibit a hazardous waste characteristic (e.g., D001 ignitable if flashpoint is < 140 F). Suggested guidelines for residue disposal:
    1. "Empty" containers can be disposed of as solid waste or recycled, if
      • All wastes have been removed using practices commonly employed to remove materials from that type of container, such as pouring, pumping, and aspirating; and
      • No more than 3 percent by weight of the total capacity remains in the container.
    2. Residues removed from empty containers should be managed as a hazardous waste if the residues exhibit a hazardous waste characteristic. If the generator is "squeezing out" the residues and collecting the residues in another container, then the residues are considered a hazardous waste if they are to be disposed of and then must be managed appropriately.
    3. Do not incinerate; ethanol is a listed air toxic pollutant.
    4. Residues cannot be discharged to sewer.
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  • Iodine Contrast Solutions
    Although not a listed hazardous waste, iodine contrast solutions may exhibit a hazardous waste characteristic (oxidizer D001). Suggested guidelines for iodine contrast solution disposal:
    1. If it exhibits a hazardous waste characteristic, dispose as a hazardous waste.
    2. If it does not exhibit hazardous waste characteristic:
      • Do not dispose as an infectious waste.
      • Do not incinerate; iodine is a listed air toxic pollutant.
      • Dispose of as non-hazardous waste through a hazardous waste transporter.
      • Discharge to sewer.
        • Verify discharge permit and authorization from wastewater treatment facility.
        • May need to neutralize with thiosulfate prior to discharge. Facility can only neutralize iodine contrast solution if it is non-hazardous waste.
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  • Lidocaine Drips

    Dispose of as a solid waste. It is not recommended that lidocaine be disposed of in the sewer.

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  • Low-Level Mixed Waste
    Mixed waste is hazardous waste containing radioactive waste. The Environmental Protection Agency (EPA) is providing increased flexibility to facilities for managing low-level mixed waste. EPA is exempting low-level mixed waste from RCRA storage and treatment requirements, such as the 90-day storage limit for hazardous waste, as long as the waste is generated under a single Nuclear Regulatory Commission license, meets the conditions specified, and is stored in a tank or container.

    New Hampshire Department of Environmental Services will be updating the Hazardous Waste Rules to reduce regulatory burdens by exempting qualified mixed-waste generators from certain hazardous waste requirements.

    In the mean time, healthcare facilities that are full quantity hazardous waste generators will need to apply for a waiverMicrosoft Word Symbolto increase storage limits to manage mixed waste.

    For more information on the mixed waste rule update, contact the RCRA hotline at (603) 271-2942 or hwcomp@des.nh.gov. Further information can be obtain from the EPA Environmental Fact Sheet Low-level Mixed Waste Conditionally Exempt form Hazardous Waste Regulation Adobe Acrobat Reader Symbol.

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  • Mitomycin C
    Unused mitomycin C is a listed hazardous waste (U010) and must be managed according to the Hazardous Waste Rules.

    Suggested guidelines for used mitomycin C:

    1. Dispose of as a non-hazardous waste through a hazardous waste transporter.
    2. Discharge to sewer, after verifying discharge permit and authorization from wastewater treatment facility.
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  • Nicotine Patches
    Nicotine (P075) is a listed hazardous waste and is the sole active ingredient in nicotine patches.

    Unused nicotine patches with an expired shelf life should be disposed as a hazardous waste.

    Used nicotine patches are considered "used" for intended purposes and are not classified as a hazardous waste. The foil packaging/wrappers are not considered to be a "container" and are not classified as a hazardous waste. Dispose of used nicotine patches and their wrappers with solid waste "trash."

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  • Products that contain mercury preservatives

    Mercury preservatives can be found in nose-, eye-, and eardrops, eye ointments, topical medications, antiseptic sprays, vaccines, antitoxins, tuberculin tests, and desensitization solutions. While mercury is a listed toxic waste (D009), waste products that contain mercury preservatives should be managed appropriately. (Env-Wm 100-1100) Do not discharge to sewer. Do not incinerate.

    1. Manage and dispose of as hazardous waste if the mercury's concentration limit is greater than or equal to 0.2 mg/L.
    2. Manage and dispose of as non-hazardous waste through a hazardous waste transporter.

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  • The RCRA "Empty" and "3 Percent" Rule
    Empty Containers, as defined in Env-Wm 401.03(h) and (i)

    Containers, IV bags, vials and inner liners that have held U-listed hazardous waste are deemed empty when:

    1. All the wastes have been removed that can be removed, and
    2. No more than one inch of residue remains on the bottom of the container or inner liner, and
    3. No more than 3 percent by weight of the total capacity of the container remains in the container or inner liner if the container is less than or equal to 110 gallons in size.
    4. Any residues removed from the empty container are managed to regulation under the Hazardous Waste Rules.
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  • Sodium Azide Containing Agars
    Sodium azide (P105) is a listed hazardous waste and it is commonly found in a variety of agars. If sodium azide is the only active ingredient, then unused sodium azide containing agars should be disposed of as a hazardous waste. However, sodium azide is usually not the only listed active ingredient in the agars.

    Unused sodium azide containing agars with two or more active ingredients should be disposed of as a non-hazardous waste through a hazardous waste hauler.

    Suggested guidelines for used sodium azide containing agars:

    1. Sterilize or autoclave the agar and plate/container.
    2. Dispose of as a non-hazardous waste through a hazardous waste hauler or dispose of as a solid waste with permission of solid waste vendor.

    Other disposal methods of used or unused sodium azide containing agars that are not an option:

    1. Do not incinerate; sodium azide is a listed air toxic pollutant.
    2. Do not discharge to a drains consisting of metallic pipes and solder. The pipes may become contaminated with metal azide salts, which can be shock sensitive.
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  • Specimen Bags
    Some healthcare facilities use plastic bags to transport specimen containers from patient care areas to inhouse laboratories. The healthcare facilities label the plastic bag "biohazard" and dispose of the plastic bag as infectious waste.

    If not contaminated, the plastic transport bags are not considered infectious waste and may be disposed of as solid waste. However, if the bags are labeled "biohazard," healthcare facilities run the risk that the solid waste hauler might refuse to transport the waste because of the belief that the bags are infectious.

    Biohazard labeled plastic bags used as secondary containment for internal transport of specimens is not required by OSHA. The labeling exemption, listed in 29 CFR 1910.1030 (d)(2)(xxii)(A) of the Occupational Exposure to Bloodborne Pathogens, applies to facilities that handle all specimens with Universal Precautions, provided the containers are recognizable as containing specimens. The exemption applies only while these specimens remain within the facility. If the specimens leave the facility, a label or red color-coding is required. In addition, secondary containers or bags are only required if the primary container is contaminated on the outside.

    To reduce red bag waste:

    1. Only use secondary containment when the outside of the specimen container is contaminated.
    2. Only use labeled biohazard bags if the specimen is leaving the facility.

    Guidelines for disposal are based on New Hampshire's Administrative Rules.

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  • Suction Canister Waste
    Suction canisters are single-use devices used in hospital operating rooms. Used suction canisters contain infectious waste and therefore must be managed according to Env-SW 904. In a recent study, up to 40 percent of the infectious waste generated from operating rooms is suction canister waste. Because a solidifying material is usually added to the canister, there is an additional exposure risk for the employee having to add the solidifier.

    New Technology Alternatives

    There are new alternatives available that allow hospitals to discharge their suction canister wastes from certain medical procedures to a sanitary sewer system. A permit or permission from the wastewater treatment facility is required prior to discharge to a public sewer.

    These new, canister-free vacuum systems have many benefits. They reduce:

    1. The amount of waste being discarded.
    2. The amount of infectious waste needing to be shipped out.
    3. The amount of materials being purchased.
    4. The risk of employee exposure to infectious waste.

    Listed below are some of the new systems that are available. The Department of Environmental Services does not endorse any of these products, they are provided as a pollution prevention alternative.

    1. Environ-mate DM6000 by MD Technologies contact: 815-598-3143 or www.mdtechnologiesinc.com. This system is canister-free, has a holding capacity up to 3300cc, and is self-cleaning. This unit costs between $2,500-$6,000, which includes installation. Unit is hard-plumbed into the facility.
    2. Neptune Waste Management System by Stryker Instruments contact: (800) 253-3210 or http://www.stryker.com/. These canisters are reusable and hold up to 20,000cc. They cost approximately $22,500. There is no installation required, and this system is portable. Units are self cleaning, and need to be emptied when full or at the end of each day.
    3. Transposal by Dornoch Medical Systems, Inc. contact: (888) 466-6633 or www.dornoch.com. The canisters are reusable, and hold 3,000cc. This unit costs approximately $19,000. There is no installation required, and the unit is portable. This unit flushes collected fluids down the drain and cleans canisters with a mixture of disinfectant and water.

    In one study, it was estimated that $75,000 could be saved annually in suction canister purchase, management and disposal costs if a vacuum system were installed.

    Regulatory Information

    Guidelines for disposing of suction canisters are based on New Hampshire’s Hazardous Waste Rules (Env-Wm 100-1100), Solid Waste Rules (Env-Wm 2100-3700), Standards for Pretreatment of Industrial Wastewater (Env-Ws 904), and Rules Governing the Control of Air Pollutants (Env-A 100-3800).

    Part of the above information was taken from the following fact sheet "Suction Canister Reduction," Minnesota Technical Assistance Program, University of Minnesota, May 2003. An original document can be found by visiting http://mntap.umn.edu/health/91-Canister.htm.

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