Waste Reduction Plan

8/3/2019 Waste Reduction Plan

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W r i t i n g a W a s t e R e d u c t i o n P l a n f o r H e a l t h C a r e O r g a n i z a t i o n s

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Writing a Waste Reduction Plan forHealth Care Organizations

Sponsored by:

Tennessee Hospital Association

Tennessee Valley Authority

The University of Tennessee Center for Industrial Services

In cooperation with Tennessee Department of Environment andConservation


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U T C e n t e r f o r I n d u s t r i a l S e r v i c e s

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About This Handbook

This hand book will help your hospital comp ly with the TennesseeHazard ous Waste Reduction Act of 1990, the Resource Conservationand Recovery Act (RCRA), and the Joint Comm ission requ irementfor a man agement p lan to consider hazard ous wastes.

In it, you will find information to help you identify and a ssesspollution p revention/ waste reduction op tions. You will also findanswers to qu estions such as:

How do I iden tify RCRA hazard ous wastes?

What are the rules for hazard ous waste generators?

How do I write a plan to redu ce wastes?

How do I conduct a waste redu ction assessment?

How do I imp lement w aste redu ction practices?

Because ind ividu al hospital circum stances and needs vary w idely,you shou ld mod ify the waste redu ction opportu nities to meet yourown unique requirements.


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ContentsABOUT THIS HANDBOOK....................................................................... 2

WHY DO WE NEED A WRITTEN PLAN? ................................................ 6

FOUR COMMON QUESTIONS................................................................. 8

CHAPTER 1 HAZARDOUS WASTE....................................................... 10

LISTING YOUR HAZARDOUS WASTE.............................................................................................. 12

TABLE 1 WASTE REDUCTION STATUS .......................................................................................... 13

TABLE 2 WASTE VOLUME AND COST TARGETING ..................................................................... 14

TABLE 3 HAZARDOUS WASTE REGULATIONS............................................................................. 15

WRITING A WASTE REDUCTION PLAN........................................................................................... 20

CHAPTER 2 REDUCTION OPPORTUNITIES........................................ 24

PURCHASING...................................................................................................................................... 25

INVENTORY CONTROL ...................................................................................................................... 26

XYLENE ............................................................................................................................................... 27

FORMALDEHYDE ............................................................................................................................... 30

MERCURY ............................................................................................................................................ 32

FLOURESCENT LIGHTS .................................................................................................................... 33

SILVER ................................................................................................................................................. 34

PHARMACY ......................................................................................................................................... 35

TABLE 4 CHARACTERISTIC WASTES............................................................................................. 36

TABLE 5 LISTED WASTES ................................................................................................................ 37

CLEANING CHEMICALS .................................................................................................................... 37

CHAPTER 3 MAINTENANCE WASTES................................................. 38

BATTERIES ......................................................................................................................................... 37

PARTS WASHING ............................................................................................................................... 40

PAINTS................................................................................................................................................. 41

AEROSOLS.......................................................................................................................................... 42

PESTICIDES ........................................................................................................................................ 43

LAUNDRY CHEMICALS ..................................................................................................................... 43

USED OIL ............................................................................................................................................. 44

DRUMS................................................................................................................................................. 46

HAZARDOUS WASTE STORAGE ..................................................................................................... 48


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CHAPTER 4 SAMPLE HOSPITAL PLAN ............................................ 51

WASTE REDUCTION POLICY STATEMENT .................................................................................... 53

SCOPE AND OBJECTIVES ................................................................................................................ 54

WASTE REDUCTION PLAN ADMINISTRATION .............................................................................. 54

BARRIERS TO WASTE REDUCTION ................................................................................................ 56

WASTE REDUCTION OPPORTUNITIES ........................................................................................... 56

CHAPTER 5 HAZARDOUS MATERIALS TRAINING ............................ 58

MSDSs AND WASTE REDUCTION.................................................................................................... 59

CHAPTER 6 SOLID WASTE................................................................... 61

ESTIMATING YOUR CARDBOARD GENERATION.......................................................................... 63

ESTIMATING YOUR PAPER GENERATION ..................................................................................... 65

ESTIMATING YOUR PLASTIC GENERATION .................................................................................. 66

FOOTNOTES........................................................................................... 68

APPENDICES.......................................................................................... 69

A ........................................................................................................................................................... 69

B ........................................................................................................................................................... 70

C ........................................................................................................................................................... 71

D ........................................................................................................................................................... 72

E ............................................................................................................................................................ 73

F ............................................................................................................................................................ 74

G ........................................................................................................................................................... 75

H ........................................................................................................................................................... 76

I ............................................................................................................................................................. 77

J ............................................................................................................................................................ 78

K ........................................................................................................................................................... 79

L ............................................................................................................................................................ 80

M ........................................................................................................................................................... 81

N ........................................................................................................................................................... 82

Solid Waste Markets .......................................................................................................................... 83


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ABOUT THE SPONSORS

Tennessee Hospital Association, established in 1938 as a not-for-

profit mem bership association, serves as an ad vocate for hosp italsand the patients they serve, provides education an d information forits mem bers, and informs the p ublic about h ospitals and health careissues at the state and national levels.

The Tennessee Department of Environment and Conservations

Division of Pollution Prevention and Environmental Aw areness

and Division of Solid Waste Assistance exist to help indu stries andcounties implement volun tary pollution p revention m easures.

Tennessee Valley Authority is a resource developmen t arm of the

federal governm ent committed to environmental leadershipsupporting creative solutions to environmental p roblems. Throughpu blic and private partnerships, TVA promotes sustainableeconomic development by edu cating corporate America on thevalue of waste reduction.

The University of Tennessee Center for Industrial Services isTennessees statewide ind ustrial extension p rogram . CIS providestechnical and management assistance to Tennessee indu stry andhosp itals to help th em p rosper. CIS was created in 1963 by theTennessee General Assembly to render service to the industries in

this state by provid ing information, data, and m aterials relating tothe needs and problems of indu stry.


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Why Do We Need A Written

Plan?

The first answer to th is question is tha t The Joint Commission 1995Accreditation Man ual for Hospitals standard on Man agement ofthe Environment of Care requires that health care organizationshave a documented m anagement plan(s) for the environm ent ofcare that considers... hazard ous materials and wastes.1

Secondly, the H azard ous Waste Reduction Act of 19902 requires aplan to red uce RCRA hazard ous w aste from all large and smallquantity generators in Tennessee. The Act provides for civilpenalties of up to $10,000 per day for failure to file, refusal tocomply, or knowingly giving false information.

In add ition, every time you d ispose of your hazard ous w astes with adisposal comp any, you p repare and sign the EPA-required m anifest.Above you r signature is a certification statement tha t states I [you]certify that you are making your best efforts to reduce hazardous

waste generation. Having this written p lan and making annu alprogress reports documents that certification of having a program -in-place.

Add itional reasons includ e:

A plan may help you lower your waste disposal cost and otherless obvious expenditures. These costs make your operation lessprofitable. The plan m ay also help you justify cap ital expend ituresto upper managemen t for waste reduction investments.

Remember, the true cost of wastes includ e:

Management or oversight costs (administrative recordkeeping costs, regu latory reporting and comp liance cost,environmental training cost, spill and emergency responsecosts, and monitoring costs)

Waste disposal costs (on-site labor, safe and legal storagespace, laboratory analysis costs, value of raw materialslost, and off-site d isposa l cost), and

Potential liability costs (cleanup cost, long-term em ployeehealth care cost, legal fees, and bad pu blic image imp act).


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A plan may help you redu ce your cradle to graveliabilities.

When you r organization generates hazardous w astes, it assumesperp etual liability for any future imp acts those wastes may have onthe environm ent because of storage, treatment, or disposalpractices.

A plan will identify waste redu ction opp ortunities.

The procedure involved in w riting an effective w aste reduction planrequires that you and a team carefully examine all operations andpractice, including procurem ent. Close observation of processes andprocedures by a team of peop le with d ifferent expertise is likely toresult in improvem ents in p rodu ctivity, quality, safety, and wastereduction.

A plan is good for emp loyees.

Redu cing the facility hazard ous w aste generation rate redu cesemp loyee exposure to materials that may harm their health. It alsoinvolves them as stakeholders in the w aste redu ction p rogram.

A plan can be inexpensive and easily imp lemented .

Much of the w aste may be generated u nnecessarily and is easilyeliminated w ith minimal efforts, modest changes in p rocedu res, andwaste aw areness training. These better operating p rocedu res canimprove profitability without significant expenditure.


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Four Commonly Asked

Questions

1. Is our plan a public record and available to anyone who wants

to see it?

No. Your p lan and an nu al upd ates remain on your p remises. Theplan an d up da tes must be available for on-site inspection by theTennessee Department of Environm ent and Conservation (TDEC).You are not requ ired to file them w ith the Solid Waste Control

Board or any other state agency. You report progress to TDEC inyour Annu al Hazard ous Waste Activities Report.

2. Am I required to reduce my hazardous w aste by 25 percent?

No. The 25 percent reduction before Jun e 30, 1995 is a statewideredu ction goal. Individual generators have no limits. How ever,genera tors are expected to set goals that su pp ort Tennessees policythat states, wherever economically and technically feasible, thegeneration of hazardou s waste is to be prevented or redu ced asexped itiously as possible.3

3. Does the Solid Waste Management Act of 1991 require us toreduce solid w aste generated and hauled to the landfill?

No. It does requ ire Solid Waste Planning Regions (counties orgroup s of coun ties) and mu nicipalities to redu ce the amount ofsolid waste land filled an d incinerated by 25 percent beforeDecember 31, 1995. This means that industrial, commercial, andinstitutional generators w ill eventually find d isposal costsincreasing. So, solid waste redu ction w ill make greater economicsense as the years progress. For this reason, you shou ld considerwriting a w aste reduction p lan to include solid w aste reduction.

Many generators of hazardous waste w ill find greater economicbenef its for reducing solid waste than for hazardous waste.


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4. How do w e get started on a w aste reduction plan?

In order to plan w aste redu ction, it is first necessary to identify yourwastes. You m ust at least know wh at your w astes are and howmu ch is generated. To do this you mu st cond uct a waste redu ctionassessment.

Most comp anies that have a p lan believe the team ap proach w ill

include a cause champ ion, or team leader. The cause champ ion willhave ideas, broad-based talents and insights. Other causechampions may include the environmental or safety director for thehospital or a laboratory technician w ho kn ows instrum entation an dmay easily observe wasteful equ ipment performance. Purchasingdep artment p ersonnel and lab managers who oversee test qualitycan help identify wasteful practices and propose corrective action.The assessment team shou ld have mem bers from differentd isciplines such as safety and environmen t, facility maintenan ce,laboratory services, infection control, and h ousekeeping.Independen t consultants from u niversity-based p rograms or p rivate

companies can be of great benefit because they can m ore easilyobserve and objectively question trad itional ways of doing things.

During an assessment, identify, quantify, and profile each wastestream. The profile mu st includ e a description of the operation orprocess that causes generation and factors impacting generation andquantities. Once the wastes are profiled, the opp ortunities for wastereduction are easily identified . Remem ber, every waste stream is awaste reduction opp ortunity.


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Chapter 1 Hazardous Waste

The first responsibility for a hazardous waste generator is to identifyall RCRA hazardous wastes generated . A waste is hazard ous if itappear s on on e of EPAs hazard ous w aste lists or if it exhibits ahazardous characteristic.

EPA has four hazard ous waste lists. These lists are found in 40 CFR261. Any RCRA waste that ap pears on these lists is hazard ous andhas a d esignated waste code. The first list is for nonsp ecific sourcesand is called the F list. An examp le of an F listed m aterial is

spent xylene found in histology laboratories and the sludgegenera ted from d istilling xylene. The waste has an F003 hazard ouswaste code.

The K list is for w astes from specific sources. The lists typicallyinclude w aste water slud ge and probably will not apply to hospitals.

The P and U lists contain chemical prod ucts, off-spec materials,container residu es and spill residues. The P list contains acutelytoxic wastes and if 1kg (2.2 lbs) of a P listed waste is generated ,the facility is a Large Qu antity Generator (LQG). Mercury is atypical U listed w aste.

If a waste exhibits a hazardous characteristic, then it is a hazardouswaste. The four characteristics are:

IGNITABLE (D001) means the w aste has a flash p oint < 140 F. Anexamp le of an ignitable waste is xylene w hich is a D001 and a F003waste. Both nu mbers mu st be used on the hazardous wastemanifest.

CORROSIVE (D002) means the p H < 2.0 or > 12.5. Stron g acids andstrong bases are examples of corrosive hazardous wastes.

REACTIVE (D003) means the w aste is unstable or reacts withwaterunstable ethyl ethers tha t easily form explosive peroxides,for example.

TOXIC (D004-D043) means tha t the w aste exceeds regu latoryconcentrations of toxic chem icals such as lead , chrom ium ormercury. A complete list of toxic wastes are in th e TCLP Techn icalBulletin prod uced by CIS in App end ix A.


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The first step for identifying a hazardous waste is to review the fourlists and d etermine if any of the wastes app ear on them. Next,determine if the wastes exhibit one of the four characteristics. With

most materials it w ill be obvious. Other times, it is not so clear. Itmay be necessary to obtain a laboratory analysis of the waste todetermine if it exhibits one of the four characteristics.

Most Material Safety Data Sheets (MSDSs) will list the characteristicproperties of the material. Just because an MSDS show s that the rawmaterial has a hazard ous waste characteristic (e.g, a flash point< 140 F) does not m ean the w aste from th e process that u ses thatmaterial will exhibit the characteristic. The p rocess may alter thechemical prop erties so tha t the flash point is 140o F or greater.

Also, materials that d o not display the hazard ous characteristic mayproduce a waste that is characteristic. You m ust combine you rknow ledge of the m aterials and the process to determine if thewastes are characteristic or listed.

You can get assistance with identifying hazard ous w astes fromTDEC (615) 532-0780, from disposa l vendors, from the EPASup erfund Hotline (800) 424-9346, and from th e Un iversity ofTennessee Center for Ind ustrial Services (615) 532- 8657.

LIST ALL HAZARDOUS AND NON-HAZARDOUSWASTE STREAMS GENERATED AT YOUR FACILITY.


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1. Xylene

2.

3.

4.

5.

6.

7.

8.

9.

10.

11.

12.

13.

Identify wastes that have been eliminated , reduced, or recycled .Check the action taken an d comment if approp riate. List yourRCRA hazardous wastes first.

HANDS ON TASK


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TABLE 1 Waste Reduction Status Report

Determining w aste volum es and costs may help you prioritize and

target wastes for redu ction and / or recycling. Docum enting yourwaste w ill also help you keep track of where your wastes are going.List your RCRA hazardous w astes fi rst.

HANDS ON TASK


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TABLE 2 Waste Volume and Cost Targeting

HAZARDOUS WASTE REGULATIONS

If your facility generates RCRA hazard ous w astes, you belong inone of three categories based on you r mon thly generation ra te. Thethree categories are in Table 3 below.HANDS ON TASK


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TABLE 3 Hazardous Waste Regulations

CONDITIONALLY EXEMPT SMALL QUANTITYGENERATOR (CESQG) HAZARDOUS WASTE RULESAND REGULATIONS

CESQGs have the least compliance requirements. In add ition to theaccum ulation limits in Table 3, they must also comply w ith numbers1, 5, and 6 of the SQG requ irements.


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SMALL QUANTITY GENERATOR HAZARDOUS WASTERULES AND REGULATIONS

1. The SQG mu st determine the types and am oun ts of hazard ouswaste generated and the w aste code for each waste. Recordsdocumenting the basis of this determination (generatorsknow ledge, laboratory analysis, etc.) must be kept for three years.

2. The SQG mu st have an EPA Identification number.

3. Label each hazard ous w aste container Hazardou s Waste.

If the drum is in the hazardous waste storage area, markthe date accum ulation begins on each container so it isvisible for inspection.

If the d rum is in a satellite accum ulation area, the officialAccumulation Start Date is the date when the dru mbecomes full. When the d rum is fu ll, it mu st be transportedfrom the satellite accum ulation area to the main storagearea within three days.

4. Package, label and mark the w aste accord ing to DOT regulationspr ior to shipp ing. The labeling m ust include the SQGs name,add ress, and man ifest nu mber.

5. Use only EPA p ermitted waste transporters, storage and disposalfacilities to dispose of wastes. They shou ld be bonded, insured,and able to show you permits up on request. If the transporterdoes not have p lacards, the hospital mu st provide the app ropriateplacards before shipp ing w astes.

6. Ship the w astes with a Un iform Hazard ous Waste Manifest andkeep the man ifest for three years. If you have not received asigned copy of the manifest within 45 days of shipment, file anException Report w ith TDEC. The hazard ous w aste man ifest isused to track hazard ous w astes from cradle to grave. It alsocontains information abou t the wastes in case of an em ergency.

7. Subm it by March 1 an Annu al Report on hazard ous w aste activityfor the previous calendar year. Generators with EPA ID nu mbersreceive these Ann ual Repor t from TDEC at the beginning of thecalendar year.

8. Develop a Hazard ous Waste Redu ction Plan and an an nu al PlanUpd ate Report. Keep these reports on-site and have themavailable for inspection by TDEC.


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9. Emergency Coord ination

a. The generator mu st name an emergency coordinator who iseither on p remises or on call.

b. The generator m ust p ost next to a telephon e:

1. The emergency coordinators name and phone number.

2. The location of fire extinguishers, spill control material andfire alarm(s).

3. The fire departm ent p hone nu mber (un less there is a directalarm).

c. Employees must be thoroughly familiar with p roper w aste

handling and emergency procedu res relevant to theirresponsibilities. They m ust know wh en an emergencyrequires third party intervention.

d . If the genera tor has knowledge that a sp ill has reachedsurface water, the generator m ust notify the TennesseeEmergency Managem ent Agency (800) 262-3300 or theNational Response Center (800) 424-8802.

10. Preparedn ess and Prevention

a. Maintain and operate the facilities to minimize the

possibility of fire, explosion or an u np lanned release ofhazardous w aste.

b. All facilities mu st have an intern al comm unications oralarm capable of providing immed iate emergencyinstruction (voice or signal).

c. A device (e.g., teleph one) to su mm on police, firedep artment or emergency response teams mu st bemaintained.

d . Maintain portable fire extinguishers, fire controlequipm ent, spill control equipment and decontaminationequipment.

e. Provide emp loyees with immed iate access to an internalalarm or em ergency commun ication (visual or voicecontact) wh enever hazard ous waste is being p oured ,mixed, spread , or otherwise hand led.

f. Be sure tha t aisle space perm its the movem ent of personn el,


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fire, and spill containment equ ipment around storedhazardous w aste.

g. Make arrangemen ts to familiarize police, fire depar tmen ts,hospitals and emergency response teams to potentialemergen cy situa tions that w ill require their services.

h. Periodically test and m aintain communication systems andcontrol equipm ent.

11. Storage

Keep containers in good cond ition an d keep them closed exceptwh en ad ding waste. Inspect storage areas for leaks anddeterioration every week. A sample container inspection log is in

App end ix B.

LARGE QUANTITY GENERATOR (LQG) HAZARDOUSWASTE RULES AND REGULATIONS

Large Quantity Genera tors (LQGs)must meet the sp ecificrequ irements in Table 3 and nu mbers 1-11 listed in Small QuantityGenerator H azard ous Waste Rules and Regulations section. Inadd ition to those requirements, the LQG mu st also comp ly with thefollowing:

12. Prepare a Hazard ous Waste Emergency Contingen cy Plan.The Emergency Coordinator has ad ditional du ties du ring andafter an emergency event. You can find those duties in theHazardous Waste Contingency Planning technical bulletinprod uced by CIS is in App end ix C.

13. Train personnel on han dling haza rdou s wastes in emergencies,emergency waste management, and implementing the hosp italshazard ous w aste contingency plan. The training mu st includ enu mbers 9 and 10 for SQGs and :

a. Response to ground water contamination

b. Shu tdow n of operations

14. Maintain documentation demonstrating employee class-room oron-the-job training. Keep training records of former emp loyeesfor three years beyond the last date of emp loyment. Keep recordsof cur rent em ployees until the facility closes. Those d ocumentsmu st show:


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a. Title and name of each employee with a hazardous w asteposition, a written job d escription giving requisitequalifications and assigned duties.

b. Records that document training of emp loyees.

15. SQGs and LQGs must also file a report and pay remedial actionfees to TDECs Sup erfund by October 15 of each year.

You have just been familiarized w ith some very important generatorru les. There will be additional regu lations for disposal of ind ividualwastes in you r facility. Now, lets wr ite a plan to red uce wastes.

WRITING A WASTE REDUCTION PLAN

STEP 1

The first step in writing a p lan is drafting a p reface. The p reface isnot a m and atory requ irement. A preface will list the successes andaccomp lishments in waste reduction p rior to writing the plan and /or the imp ediments to hazardou s waste redu ction specific to thefacility. Remem ber, this p lan is for RCRA hazardous w astereduction. Ideally, you w ill wan t to have a separate p lan for solid


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and regulated med ical wastes.

STEP 2The second step is drafting a policy statement. The policy statemen tis a formal statement that best conveys w aste reduction programobjectives to employees. In th e policy statement for your hosp ital,you may wan t to list motivations for waste redu ction planning. Asample plan is in Chapter 4.

STEP 3

The third step is developm ent of the scope, objectives, and w asteredu ction p lan ad ministration. The checklist helps you with thecontents of this section of the p lan. [Information on the final step,Step 4, begins on page 23]

I. The SCOPE identifies what and wh om the plan involves, andwhy.

II. The OBJECTIVES describe what the p lan is expected toaccomp lish, and w hen.

III. The MEANS identifies wh at and wh o w ill be used to accomp lishthe plan.

From the items below, check what you want to includein your statement.

I. Scope

A. Why wil l the hospital develop a plan?

1. To comp ly with the Tennessee Hazard ous WasteRedu ction Act of 1990


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2. To comply w ith Joint Comm ission stand ard thatrequires this organization to h ave a d ocumentedman agement p lan(s) for The Environment of Care that

considers hazardou s materials and hazard ous wastes

3. To reduce the hosp itals imp act on the environm ent:

4. To improve hospitals corporate image.

5. To protect the safety and health of emp loyees.

6. Other(s)___________________________

B. Who is involved?

1. Corporate-management

2. Hospital adm inistrators

2. All employees

3. Other(s)______________________

C. What wastes will the plan reduce?

1. RCRA hazardous wastes

(e.g., xylene, mercury, formaldehyde, silver, pharmaceutical,etc.)

2. Wastewater

3. Other(s) ______________________

4. Solid Wastes (e.g., cardboard , plastics, packaging wastes,etc.)Note: Include solid wastes in another plan because they arenot hazardous.

II. Objectives

A. What is our final goal?

1. To redu ce all waste streams (as defined in the p lans scope)to the technically feasible and economically p racticableminimum.

2. To reduce RCRA haza rdous wastes by ____ percent.


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Note: Each hazard ous waste stream mu st have its ownspecific goal per p rodu ction un it to comp ly with the law.

3. Other

B. By w hat dates?

1. By June 30, 1995 Note: This date is TDECs deadline for a 25percent reduction statewide.

2. In calend ar year 1995.

3. Each year until eliminated .

4. Accord ing to other timetable(s) established by team .

5. Other______________________________

III. Means

A. What will w e use to accomplish our objectives?

1. Waste Reduction Team Assessmen ts (every 6 mon ths orann ually;). See page 9 for who to includ e in your team .

2. Annu al progress report requ ired by law.

3. New p rocesses, equipment or process changes.

4. Employee training.

5. Raw m aterial substitution.

6. Waste tracking system.

7. Charging w aste managem ent cost to generatingdepartment.

8. Improved maintenance and preventive maintenanceprograms.

9. Improved scheduling and inventory controls.

10. On-site recycling .

11. Off-site recycling.

12. Waste stream separa tion.


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13. Employee incentives.

14. Other____________________________

B. Who is responsible?

1. An ind ividu al(Name)_________________________________________

2. A position (Job Title)_________________________

3. A team composed of: (names an d job titles)

____________________________________________

____________________________________________

4. Individuals or positions, depend ing on area ofresponsibility

Now, take your choices and put them together into a one-page or

shorter statement similar to the sample plan in Chapter 4. You

have just initiated the first steps toward completing your plan.

STEP 4

The fourth step in comp leting you r hazard ous w aste redu ction p lanwill requ ire you to develop qu antitative goals in numer ic terms. Thepreferred un it of measurem ent is grams or pounds of wastegenerated per unit of production. You may define you r unit ofproduction. If nu meric goals are not practical, the p lan mu st includ ea clearly stated list of actions leading to the establishment ofnu meric goals as soon as practicable.

Chapter 2 OPPORTUNITIES

THE WASTE REDUCTION ASSESSMENT

In order to assess your facility for waste reduction opportunities,you m ust know some definitions and be able to identify wastefulprocesses and p rocedu res.

HANDS ON TASK


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Waste Reduction Hierarchy

Your waste reduction p lan requires that you identify source

reduction opp ortunities. Source reduction refers to any p racticewh ich red uces the amount of any hazard ous substance, pollutant, orcontaminant entering any waste stream or released into theenvironment pr ior to recycling, treatmen t, or disposal.

Source reduction opportunities includes identifying wastefulpurchasing patterns, raw material substitution, process orprocedure modifications, improvements in inventory control,

training, maintenance, and housekeeping. Periodically assess theseareas to redu ce unnecessary w aste generation.

If you cannot eliminate the generation of waste, then evalua terecovery, reclamation, reuse, and recycling of wastes. Successes inrecycling are documented in non-hazard ous, solid w aste streamslike cardboard and pap er. However, d istillation un its cansuccessfully recycle xylene in histology laboratories for reuse.

If source red uction an d recycling are not feasible or possible, thenconsider treatment. Neutralizing acids and bases and d ilutingalcohols for POTW disposal are examp les of waste treatmen t.

As a final option, consider disposal through permitted transportersand waste m anagement compan ies. Municipal landfills w ill notaccept haza rdou s wastes.

OPPORTUNITIES

On the following p ages you w ill read abou t opp ortunities to reducewaste in your facility. When ap propriate, you will also findregu latory requirements for the waste streams listed .

Check off with an ink pen the oppor tun ities that will definitely helpyour facility red uce w aste. Then, with a pen cil (or d ifferent coloredpen) check off the w aste reduction op portunities that wou ld helpyou but are more d ifficult to implement because of barriers. You canuse this information to complete your w aste reduction p lan anddevelop your implementation schedule.


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PURCHASING

Look at your hospitals purchasing program. Purchasing practices

may contribute significantly to waste generation. Chemicals canbecome obsolete du e to expired shelf-life. Misman aged sup plies canbecome w aste. Eliminate, redu ce, or recycle packaging materialswhere possible. Inventory controls and practices can help to redu cewastes. While pu rchasing program s will vary, they shou ld:

1. Monitor requ ests for chemicals and implement p olicies to redu ceover-pu rchasing that resu lts in waste generation. Those polices caninclude:

Procure chemicals through a central departm ent or person.

Minimize of on-hand inventory.

Determining wh ere Just-In-Time inventory can beimplemented in the hospital.

Stagger deliveries.

Accomm odate partial pu rchasing of orders fromdepartmental managers if quantities seem excessive.

Arrange for partial shipment of supplies with the

remainder shipp ed on as-needed basis.

Negotiation w ith p urchasing alliance to exclude certainitems in patient care kits that are repeatedly not used inpatient procedu res and become unu sed waste.

Negotiating the return of un used reagent chemicals orobsolete raw m aterials and their container s to the sup plieror manu facturer.

Purchase smaller quantities of chemicals and supplies not

frequen tly used.

Purchase chemicals in totes or in recyclable containers.

Control acquisition and use of reagents that have limitedshelf-life. These supp lies should be ordered in smallestpractical container (e.g. ethyl ether and its formation ofexplosive peroxides).

Purchase of large quantities of chemicals and suppliesfrequen tly used.

HANDS ON TASK


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Avoid over-pu rchase of supplies. Order reagents andchemicals in exact amounts to be u sed. Be carefu l whenordering extra quantities to take advantage of unit cost

savings. You can lose the net savings for unu sed chem icals.

2. Encouraging su pp liers to become responsible partners byproviding quick delivery of small orders, accept retu rn of unop enedstock, and accept sealed bottles of stable chemicals that may beresold.

3. Requiring an on-going relationship involving w aste redu ctionwith suppliers and pu rchasing alliance representatives.

INVENTORY CONTROLManaging the inventory p rovides the next best opportu nity toredu ce hazardous waste generation. A good inventory controlprogram will attempt to:

Adopt first-in, first-out order.

Ensure distribution throughou t the facility through oneperson.

Redu ce chemical use where possible.

Promote sharing of chemicals between common users.

- Develop and implement a program involving the reuse ofunwan ted, but u sable chemicals. A comp uterized, runn inginventory of un used reagent chem icals for re-use in otherdep artments is helpful.

Track waste generation:

- Develop data (chemical inventor ies) by user.

- Identify high volume users and generators.

- Locate where caches of un used reagents are and w hy theyaccumulate.

- Monitor reagent chem icals half-life and expiration dates.

Include every d epartment that contains inventoried chemicals.

Develop management p lans for leftover chemicals with d isposalas a last resort. Reduce high volume chemical inven tories to an


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ideal (four weeks or less) sup ply level.

Ensure that the iden tity of all chemicals is clearly marked on all

containers. It is illegal to ship unu sed reagent chemicals,containers, and solution m ixtures and un identified wastes fordisposal w ithou t an alysis.

XYLENE

Source Reduction Opportunities

MATERIAL SUBSTITUTION

Xylene is used in processors and stainers. Xylene is typically used asa clearing agent that removes paraffin from the tissue. There arealternative chemicals that have been u sed to rep lace xylene in thestainers.

Carefully evaluate citrus-based substitutes. Citrus-based alterna tivesmay redu ce worker exposure but may p roduce a hazardous w astebecause these p rodu cts may have a flashpoint less than 140oF. Thesecitrus-based solvents may process samp les slower than xylene andwill require temperatu re and time mod ifications. Generally, theseproducts are effective on samp les in the micrometer range.

However, thicker samples may be d ifficult or impossible to process.Evaluate h azardous w aste and quality issues before using xylenealternatives.

PROCEDUREMODIFICATION

Do not m ix wastes unnecessarily. Sometimes wastes are m ixedwithout resp ect to characteristic and compatibility at the point ofgenera tion. In one hospital, five 16-gallon drums of formalin(fixation), alcohols (dehydrators), xylene(processors), chromic acid(glass cleaners), paraffin w ax , and wa ter were mixed. In th is case,

the hosp ital reduced 75 percent of its RCRA hazardous w aste by notmixing formalin waste with alcohol waste. The hospital diluted ortreated formalin an d alcohol and discharged it to the sewer system.

INVENTORYCONTROL

Mounting chemicals are used to stabilize the sample on the slide.These mou nting chemicals contain polymers and solvents such astoluene and xylene. Control the inventories of these chemicalsbecause they have limited shelf lives.


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Evaluate rou tine laboratory p rocesses or tests such a s fixation andextraction to d etermine if quan tities of reagents are reducible. The

evaluation can includ e:

- using calibrated solvent dispensers.

- using un itized test kits.

- reducing volum es of reagents.

- increasing the use of instrum entation in tests andexperiments.

Recycling4

There is significant op portu nity to redu ce hazardou s wastegenera tion in hospital histology laboratories by d istilling xylene.You can eliminate hazardous w aste that mu st be man ifested exceptfor an extremely small quantity of sludge (still bottoms) fromdistillation, which is an F003 haza rdous w aste. Other solvent w astesmay not have sufficient generation rates to use distillation.Distillation of xylene w ill redu ce xylene raw material costs. At aminimum:

Evaluate the quality of d istilled xylene. Laboratory

personnel and/ or chemical review board m embers shou ldagree on recycled xylene quality. Distilled xylene oftenexceeds v irgin xylene quality.

Do not mix waste streams because this practice maycomplicate or negate d istillation opp ortunities.

Stand ardize solvent u sage if possible.

Check w ith you r local fire marshall and OSHA field office todetermine if there are location and safety issues tha t mu st be

addressed. Fire-rated d oors and w alls, impermeable floors,designated ventilation, and locations aw ay from patient care areasare some issues that mu st be add ressed. App end ix N contains acomplete checklist for evaluating the pu rchase of a distillation un it.

Treatment

Waste xylene that results from the tissue-prep aration procedu re isoften contaminated with an ethanol and water solution. Xylene is


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immiscible with w ater. Any w ater-miscible solute (e.g., ethan ol andformalin) is read ily extracted by m ultiple washes with w ater.Decanting by gravity separation m ay make the wash water suitable

for disposal to the sewer. Addition of a desiccant salt would removepractically all remaining w ater. Consult your POTW and / or seweruse p ermits to ensure that d ischarge of small amounts of ethanoland formalin will not result in a v iolation or fines.

Disposal

If d istillation of xylene is not feasible, and off-site waste d isposa l ischosen, wastes should be separated from other w astes. The fuelvalue decreases wh en water and oxygenated organic compound s(alcohols) are p resent. Fuel blend ers charge less to dispose of wasteswith h igh heating values.

CHROMICACID

Chrom ic acid is typically used as a glass cleaner. Some POTWsallow disposal of chromic acid solutions p rovided the p H isadjusted to six and the chromium is redu ced. The pH is ad justed byslowly ad ding NaOH . After this neu tralization step is complete,redu ce the hexavalent chromium to trivalent chromium by addingsaturated sod ium bisulfite solution. However, contact your POTWto determine if this neutralization/ reduction practice is acceptable

to the w astewater treatment p rocess.

ALCOHOL

Methyl, ethyl, and propyl alcohols are sometimes eligible for sewerdisposal if quantities are small (less than 100g) and d ilu ted (20 to 50fold). The alcohols eligible for d isposal are generally w ater soluble,present low toxicity haza rd , contain few carbons and acceptable tothe local POTW.

FORMALDEHYDE



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Formalin (formaldehyd e and water) is used to d isinfect d ialysismachines and d ialyzers. Some d ialysis machines are designed to usealternative disinfectants. Check with your machine vend ors todetermine if bleach, peracetic acid , or other d isinfectants can be usedinstead of formalin. Carefu lly evaluate a ll substitutes for cleaningeffectiveness and comply with all machine manufacturerrequirements.

PROCEDUREMODIFICATIONS

Determine the effective cleaning formalin concentrations. Effectiveformalin concentration for d isinfecting and cleaning machines anddisinfecting d ialyzers are in the Cen ters for Disease ControlGuid elines. Great potential exists for minimizing formalin waste byoptimizing formalin concentration.

MACHINES

Formalin concentrations used to d isinfect d ialysis machinesvaries among machines and hosp itals. Formalin is typicallypu rchased in concentrations that ran ge from 10 to 37 percent.Many machines will dilute the 37 percent formalin to a 10:1ratio to achieve a 4 percent disinfecting concentration.Formalin concentrations of 2 percent are not recognized as

effective disinfectan ts.

However, some machines will requ ire mixing offormaldehyd e and w ater to prod uce formalin that is pouredinto machines. These machines don t internally diluteformalin. Therefore, the effective formalin concentration (4percent) should be m easured accurately and maintainedconsistently. Using formalin concentra tions greater than 4percent for disinfecting machines may generate unnecessarywastes.

DIALYZERS

Formalin usage may be reduced in dialyzers. The use of specialincubators to heat dialyzers in 1.0 percent formalin solution at 400 Cfor 24 hours may be an effective alternative to using 4 percentformalin at room temperature for 24 hours.5

Recycling (Reuse)


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In autop sy and pathology laboratories, it may be possible to reuseformaldehyd e. These solutions retain their desired p roperties forperiod s far longer than the usual hold ing times for specimens. In

addition, the desired p reservative prop erties may be effective atconcentrations less than the stand ard 10 percent.

Treatment

Supp liers may offer chemicals that neutralize formalin. Theneutralizers polymerize the aldehyd e group s into carbon d ioxideand amm onium. The neutralized formalin may be eligible forPOTW disposal. Check with your POTW to determ ine if thispractice is acceptable before pu rchasing these chemicals.

Disposal

Formaldehyde is a listed w aste if its shelf-life has expired . It is notconsidered a RCRA hazard ous w aste when generated fromstand ard tissue p rocessing in histology laboratories. Disposing offormalin in the POTW followed by copious amou nts of water maybe an acceptable disposal practice. However, consu lt with localPOTWs to determine if d ischarg ing formalin wastew ater isacceptable.

MERCURY

Mercury is a U listed, RCRA hazard ous w aste. It is also acharacteristic hazard ous w aste when its concentration is above 0.2pp m. Mercury is present in significant, but red ucible quantities inhealth care organizations. Significant op por tun ities exist to redu ceits usage.




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Replace mercury-formalin tissue fixatives with zinc-formalinfixatives.

Mercury B-3 and B-5 fixatives are typ ically used as tissue fixatives.Zinc fixatives are substitutes and can redu ce or eliminate mercurychloride precipitates that require costly hazardous waste disposal.The pH in zinc-formalin mixtures has to be carefully controlled.Zinc fixatives provide good nu cear detail but not as good asmercury fixatives. Surgical specimen, biopsies, and skin lesionsgenera lly work will with zinc. Bone marrow and cytologyspecimens m ay requ ire the use of mercury.

TECHNOLOGYMODIFICATIONS

Replace mercury thermom eters and sphygm omanometers withelectronic, solid state devices.

The high er initial cost of these devices are typ ically justifiedbecause costly spills, clean-up s and hazard s from glassbreakage are eliminated.

Evaluate the continued use of Cantor Tubes.

Mercury-containing Cantor tubes contain significant am ountsof mercury that mu st be managed p roperly.

RECYCLING

Provide mercury spill kits. Mercury recyclers may p rovide airtight,steel container s that th e facility can use for collecting and shipp ingwaste mercury withou t add itional packaging.

FLUORESCENT LIGHTS

Many fluorescent lights are hazardous u nd er the ToxicCharacteristic Leaching Procedu re (TCLP) testing protocol and arehazard ous w astes. The m ercury that is released to the environmentdep ends on how the spent lamp is hand led d uring d isposal. Inorder for Tennessee to exempt these lights from the hazardou swaste d etermination requ irements, an exemp tion will require afederal written policy and ad option by states. Fluorescent lightrecyclers are in Ap pen dix E. For the latest development in federalregu lations on fluorescent lamp disposal call:


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Toxic Substan ce Con trol Hotline (202) 554-1404

Resources Conservation and Recovery H otline (800) 424-9346

US EPA (202) 775-6650.


To redu ce the mercury waste that is generated wh en lights aredisposed, consider:

Using T8 lamp s instead of T-12 lamps.

Using timed lights or lights w ith occupancy switches

instead of manual switches.

Implementing the Green Lights Program.

Green Lights Program

The U. S. EPA Office of Air an d Radiation op erates the FederalGreen Lights Program. If you are u sing fluorescent lights, thisprogram can help you. Many h ealth care organizations havereduced costs significantly by u sing a combination of T-8 lamp swith electronic ballasts, compact fluorescent and other p roven

lighting technologies.

The internal rate of return for hospitals from lighting upgrad es canbe as much as 50 percent and savings of up to $100,000 are typ icalfor a 400,000 s.f. hosp ital. For the latest inform ation on th e GreenLights Program an d a list of participa ting health care organizations,contact the Green Lights General Hotline at (202) 775-6650 or GreenLights Technical Hotline at (202) 862-1145.

RECYCLING

Instead of disposing fluorescent lights as hazard ous wastes,consider recycling them . App end ix E contains a list of light recyclersthat m ay service your area. If you choose a recycler, documentwh ere and how your lights are disposed. App end ix F contains a listof mercury r ecyclers.

SILVER


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Many chemicals are sensitive to temp eratu re and light. Designph otosensitive film and paper storage areas for economical andefficient use. Chemical containers list the recomm end ed storage

conditions. Meeting the recommen ded cond itions will increase theirshelf life. Store materials properly.

Test materials having expired shelf-life for effectiveness. Thematerials may be usable, rather than becoming a w aste. A recyclingoutlet shou ld be found for raw m aterials that are no longer wanted .

PROCESSMODIFICATION

Silver can be recovered from fixing baths to p ermit bathregeneration. In ad dition:

Add amm onium thiosulfate, wh ich increases the allowableconcentration of silver bu ildup in the bath .

Use an acid stop bath prior to the fixing bath.

Add acetic acid to the fixing bath as needed to keep the pHlow.

Use coun ter-current washing to reduce waste watergeneration from p arallel tank systems. In coun ter-cur rentrinsing, water from p revious rinsings is used in the initialfilm washing stage. Fresh w ater enters the p rocess only atthe final stage, at wh ich point mu ch of the contaminationhas already been rinsed off the film.

Accurately add ing and monitoring chemical replenishm entof process baths will cu t down chemical waste. Protectstored p rocess bath chem icals from oxidation by reducingexposure to air. Store chem icals in p lastic containers.

Determine if off-spec chemicals can be retu rned to thesupplier.

Recycling

The two most common methods of recovering silver are metallicreplacemen t and electrolytic replacemen t. Metallic replacementinvolves ion exchange betw een silver and an other m etal. The othermeta l is usually iron (mesh) or steel wool. Electrolytic replacementinvolves the accumulation of silver on a negative cathod e. The silveris reclaimed from a 5-10 percent fixer solution.


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There are four m ajor w aste streams associated with electrolyticimage processing at hospital radiology departm ents that mu st beman aged p roperly. They are:

Silver that is recovered from recycling u nits. This silverwaste is not a hazard ous waste.

Discharged waste water. The waste water may containsilver. The waste w ater is hazard ous if its concentra tion isgreater than 5ppm .

Spen t fixer is haza rdous if its silver concentration is greaterthan 5ppm .

Discarded X-ray film has recoverable amoun ts of silver thatis typically removed by a recycler for processing. Thereclaimed silver can be used in other industrial orcommercial applications. If the silver is removed , theremaining X-ray film is a recyclable polyester.

PHARMACY

The US EPA says that p harm aceutical prod ucts do not becomewaste until the d ecision has been m ade to d iscard them. If the

dam aged or outd ated prod ucts are returned to the manu facturer,d istributor, or third party processors with an inten t to receive credit,and if the p harm acy has n o role in the d ecision to recycle, reclaim,or destroy the p rodu cts, they are regarded as prod ucts (not w astes)at the time they are shipped .6,7 The only requirement for shippingwill be prop er DOT labeling.


Consider closed formu laries.

In add ition to making mon itoring patient drug u se moredifficult, open formularies may significantly contribu te to thevolume of dru gs that must be disposed. Open formu lariesallow prov iders to dispense samp les to patients. Thisdispensing p ractice encourages the d evelopm ent ofsecond ary storage areas. Once established , secondary storageareas and their environments cannot be controlled. Whendru gs are improperly stored (e.g. imp roper cooling


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requirements) they m ay become obsolete and requiredisposal wh ich w ill increase d isposal costs.

Monitor outside dru g sources.

Medical providers (who may have off-site offices) withhosp ital pr ivileges accumulate samp les that may become adisposal problem for pharmacies. Typically, ph armaciesdispose of these dru gs gratuitously for the p rovider.

Track and redu ce the distribution of dru g samples.

Some examples of preparations and chemicals that are likely to becharacteristic wastes are found in the table below.

TABLE 4 CHARACTERISTIC WASTES

If the sole active ingred ient in the waste is named on the P or Ulist, it is hazard ous. Below are examp les of listed wastes found in

pharmacies.


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TABLE 5 LISTED WASTES

CLEANING CHEMICALS


Redu cing w aste at its source may ensure that no hazard ous wasteneed d isposal. Many cleaning chemicals are flammable and containchlorinated solvents. Thus, cleaning processes may provide anopp ortunity for reducing and eliminate hazard ous wastes.


Evaluate the use of less hazard ous materials and cleaning agents innon-critical areas

Evaluate p hysical cleaning m ethods that may replace and redu cechemical cleaning requirements

Evaluate the u se of sonic or steam cleaning instead of chemicalsterilization.

Evaluate specialty detergents, potassium hydroxide, or sonic bathsto replace chromic and sulfuric acid for cleaning glassware. Sodiumor potassium dichrom ate dissolved in su lfuric acid an d chrom ic acidcleaning solutions are common meth ods of cleaning glassware.How ever there are alternative cleaning agen ts that have p roveneffective and less hazardous. They are found in App end ix G.


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Chapter 3 Maintenance Wastes

BATTERIES

Recycling

If batteries are sent back to the manu facturer for recycling, thebatteries are not a hazardous w aste. A tolling agreement w ith thefacility and the recycler docum enting this arrangem ent shou ld be inplace. A manifest for the batteries is un necessary provided eight

requirements are m et. They are:

A written contract to collect, reclaim an d retu rn at aspecified frequency.

Transport vehicle own ed by reclaimer.

Generator or reclaimer maintains title to material at alltimes.

Comply with record keeping requirements.

Comply with DOT shipp ing pap er requirements.

A copy of contract filed w ith both generator and reclaimer.

Reclaimer/ Transporter records on shipping document orlog (This information must accompany waste.):

a. EPA ID #

b. Quantity of waste

c. DOT shipp ing information

d. Date

Disposal

Accord ing to TDEC, if lead acid batteries are not cracked and thecontents are wh olly contained w ithin, a broker or recycler mayreceive the batteries. If these two cond itions are met, lead acidbatteries are non-hazard ous.


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How ever, the following batteries are hazard ous

Nickel-cadmium batteries are hazardou s because of the

cadmium present. Nickel-cadmium batteries are found inalarm systems, pagers, backup pow er sources in m edicalmonitors and equ ipment. These batteries are oftenrechargeable but need eventual d isposal.

Mercuric oxide batteries are hazard ous because of themercury p resent. These batteries are typically used inhearing aids, smoke detectors, oxygen m onitors, fetalmonitors, and portable EKG mon itors. They mu st bedisposed of as a hazardou s waste.

Lithium batteries are hazard ous and mu st be disposed ofas a hazard ous waste.

Silver cadm ium batteries are in med ical electronics. Thesebatteries contain silver and cadm ium an d m ust bedisposed of as a hazardou s waste.

Zinc-air batteries may be used to replace mercuric oxidebatteries. These batteries are typ ically foun d in hearingaids and electronic pagers. They contain zinc and m ercuryand are a hazard ous waste. A list of battery recyclers is in

Append ix H.

In Tennessee, these hazardous waste batteries are exempted fromreporting requ irements if the facility generates less than 100 kg ofhazard ous w aste (including the batteries) in any calendar m onthand those batteries are hand led prop erly. You do not have to notifyTDEC on the waste battery generation but you must manage and

dispose of them as a hazardous waste. If the facility generates m orethan 100kg of hazard ous wastes (includ ing the batteries) in anycalendar m onth, the total generation m ust be reported to TDEC onthe Annu al Hazardou s Waste Report.


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PARTS WASHING



When you eva luate for alternative cleaning m ethod s, look for non-hazard ous substitutes. There are petroleum d istillates available thatare non-hazardous (non-ignitable) because the prod uct has beenformulated so that the flash point is 1400 F or greater.

Consider, aqueou s-based cleaning technologies. Hot soap cleanersare very effective for parts wash ing. They m ay replace parts washers

and eliminate all hazard ous w astes associated with p arts cleaning.Oil skimm ers can recover oil before water is discharged to thePOTW. Mix the skimm ed oil with other used oils for recycling.How ever, consult w ith wastewater au thorities to determine if anylocal limits restrict hot soap w astewater d ischarges.

Evaluate wh ether all ma intenance functions that require cleaningare compatible with keton e, ester, or aqueous-based cleaningtechnologies.


Do not locate solvent p arts washer stations near exhaust fans anddoor d rafts. Pum ps that are continuously running volatilizeprod uct into the air. Make sure p arts washers are off wh en not inuse. If the parts washers have lids, keep the lids closed wh en thewasher is not in use.

MAINTENANCEIMPROVEMENTS

Efficient operating procedures for parts washing in maintenanceareas can help eliminate some solvent w astes. For example, do nothave m ore parts w asher stations than necessary nor allow

un necessary pick u ps. Neglecting these two strategies couldunnecessarily change your status from small quantity generator to

large quantity generator.


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PAINTS



Replace oil-based pa ints with wa ter-based paints in facilitymaintenance operations to eliminate the use of solvents and thinnersas cleaners. Using paints without m etal pigments or p aints withhigh solid, low volatile organic compoun d w ill also help reducehazardous waste.

INVENTORYCONTROL

Controlling inventory is imp ortant w hen trying to redu ce waste. Ithelps to eliminate excess supplies that are p otential wastes. Threepractices that can help control inventory are:

Adopt first-in, first-out inventory practices for pa ints toreduce waste associated w ith expired shelf life.

Purchase paints only in needed qu antities.

Do not mix more paint than is needed for a painting job.

Standard ize paint colors used in the facility.

TRAINING

Over-spray is the paint that does not reach the part. Over-spraycreates waste and increases raw materials cost. To reduce overspray:

Use spray system equipm ent with high transfer efficiency.High volum e, low p ressure (HVLP) guns provide thehighest transfer efficiency. Electrostatic spry guns also

improve transfer efficiency.

Maintain prop er pressure as iden tified in the operatorsmanu al for specific gun systems. Higher pressu rescontribute to overspray.

Clean spray gun n ozzles.

Replace dam aged nozzles.


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Keep spray gun perp endicular to the surface.

Maintain a fifty percent overlap of spray pattern.

Maintain gu n d istance of six to eight inches fromworkpiece.

Trigger gun at the beginning and end of each stroke.

Use heaters to redu ce paint viscosity instead of add ingthinners.

RECYCLING

If pa int gun s are cleaned w ith solvents, consider investing in a guncleaner system that r ecirculates the solvent. Gun cleaners can saveyou as mu ch as 30 percent on d isposal and raw material costs.

AEROSOLS

Aerosols are present in th e facility maintenance areas in hea lth careorgan izations. Aerosols includ e adhesive cleaners, non-flamm ableglues, cutting oils, stainless steel cleaners, electron ic solventcleaners, touch-up pa ints, and ceiling tile renew ers. These aerosols

represent a very small portion of the total aerosol inven tory.

Implement or imp rove procedu res for inventory controls to ensurethe review an d use of all aerosols in the facility.



To increase the shelf-life of aerosol cans, keep th em away frommoisture, sun light, and extreme heat and cold. It is also imp ortant to

keep p rotective caps on the containers when not in use. This helpprevent contamination, rusting of the container top , and nozzledamage.

INVENTORYCONTROL

An inven tory control system can assist in redu cing w aste. Ord erprod ucts according to d emand because expired shelf-life mayrequ ire excess inventories to be disposed. Dispense aerosol canswh en an emp ty can is return ed. This process should be controlledthrough one person in one location to prevent u nnecessary usage.


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Disposal

Contact you r local land fill author ities to d etermine if notification is

requ ired before you d ispose of your aerosol cans.

Contact TDEC to determine if you need a special waste ap provalapp lication and if you mu st pay fees. You mu st have ap proval fromyour local land fill and state regulatory agency for disposal.

PESTICIDES


Redu ce generation of pesticide waste generated by ground smaintenan ce activities by:

Reducing p esticide inventor ies toward a goal of just-in-time

Reducing pesticide, herbicide and fertilizer ap plication

Preparing and using only the required quan tities

Using non-chemical pest control methods

Using d ry pesticides that are spread on the groun d an d w atered intothe ground . Using th is method m ay eliminate the need for pesticidespraying containers and the resulting contaminated waste wa terfrom clean u p operations.

Using contract services for insect control, rodent control, and lawnmaintenance. Waste is managed by the contractor and doesntimpact the hospitals generation rates.

LAUNDRY CHEMICALS


Laundry chemicals are often supp lied in 5 gallon containers.Consider receiving chem icals in totes. See Dru ms for a descriptionof totes and its app lications.

TRAININGANDTECHNOLOGYMODIFICATION

Poor hand ling of laund ry chemicals can lead to accidental spills,un deruse, or overuse of chemicals. Und eruse of laundry chemicals


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results in poorly cleaned articles that mu st cleaned again. Theoveru se of laundry chemicals un necessarily increases the volum e ofchemicals and increases raw material costs.

Optimizing the u se of laun dry chemicals and minimizing accidentalspills is achieved th rough worker training, prepackaged laund rychemicals, or the u se of an au tomated laund ry chemical feed system.While laund ries might incur initial capital costs to install anautom ated system, the savings from optimal chemical usage andreduction in labor costs may h ave long- term benefits.

USED OIL

Used oil is exemp t from most federal regu lations in ord er toencourage recycling and energy recovery. If used oil is not recycled ,it must be d isposed as a h azardous w aste. Used oil that is burnedfor energy recovery is exemp ted from EPA hazard ous w asteregulations u nless it has been contaminated w ith another listedhazard ous waste (e.g. chlorinated solvents). If the generatorprovides u sed oil directly to an end -user, the generator mu stregister with EPA as a Used Oil Fuel Marketer. There are th reeoptions to man age waste oil properly:

Burn the used oil on-site in a u sed oil space heater.

Provide used oil to an end -user d irectly.

Work with a marketer who m ay provide the oil to end-users. If amarketer transports you r used oil to a cement kiln, asphalt plant,or industrial boiler and that u sed oil is processed to createenergy, recycling requirem ents have been satisfied.

Recycling

The generator is required to u se a transporter w ith an EPA

identification nu mber wh en shipp ing used oil off-site. Generatorsshould know that the used oil hau ler has made approp riatenotifications and know that the used oil is stored, recycled, andmanaged proper ly. A checklist for selecting a tran sporter is inAppen dix I. A list of used oil han dlers is found in Appen dix J.

Except as prov ided in paragraph s (a) through (c) of this section,generators must ensure that their used oil is transported on ly bytransporters wh o have obtained EPA identification numbers.


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(a) Self-transporta tion of small amounts to approvedcollection centers is acceptable. Generator s may transport,without an EPA identification num ber, used oil that is

genera ted at the genera tors site to a used oil collectioncenter provided that:

1. The generator transports the u sed oil in a vehicle owned bythe generator or owned by an employee of the generator;

2. The generator transp orts no more than 55 gallons of usedoil at any time; and ,

3. The generator transports the used oil to a used o ilcollection center that is registered , licensed, p ermitted , or

recognized by a state/ county/ mu nicipal government toman age used oil.

(b) Self-transpor tation of small amou nts to aggregation p ointsown ed by the generator is acceptable. Generators maytransport, without an EPA identification nu mber, used oilthat is generated at the generators site to an aggregationpoint provided that:

1. The generator transports the u sed oil in a vehicle owned bythe generator or owned by an employee of the generator;

2. The generator transp orts no more than 55 gallons of usedoil at any time; and

3. The generator transports the used oil to an aggregationpoint that is owned and/ or operated by the same generator.

(c) Tolling arrangem ents. Used oil generators may arrange forused oil to be transported by a transporter w ithout an EPAidentification nu mber if the used oil is reclaimed un der acontractual agreement pu rsuant to which reclaimed oil isreturned by the p rocessor/ re-refiner to the generator for

use as a lubricant, cutting oil, or coolant. The contract(known as a tolling arrangem ent) must indicate:

1. The type of used oil and the frequency of shipm ents;

2. That the vehicle used to transp ort the used oil to theprocessing/ re-refining facility and to d eliver recycled u sedoil back to the generator is owned and operated by the usedoil processor/ re-refiner; and

3. That reclaimed oil will be returned to the genera tor.


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Storage

Spill Prevention Control and Counterm easures (SPCC) ru les apply

to above-groun d storage tanks that are 660 gallons or greater and toaboveground oil storage facilities storing m ore than 1320 gallons.For example, three, 435 gallon tan ks are exemp t. One 660 gallontank an d one 650 gallon tank w ould not be exempt from SPCC. Atechnical bulletin, Spill Prevention Control and Coun termeasures(SPCC) is in Appen dix K.

An u nd ergrou nd oil storage tank (UST) less than 110 gallons isexempt from UST regulations.

USTs that store oil for on-site heating are exemp t from UST

regu lations. Keep containers in good condition, and clearly labeledthem Used Oil to prevent contamination. Do not mix solventswith used oil. When solvents are mixed with u sed oil, the oilmixture may be subject to regulation as a hazard ous w aste. Thatmeans the u sed oil may no longer be subject to the recyclingexclusion.

Store used oil in areas with oil-impervious flooring and second arycontainm ent structures.

DRUMS

A drum is emp ty if all material has been removed using thepractices commonly em ployed (e.g., pou ring, pum ping, andaspirating), and no m ore than one inch remains on the bottom of the55 gallon container or inner liner.

For a container of less than 110 gallons, the em pty containers mustcontain less than 3 percent by weight of the original conten ts. Forcontainers greater than 110 gallons, empty containers mu stcontain less than 0.3 percent of the original contents. It is importantto manage emp ty dru ms p roperly, particularly if contents werehazardous.

Drum s that contained acutely hazard ous (P listed) materials must betriple rinsed to be considered nonh azardous. Dispose of wasterinsates as a hazard ous w aste.


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Evaluate the u se of totes (bulk dispensers) and reusable transfer

containers. Many chem icals used in hospital engineering, facilitymaintenance, and laboratories are sup plied in dru ms. Unless theemp ty drum s containing P listed chemicals are triple rinsed beforedisposal, they may have to be hand led as hazard ous waste.

Many industrial facilities receive solvents, inks, adh esives, andchemicals in 400-gallon, reusable totes. When emp ty, the tote isreturned to the sup plier for cleaning and refilling. Using totesensures that th e container an d any chemical residu e left inside doesnot have to be d isposed of by the hospital.

RECYCLING

Empty containers can be sent to scrap m etal vendors. However, youmay consider crushing or cutting the d rum s and containers intometal scraps to ensu re that they are not being reused for storing ortransporting other material. Before cutting or crushing drums,determine if the dru m contained a flamm able material. These d rum smay contain an explosive mixture of air and vapor. Drum s shouldbe thorough ly pu rged before cutting operations.

Determine if a dru m reclamation comp any can recond ition yourdru ms for resale. Visit the site to insure that your dru ms areman aged responsibly and lawfully. If you d ecide to scrap yourdru ms, visit your scrap metal vendor to note how scrap is hand led.Ask questions on how your scrap is received and processed. Tourthe comp any to monitor how the containers are managed .

You have just assessed your departments and practices for waste

management and reduction. Now, review your checks and comments

that identify opportunities you can include in your plan and barriers

that may prevent implementation of other opportunities. Record

them in your hazardous waste reduction plan.

HANDS ON TASK


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HAZARDOUS WASTE STORAGE

A good hazardous waste storage and training program will contain:

A formal training on the safe hand ling of raw materials,hazard ous w astes, and th e types of dru ms, containers, andpackages received.

Provide and encourage the use of mechanical hand lingaides for hand ling d rum s.

A documented spill prevention and control program . Inaddition evaluate all processes that requ ire on-site mixing.Work with the suppliers or manu facturers to provide p re-

mixed compou nd s. Pre-mixed comp ounds maysignificantly red uce sp ills that resu lt from on-site mixing.

Clean-up kits.

Weekly inspection for drums (See Appendix B for a samp lechecklist).

A designated, centralized facility or place for hazard ouswaste storage, preferrably isolated from main buildings.The storage area shou ld be ventilated , contain a safety

shower, eye wash, sealed berm floors, and an emergencytelephone nearby.

Ensure that the storage area is located away from stormdrains, equipmen t or traffic. Also, chemicals and liqu idwastes should be stored in areas that do not d rain or spilld irectly to the sewers.

A storage area large enough to handle wastes for plannedbusiness growth or accomm odation for smaller d esigns toaccomm odate w aste reduction goals.

Diking and drainage containment.

An explosion proof area.

Electrical lighting systems that are designed to meet safetyrequirements for flammable hazard ous w aste storage.

No tools that may produ ce ignition with storedflammables.


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An overhead sprinkler system.

A fire detection system.

Identification of all chemicals and wastes.

A running inventory that indicates the type and am ount ofhazard ous wastes on-site.

Separation of hazard ous wastes from non-hazardou swaste an d chemicals.Note: If non-hazardous wastes orchemicals are mixed in any proportion with hazardous wastes,

the entire amount will become a hazardous waste.

Compliance with local fire and building coderequ irements. A local fire dep artment representativeshould be invited to aud it your hazard ous chemical andwaste storage areas.

Metal storage containers should be ground ed and bonded.Pouring and transfer containers must be bonded toreceiving d rum s.

ADDITIONAL ISSUES

Consider the w astes that w ill be generated w hen p lanning

procedures and experiments. Into every laboratory procedu re used,design the steps to render residues non-hazard ous.

Identify all wastes that are d isposed to th e POTW (pu blicallyown ed treatment w orks) and the federal wa ter and local POTWdisposal requirements that ap ply.

Do not mix solvent w aste streams with w ater or any other non -hazard ous waste. This practice ensures tha t your d isposal costs willincrease.


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SECONDARY CONTAINMENT

Secondary containm ent collects leaks and spills. It p rotects yourprop erty, resources and employees from hazard ous w aste spills.Second ary containment investment is minimal compared to clean u pcosts associated with one sp ill or accident.

Use second ary containm ent systems in satellite accum ulation areasand final w aste accumu lation areas.

Second ary containm ent should :

Ensure that the storage area keeps out rain, snow , andstanding water.

Prevent water, such as storm water from a parking lot,from entering the containment system. Carefu l layout,sloping or elevating th e containment area above grad eusually works.

Ensure that the stored wastes can not penetrate the base orfloor of the system. Sealed concrete and impervious p lasticmay work well while asphalt generally d oes not. Avoidcracks or un sealed joints.

Make sure the system can hold the entire volume of thelargest container. Appen dix L contains examples ofsecondary containment systems.


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CHAPTER 4

HOSPITAL XYZ WASTEREDUCTION PLAN

OCTOBER 1, 1994 Revision : New


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PREFACE

Hospital XYZ is committed to comp liance, risk red uction, pro tectingthe environment, and pollution p revention. Prior to the firstreporting d ate, Hospital XYZ had completed, or had in p rogress, thefollowing w aste redu ction efforts.

In 1991, we ph ased in zinc-formalin usage for surgical specimen, forbiopsies in 1992, and for skin lesions in 1993. Mercury-formalin isonly used as a fixative in cytology and bone marrow.


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WASTE REDUCTION POLICY STATEMENT

Hospital XYZ

Hospital XYZ advocates a safe and sup por tive environment forpatients and other individuals served by or provid ing services in thehospital. Hospital XYZs policy is to periodically evaluate andminimize the generation of solid w astes, especially hazard ouswastes.

Hospital XYZ is comm itted to a leadership ro le in p rotecting th eenvironmen t. Whenever feasible, we will eliminate, redu ce, orrecycle our waste in full comp liance with Federal and StateRegulations.

Furthermore, Hospital XYZ wants its employees to be fully aware ofall hazard ous and potentially dangerou s chemicals or equipmentused in the environment of care and to u se them in a completelysafe man ner. Our emp loyees will be informed an d included in thehosp itals effort to redu ce waste genera tion.

_____________________ _______________

CEO, Hospital XYZ Date


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SCOPE AND OBJECTIVES

To comp ly with the Tennessee Hazard ous Waste Reduction Act of

1990 and improve the env ironment, all emp loyees of Hospital XYZwill be involved in w aste redu ction. RCRA hazard ous wastes will beour first priority for waste redu ction.

Our goal is to reduce hazard ous w aste streams to the technicallyfeasible and economically practicable minimu m by th e timetablenoted in this plan. We will achieve these reductions through wasteredu ction assessments, procedure imp rovements, equipm entchanges, material substitution, emp loyee training and other effectivereduction methods.

WASTE REDUCTION PLAN ADMINISTRATION

(Name), (Position) will act as the Waste Redu ction Coord inator forHospital XYZ. The Waste Redu ction Coord inator w ill adm inister theplan, prepare the annu al progress report, up date the plan, andsupply information for the Annu al Hazardous Waste Report.

Waste redu ction op tions will be evaluated by the Safety Director,Purchasing Director, Housekeeping and/ or Environmental ServicesManager, Laboratory Services Manager(s), and other ap plicableemp loyees involved in the assessment team.

Waste reduction can only be achieved w ith the cooperation ofemp loyees generating the waste. Therefore, all emp loyees will bemad e aware of the need for waste redu ction. Training will beincorporated into the Haza rd Commun ication Training. Employeeswill also be polled on ways to imp lement waste reduction andmanagers will incorporate their suggestions, where p racticable, intotraining activities.

The true cost of waste management will be tracked. Whereapplicable, the following costs will be includ ed in th e plan an d bedocumented in the footnotes. Those costs can includ e:

Cost of raw materials lost to waste stream, management oroversight costs (adm inistrative record keeping cost, regu latoryreporting and compliance cost, record keeping costs, environmentaltraining cost, spill and emergency response management costs), andwaste disposal costs (labor, space, on-site storage and managemen tcosts, transportation costs, and off-site disposal costs).


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WASTE STREAM #1: Xylene Waste

Hospital XYZ u ses xylene in its processors an d stainers. Xylene is

typically used as a clearing agent that removes paraffin from thetissu

Documents

Waste Reduction Plan