Waste Determination in Healthcare: Best Practices

Waste generators are responsible for conducting a waste determination for all waste they produce. A generator is the person or site whose act or process produces the waste. This includes healthcare facilities such as hospitals, clinics, or labs. A waste determination is a conclusion about the makeup of the waste that is used to decide how it should be managed under applicable regulations. This helps ensure that organizational waste is handled and disposed of properly. For example, the U.S. Environmental Protection Agency (EPA) requires that a person who generates a solid waste must make an accurate determination as to whether that waste is a hazardous waste to ensure wastes are properly managed according to applicable RCRA regulations.

Organizations should have policies, trainings, and resources in place that can guide employees on how to make accurate waste determinations. A waste determination should be based upon an understanding of the processes that produce the waste.

When making a waste determination, some of the key considerations to ask include:

• What is the waste?

• Who generated it?

• How was it generated?

• Where was it generated?

Answers to these questions will give insight into the characteristics of the waste, which is relevant to determining whether the waste is hazardous or otherwise regulated. Within healthcare, waste determinations can be particularly complex due to the numerous processes generating waste, the volume of waste generated, and the types of chemicals used.

In addition to understanding how the waste was generated, healthcare facilities should consider applicable regulations and policies when conducting waste determinations. This includes:

Regulations

Regulations are the legal requirements your organization must follow, and they may be local, state, or federal. Where the waste is generated matters, as some regulations, such as those governing regulated medical waste (RMW), may vary from state to state. Examples of federal regulators of RMW include the Occupational Safety and Health Administration (OSHA) and the Department of Transportation (DOT). Regulatory definitions will help you classify your waste as part of a waste determination.

Standards and Industry Best Practices

When considering industry best practices, look to organizations such as the Centers for Disease Control and Prevention (CDC). Regulatory agencies may also publish industry-specific guidelines and resources, such as A 10-Step Blueprint for Managing Pharmaceutical Waste in U.S. Healthcare Facilities, which was published in 2022 with support from the U.S. EPA. These types of guidelines will help you in performing accurate waste determinations.

Waste Acceptance Policies

Waste acceptance policies are the requirements of a waste vendor about what they will or will not accept, and under what conditions. These acceptance policies are designed to meet regulatory requirements but are also informed by operational constraints, safety, business needs, and other policy considerations. Some waste vendors may choose to have stricter guidelines than what would otherwise be permissible under applicable law. After you perform a waste determination, taking into account the relevant regulations, it is important to also review your waste vendors’ policies.

Organizational Policies

Your organization may have its own policies and procedures governing how certain waste is to be classified or managed. Your organizational policies should consider regulatory requirements, industry best practices, and standards you determine as necessary. Organizational policies should also consider vendors’ waste acceptance policies and alignment with your internal policies that relate to managing waste.

If waste is not properly identified, there can be a variety of negative effects relating to compliance, safety, and sustainability. These include environmental impacts, community health impacts, and financial impacts. To help ensure compliance, make accurate waste determinations. This will help keep people safe and will promote sustainable waste management practices at your facility. Being diligent at the outset can save time and prevent issues down the line.

For information on how WM can support your organization’s regulated waste management needs, please contact us.

This article is for general information purposes only and should not be construed as legal advice on any specific facts or circumstances.