Hazard Waste Generator Status
In light of the ongoing implementation of the EPA's Final Rule on hazardous waste pharmaceuticals, known as Subpart P, it is crucial for healthcare organizations to assess their hazardous waste generator status. This determination process can be complex, and the following sections will provide necessary clarity and guidance to Assist healthcare facilities in identify whether they generate hazardous waste.
Hazardous waste is a broad term that encompasses a range of dangerous chemicals, pharmaceuticals, and other potentially toxic materials. To comply with EPA regulations, every organization, including hospitals and health systems, must determine whether they generate hazardous waste, and if they do, how much of it they generate. Note that hazardous waste is not the same as regulated medical waste, such as sharps waste or red bag waste. These are completely different types of wastes and must be handled differently.
Most healthcare organizations generate hazardous waste to some degree, whether that’s lab reagents, certain cleaning products, hazardous pharmaceuticals, or other items. However, quantifying these wastes can become tricky because many of the materials that fall under this category are not labeled as hazardous, and there is no “master list” organizations can check. Your waste hauler cannot make this decision for you either. It is up to every organization to figure out whether it generates hazardous waste and how much of it there is. To ensure compliance, someone in your organization should be tapped to oversee the process.
