Health Waste_Content Page_Hazardous waste management at healthcare facilities

Hazardous waste management at healthcare facilities

Healthcare providers generate many types of wastes, including pharmaceutical, medical, infectious, solid and hazardous waste. While hazardous waste can be a relatively small percentage of the waste generated by healthcare providers, it must be identified and managed appropriately.

Hazardous wastes potentially generated at healthcare facilities include:

  • Hazardous waste pharmaceuticals
  • Discarded and unused chemical products and formulations
  • Waste alcohols
  • Aerosols
  • Mercury-containing wastes, such as vaccines preserved with thimerosal
  • Strong acids and bases
  • Picric acid or ethyl ether
  • Leaded aprons
  • Universal wastes and used oil

Health Care Initiative Fact Sheet: Table of Common Wastes in Health Care (WA-1259) [PDF] provides guidance on common healthcare wastes.

Determining generator status

The quantity and types of waste generated each month determines a facility’s generator classification or status and the requirements that apply.

If the facility is a small quantity generator or large quantity generator, the facility will be required to notify the Department of Natural Resources and operate under the Subchapter P pharmaceutical rules. Under Subchapter P requirements, the facility’s generator classification may potentially be reduced. This reduced generator classification would be part of the notification to the DNR.

To determine generator status:

  1. Count all hazardous waste generated or stored by all departments in the healthcare facility, including pharmaceutical waste, and determine generator classification.
  2. Count all non-pharmaceutical hazardous waste and determine the generator classification.

A large quantity generator may potentially reduce to a small quantity generator or a very small quantity generator classification and manage its non-pharmaceutical hazardous waste under this new generator classification. A small quantity generator may potentially reduce to a very small quantity generator classification and manage its non-pharmaceutical hazardous waste under this new generator classification.

The pharmaceutical waste is managed under Subchapter P requirements.

Limitations on sewering pharmaceutical waste

In 2020, the Pharmaceutical Rule was adopted into Wisconsin Administrative Code. To the extent possible, the content and format follow federal regulations.

Under s. NR 666.505, Wis. Adm. Code., all healthcare facilities are banned from discharging hazardous waste pharmaceuticals into a sewer system (i.e., disposing of them down a sink or toilet drain). The DNR s recommends all facilities avoid sewering any pharmaceuticals, regardless of their solid or hazardous waste classification.

DNR publications