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lists of licensed waste management facilities.
a licensed infectious waste transporter [exit DNR].
to Healthcare Waste News.
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For more information about healthcare waste, contact:

Hazardous waste management at healthcare facilities

Hazardous waste is a waste with properties that make it dangerous or potentially harmful to human health or the environment. Under state and federal law, a waste is hazardous if it is specifically listed as a hazardous waste or if it exhibits a hazardous characteristic.

As defined by the U.S. Environmental Protection Agency (EPA), the list of hazardous wastes are:

  • "F-listed" wastes that come from common industrial and manufacturing processes, including such spent solvents as xylene and acetone;
  • "K-listed" wastes that come from specific industry processes; and
  • "P- and U-listed wastes" that are discarded and unused chemical products and formulations. Some drugs are P-listed acute hazardous waste, which mean they pose severe risk to human health and the environment. Some unused chemotherapy drugs are listed as P- or U waste. Because of the increased hazards, more stringent standards apply to P-listed wastes and containers or packaging that held P-listed pharmaceuticals.

Characteristics of hazardous waste include ignitability, corrosivity, reactivity and toxicity. Other wastes that can also be hazardous include:

  • waste alcohol, which may exhibit the hazardous waste characteristic of ignitability;
  • aerosols, which may be ignitable hazardous waste because of the contents or the propellant used;
  • mercury-containing wastes, such as vaccines preserved with thimerosal, which generally exhibit the toxicity characteristic;
  • strong acids and bases, which are hazardous waste because of corrosivity; and
  • picric acid or ethyl ether, which may exhibit the characteristic of reactivity.

For more information, see hazardous waste rules, ch. NR 661, Wis. Adm. Code.

Proper hazardous waste management at healthcare facilities

Hazardous waste can be a relatively small percentage of the waste generated by healthcare providers. However,l hazardous waste must be managed appropriately. There are three steps to the proper management of hazardous waste.

  1. Make a waste determination. Identify which wastes are hazardous and why – are they listed or do they have one or more of the characteristics?
  2. 2. Determine the generator classification. Count the hazardous waste generated by all of the different departments in the healthcare facility. The quantity and types of waste generated during each month determine the generator classification and the requirements that apply to your facility. For example, generating even small quantities of P-listed acute hazardous wastes can mean more stringent requirements.
  3. Manage the hazardous waste according to the requirements, which are based on your facility's hazardous waste generator classification. The specific requirements for very small, small and large quantity generators are stated in Wisconsin hazardous waste rules, ch. NR 662, Wis. Adm. Code. [exit DNR]

The three hazardous waste generator classifications are as follows:

  • Very Small Quantity Generator (VSQG): generates 220 pounds or less per month non-acute hazardous waste and less than 2.2 pounds per month acute hazardous waste.
  • Small Quantity Generator (SQG): generates between 220 pounds and 2,205 pounds per month non-acute hazardous waste and less than 2.2 pounds per month P-listed acute hazardous waste.
  • Large Quantity Generator (LQG): generates 2,205 pounds per month or more non-acute hazardous waste or 2.2 pounds per month or more acute hazardous waste.

Large quantity and small quantity generators, very small quantity generators that choose to manifest their waste, and hazardous waste treatment and storage facilities must notify the DNR of their hazardous waste activity and obtain an EPA ID number.

To apply for an EPA ID number, you must file a Notification of Regulated Waste Activity (EPA Form 8700-12). For assistance with the form, or to submit completed applications, contact your DNR regional environmental program associate.

Used oil

Used oil is an additional type of hazardous waste that healthcare facilities may generate. Used oil, including lubricating oil, penetrating oil and turbine oil, is regulated under ch. NR 679, Wis. Adm. Code [exit DNR]. Store used oil in containers or tanks that are in good condition and labeled with the words "used oil."

Do not mix used oil and hazardous waste; the mixture may need to be disposed of as hazardous waste rather than recycled as used oil. Used oil above-ground or underground storage tanks are regulated by the Wisconsin Department of Safety and Professional Services (DSPS). For information on storing used oil in tanks, see the DSPS page on the topic [exit DNR]. If used oil is burned in an on-site space heater, see the DNR fact sheet Burning Used Oil in a Space Heater (WA-1003) [PDF].

DNR publications

Last revised: Wednesday February 19 2020