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Hazardous (and Universal) Waste Management

Course Number: 499


The Resource Conservation and Recovery Act (RCRA) of 1976, an amendment to the Solid Waste Disposal Act provides general guidelines for the management of non-hazardous (Subtitle B) and hazardous solid wastes (Subtitle C).1 The RCRA also set national goals to protect human health and the environment, to conserve energy and natural resources, to reduce the amount of waste generated, and to ensure that wastes are managed in an environmentally sound manner.

While the RCRA provides a framework for the waste management program envisioned by Congress, it gives the federal Environmental Protection Agency (EPA) the authority to develop explicit, legally enforceable requirements for waste management (Title 40, Code of Federal Regulations (CFR), Parts 239-282).2 The EPA also promulgates guidance documents and policy directives to clarify issues related to the implementation of the RCRA.1,3

The federal EPA defines any garbage, refuse, sludge, and other discarded material resulting from industrial, commercial, mining, agricultural, healthcare, and community activities as solid waste.1,4 The definition does not imply that the waste is physically solid. A solid waste may be semi-solid (or semi-liquid), liquid, or contained gaseous material. Discarded material is any solid waste that is inherently waste-like, recycled or abandoned (Box A).1,4

Box A. EPA definitions of “discarded material” as they apply to solid wastes.1,4

Inherently waste-likeSome materials pose such a treat to human health and the environment that they are always considered solid waste, i.e., they are “inherently waste-like.”
RecycledA material is considered “recycled” if it is used or reused (e.g., as an ingredient in a process), reclaimed, or used in a manner constituting disposal (e.g., burned for energy).
AbandonedThe term “abandoned” means thrown away. A material is considered abandoned if it is disposed of, burned, or incinerated.

Most solid waste generated in oral healthcare settings is non-hazardous solid waste, a subset of municipal solid waste.5. Standard methods of collecting, storing, transporting, and disposing such wastes are regulated by state or local jurisdictions. It is of import to note that municipal solid waste regulations often include mandatory requirements for recycling certain materials (e.g., newspapers, cardboards, plastics, glass containers, aluminum cans, etc.).

A small percentage of solid waste generated in oral healthcare settings is hazardous solid waste derived from hazardous material. These may be biological, chemical, radiological, or physical agents used or generated in the workplace, which because of their quantity; concentration; or physical, chemical, or infectious nature pose a hazard to human health (increase the incidence of serious illness or mortality) or to the environment when improperly handled.1

Subsets of hazardous solid waste include regulated medical waste and hazardous waste. The federal OSHA and its counterpart state agencies are responsible for developing and enforcing rules for regulated medical waste. These rules are based on anticipated risks of exposure to blood and other potentially infectious material and relate to workers’ health and safety. A review of regulated medical waste management in oral healthcare settings is presented elsewhere.6

The federal OSHA and its counterpart state agencies are also responsible for developing and enforcing rules for hazardous chemicals as they relate to workers’ health and safety. These rules are predicated on anticipated risks of exposure to chemicals in the workplace and the need to communicate this information to workers based on the principle of “right to know.” A review of hazard communication compliance in oral healthcare settings is presented elsewhere.7

Federal EPA regulations (40 CFR, Parts 239-259) identify state and local governments as the primary planning and regulating entities for non-hazardous solid waste management such as household garbage and industrial solid waste.2 Title 40 CFR, Parts 260-273 establishes a federal program for hazardous solid wastes management from cradle to grave to ensure that hazardous solid wastes are handled in a manner that protects human health and the environment.2

This continuing education course focuses on those parts of federal EPA regulations (40 CFR Parts 260-273) that are relevant to developing and implementing an effective hazardous waste management program in oral healthcare settings. It is advisory in nature and informational in content. Since state regulatory requirements may be more stringent, the State-by-State Hazardous Waste Resource Locator provides information for specific jurisdictions (Figure 1).8

state resource locator

Figure 1. State-by-State Hazardous Waste Resource Locator.8