[NORMAL] Hazardous Waste and Pharmaceutical Waste in

Hazardous Waste and

Pharmaceutical Waste in

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Veterinary Offices

Solid and Hazardous Waste Programs Florida Department of Environmental Florida Department of Environmental Protection

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Surgeon General’s Warning:

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This presentation may cause a lack of

oxygen to the brain, which may lead to

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Questions

Questions

•

Please minimize questions

until end of presentation

until end of presentation.

•

Your question may be

answered elsewhere in the

answered elsewhere in the

presentation.

Environmental Rules

• Clean Air Act (CAA) - 1970

Environmental Rules

( )

• Clean Water Act (CWA) - 1972

• Safe Drinking Water Act (SDWA) - 1974

F d l I ti id F i id d R d ti id

• Federal Insecticide, Fungicide, and Rodenticide

Act (FIFRA) - 1975

• Toxic Substances Control Act (TSCA) - 1976

• Resource Conservation and Recovery Act (RCRA)

-1976/1984

• Comprehensive Environmental Response • Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA) - 1980

• SARA/EPCRA - 1986 “Community Right to Know”

These environmental laws fall under the jurisdiction of the U.S. Environmental Protection Agency

RCRA

RCRA

• Resource Conservation and Recovery Act- 1976 • Resource Conservation and Recovery Act- 1976

• Hazardous & Solid Waste Amendments Act - 1984 • Create cradle to grave liability Create cradle to grave liability

• Provide standards for hazardous

waste generators, transporters, and waste generators, transporters, and

treatment, storage and disposal facilities (TSD)

• Ensure wastes that are land disposed meet either p concentration based or treatment based standards

No, it is not an acronym for

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• Florida Resource and Recovery Management

Florida’s Hazardous Waste Laws

Act-1980

• Chapter 403, Florida Statutes (F.S.) - 1980 • Rule 62-730 Florida Administrative Code

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Miscellaneous Florida Laws

Miscellaneous Florida Laws

• Discharge of hazardous waste to septic

tanks: F.S. 403.161(1)(a), 62-4.030 F.A.C.

• Discharges of wastes into waters or which • Discharges of wastes into waters or which

will reasonably be expected to be a source of water pollution shall be operated, p p ,

constructed, or modified with an

appropriate and valid permit issued by the Department: 62 620 300 F A C

Wh t i W t ?

Spent can’t be used again

What is a Waste?

Spent, can t be used again,

TYPES OF WASTES

TYPES OF WASTES

Trash,

Regulated

Non-Garbage,

Yard Waste

Non-Hazardous

Wastes

Wastes

Hazardous Wastes

Regulated Non-Hazardous

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Waste

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Industrial waste water

Sewage

Storm water

Storm water

Tires

Tires

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Solid Waste

IS A SOLID WASTE SOLID?

IS A SOLID WASTE SOLID?

•Liquids

•Solids •Gases

EXEMPTIONS

• Domestic sewage or if mixed with other

di h d POTW wastes discharged to a POTW

• Industrial waste discharges regulated under

Cl W t A t Clean Water Act

Solid Wastes which are not

Hazardous Wastes

(until testing complete) (until testing complete)

Other Non-Hazardous Wastes

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when Recycled /Reclaimed ….

• Universal Wastes Includes:Universal Wastes Includes:

―Light Bulbs Excluding Incandescent ―Mercury containing devices

―Certain Pesticides

―Batteries Excluding Alkaline

Ph ti l (FL)

―Pharmaceuticals (FL) • Used Oil

• Petroleum Contact Water Petroleum Contact Water (FL)

IF IT’S NOT A SOLID

WASTE...

IT’S NOT A HAZARDOUS

WASTE

Wh t i H

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What is a Hazardous Waste?

• Must be a solid waste (40 CFR 261.2)Must be a solid waste (40 CFR 261.2)

• Not excluded from regulation (40 CFR 261.4)

• Characteristic – Ignitability – Corrosivity – Reactivity – Toxicity • Listed

– Non Specific Sources

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– Specific Sources

Characteristic Hazardous Waste

(D-codes)

Ignitability – D001:

•

Flash point less than140

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Greater than 24% alcohol or

•

DOT oxidizer

Corrosivity – D002:

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pH less than or equal to 2 or

greater than or equal to 12.5

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Characteristic Hazardous Waste

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(D-codes)

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Reactivity – D003:

•

Normally unstable and reacts

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violently with water or explosive

mixtures

Toxicity -D004-D043:

•

Concentrations over TCLP levels.

•

Toxicity is determined by TCLP test

TCLP CONCENTRATIONS

40 CFR 261.24 (TABLE 1)

Basic TCLP

(Toxicity Characteristic Leaching Procedure)

(Toxicity Characteristic Leaching Procedure)

Hazardous Wastes

Hazardous Wastes

Characteristic Wastes:

– Photographic Fixer waste (silver-D011) – Spent solvents i.e. isopropyl alcohol Spent solvents i.e. isopropyl alcohol

(ignitability-D001)

– Incinerator ash (metals)

– Caustic/acid solutions i.e. NaOH

(corrosivity-D002)

Fluorescent lamps (mercury D009)

– Fluorescent lamps (mercury-D009)

– OTC products i.e. Colloidal Silver

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Listed Hazardous Waste

• F List – F001-F028: Wastes from non-• F List – F001-F028: Wastes from non-specific sources, i.e. spent solvents.

• K List – K001-K172: K List K001 K172: Wastes from specific Wastes from specific sources i.e. sludges and distillation

bottoms from wood preserving and p g petroleum refining.

• P (acutely toxic) or U (toxic)List: Pure chemical product that is discarded, spilled, off specification or container

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Hazardous Wastes

Listed Wastes:

– Paint/debris related wastes (F001-F005)

Spent solvents (F001 F005)

– Spent solvents (F001-F005)

– Off-spec chemicals (P & U list) i.e

Methanol (U154) Formaldehyde (U122) Methanol (U154) Formaldehyde (U122)

Universal Pharmaceutical Waste

(

)

(UPW)

62-730.186, F.A.C.

Hazardous Waste Rule:

Florida Administrative Code 62-730 Adopted 4/22/07

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Benefits of Rule:

• Simplified and flexible process promotes • Simplified and flexible process promotes

proper management and reduces illegal disposalp

• Grants longer storage time frames

UPW d t t t d

• UPW does not count towards

generator status

T i UPW i hi

• Transportation as UPW within

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Applies to:

• Hazardous waste pharmaceuticals while • Hazardous waste pharmaceuticals while

managed in Florida

• Large quantity handlers (LQH) and • Large quantity handlers (LQH) and

Small quantity handlers (SQH) of UPW I l d b th ti d i di

• Includes both routine and episodic

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Does Not Apply to:

• Non-hazardous pharmaceuticalsp

• Pharmaceuticals not discarded:

• Returned with reasonable expectation of credit p

through reverse distribution system

• Donated to charitable organization

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• Sold for resell (not discarded)

• Pharmaceuticals that are biomedical waste

• Spill residues, cleanup materials, and media

contaminated with pharmaceuticals

R t i l i di t d i f t

• Raw materials or ingredients used in manufacture

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How it Works:

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• Hazardous waste pharmaceuticals are

UPW when managed in accordance with this section

this section.

• Hazardous waste pharmaceuticals not

managed as UPW must be managed as managed as UPW must be managed as hazardous waste and disposed at a

permitted hazardous waste treatment, permitted hazardous waste treatment, storage, or disposal facility.

Handlers:

• Notify DEP and receive an EPA ID Number before y

accumulating or transporting UPW.

• Provide initial classroom or on-the-job training,

annual refresher, & keep documentation for 3 yrs.

• Manage UPW to prevent releases.

• Label containers with “UPW” and specific HW codes.

• Accumulation time limits:

― Small quantity handler – no longer than one year

from generation date

― Large quantity handler – no longer than six ― Large quantity handler – no longer than six

Shi

t f UPW

Shipments of UPW:

• Handlers can send to: another handler, reverse ,

distributor, destination facility, or foreign destination.

• Handlers that transport UPW must comply with

DOT regulations – package, label, mark and placard, and prepare proper shipping papers.

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• Handlers are advised to meet regulatory

requirements of receiving state.

• Handler keeps record of each shipment and retains

Does My Business Generate

Hazardous Waste?

Waste Determinations

Waste Determinations

• Material Safety Data Sheets (MSDS) P d t • Process or product knowledge • Manufacturer’s Technical • Manufacturer’s Technical sheets • Laboratory Analysis • Laboratory Analysis

Identifying Veterinary Wastes

Laboratory Wastes

•Out dated chemicals •Rinsates from

Preservation

Radiology

•S t h t hi fi t i i il

•Spent photographic fixer containing silver •Leftover barium sulfate

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& V t T h St ti

Pharmacy & Vet Tech Station

•E i d d d d

•Expired or damaged drugs •Chemotherapy waste

•Expired/Off Spec Chemicals,p / p , Reagents, & Standards

Don’t Mix Wastes

MIXING HAZARDOUS

Don t Mix Wastes

WASTES…

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•

Is often

DANGEROUS

Entities in RCRA

Entities in RCRA

•Generators

―Conditionally Exempt Small Quantity

Generators (CESQG)

―Small Quantity Generators (SQG)S a Qua t ty Ge e ato s (SQG)

―Large Quantity Generators (LQG)

•Transporters

•Transfer FacilitiesTransfer Facilities

•Treatment, Storage and Disposal Facilities

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Generator Status by Month

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•Waste counts for the month it was

generated in

CAN NOT BE AVERAGED CAN NOT BE AVERAGED

•Meet standards of generator status for that

month month

To Determine Generator Size

To Determine Generator Size

Count Hazardous Waste That: Count Hazardous Waste That:

– Is Transported Off-Site for Treatment,

Storage, or Disposal

– Is Treated or Disposed of On-Site

– Is Accumulated Prior to Recycling,

Long-Term Storage Transporting Treatment

D ’t C t

Term Storage, Transporting, Treatment or Disposal

Don’t Count:

– Spent Lead Acid Batteries sent for reclamation – Fluorescent bulbs sent for recyclingFluorescent bulbs sent for recycling

Conditionally Small Quantity

Generators

• Generates no more than 100 kg (220 lbs) of g ( )

hazardous waste per month. Approximately half of a 55-gallon drum, or about 25 gallons.

• Generates less than 1kg (2.2 lbs) of acutely toxic

hazardous wastes (P-listed) i.e. arsenic and cyanide

compounds) per monthp ) p

• Never accumulates more than 1000 kg (2200lbs) of

hazardous waste at any time.

Important CESQG

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Management Standards

• Perform Hazardous Waste DeterminationPerform Hazardous Waste Determination

• Ensure Delivery of Hazardous Wastes to

Proper Handling Facility Proper Handling Facility.

• Records Must Be Kept for at Least 3 Years

(FL) (FL).

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Small Quantity Generators

• Generates more than 100 kg (220 lbs), but

less than 1000 kg (220 lbs) of hazardous

waste per month. Approximately one half of a drum to 5 drums or 25 to 250 gallons of a drum to 5 drums, or 25 to 250 gallons.

• Generates less than 1kg (2.2 lbs) of acutely

t i h d t th

toxic hazardous wastes per month.

• Never exceeds the 6000 kg (13,200 lbs)/ 180

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day storage time limit.

Important SQG

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Management Standards

• Obtain FDEP/EPA ID NumberObtain FDEP/EPA ID Number

• Use Manifest System Unless Reclamation

Agreement Is Established

• Keep Records for Three Years

• Label & Date Hazardous Wastes Properly

H M difi d C ti Pl

• Have a Modified Contingency Plan • Train Personnel About Proper HW

Handling & Emergency Response Handling & Emergency Response

• Meet Satellite Accumulation

Requirementsq

Large Quantity Generators

• Generates more than 1000 kg (2200 lbs) of g ( ) hazardous waste per month.

Approximately greater than 5 drums.

• Generates more than 1 kg (2.2 lbs) of

acutely hazardous waste per month.

• Never stores hazardous waste greater

than 90 days.

Important LQG

Management Standards

• SQG i t l

• SQG requirements plus …….. • Do Not Store HW > 90 Days

• File Biennial Report for HW Shipped

Offsite

• Maintain Emergency Equipment • Expanded Contingency Plan

• Expanded Contingency Plan • Annual Training

So What Do We Look for

During an Inspection……?

• Inspectors look at “all” processes and Inspectors look at all processes and procedures performed on a contiguous piece of property.

• Inspectors look at what chemicals are

used how they are used and the waste used, how they are used, and the waste streams expected from each process.

• Inspectors will also usually walk

Unannounced

Unannounced

SORRY!!!

SORRY!!!

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How to Keep Inspectors Happy

“Biodegradable”

more than 100 times more than 100 times.

• Don’t say “The EPA

j t h ” was just here”

• Keep business cards

of inspectors who have been to your facility

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• First impression

Housekeeping

First impression

• If housekeeping is poor–waste management

is often poor, too. is often poor, too.

• Can become a

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Waste Determination

• Failure to perform hazardous waste

determination and/or a proper waste determination.

Notification

• Failure to notify/obtain an EPA ID • Failure to notify/obtain an EPA ID

number

M if t

• Failure to use a hazardous waste manifest

Manifests

• Failure to use a hazardous waste manifest • Failure to file an exception report (45/60

days) days)

• Missing or incorrect information on

manifest. manifest.

• Failure to retain manifests for 3 years.

• Must use Federal Uniform Manifest-since • Must use Federal Uniform Manifest since

Manifest Initiation, Movement,

,

,

& Copy Retention

The generator initiates the manifest which travels with the transporter to

Off-site Treatment/Disposal

the broker or final TSD facility. The generator, transporter, and TSD

facility each keep a copy and the TSD mails a return copy to the generator. Everybody keeps their copies for 3 years.

Waste Received from Off-site Process or Cleanup Waste Treatment System Storage Transporter (s) Manifest Copy

Off site Treatment/Disposal Generator Manifest Copy TSDF Manifest Copy Transporter's)

Manifest CopyTSDF _Manifest Copy

Shipped Off-site for Treatment/Disposal Generator Initiates Manifest TSDF Initiates New Manifest Return Manifest C

Return Manifest Copy

O b d M if l i h R M if b M il

Copy

Return Certificate of Disposal by Mail

Outbound Manifest travels with

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Labeling

•Failure to label drums/containers with the •Failure to label drums/containers with the

words “Hazardous Waste” or for satellite accumulation containers label with a

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Accumulation

• Accumulation beyond the 90(180) day limit. • Drums/containers not marked with

accumulation start dates.

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Container Management

• No weekly inspection of containers. • Failure to maintain aisle

Record Keeping

• Failure to maintain uniform

manifest or contractual agreement for 3 years.

• Failure to retain records of test results, waste

Personnel Training

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Preparedness and Prevention

• No arrangements with local authorities. • Arrangements not documented.

• Failure to have required equipment • Failure to have required equipment.

• Failure to maintain and operate facility to

minimize unplanned or sudden release minimize unplanned or sudden release.

Contingency Plan/Emergency

Procedures

• Failure to have a modified contingency • Failure to have a modified contingency

plan.

• Incomplete or outdated contact info. Incomplete or outdated contact info.

• Incomplete reporting after an incident. • Failure to report emergency incident p g y

(assuming release to the environment)

• Failure of SQG to post information by

Land Disposal Restriction

Land Disposal Restriction

FL has NO HW landfills

landfills

All h d t i All hazardous waste is

PROHIBITED from land disposal in

land disposal in Florida

Aft th I

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After the Inspection

• If you agreed to fix

something - fix it!

• If you promised to

send inspector

something - send it something send it.

• If you receive a letter

- respond within the respond within the specified time frame.

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The Process

The Process

• Non-Compliance Letter /Warning Letter • Inspection Report Pi t p •Inspection Report •Pictures • Pictures • Violations • Penalties • Informal Conference • Chance to respond

• Discuss alleged violations • Discuss alleged violations • Consent Order

Memorandum of Agreement

Memorandum of Agreement

with

with USEPA

USEPA

•RCRA Program has been delegated to •RCRA Program has been delegated to

every State except Iowa

•FDEP has 360 days from the date of the •FDEP has 360 days from the date of the

inspection to settle a case

•EPA requires penalties for certain •EPA requires penalties for certain

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New Gravity Based Component

New Gravity Based Component

POTENTIAL EXTENT OF DEVIATION

FOR HARM

MAJOR MOD. MINOR

$37 500 $28 330 $21 250 $37,500 $28,330 $21,250 MAJOR to to to $28,330 $21,250 $15,580 $15,580 $11,330 $7,090 MODERATE to to to $11 330 $7 090 $4 250 $11,330 $7,090 $4,250 $4,250 $2,130 $710 MINOR to to to MINOR to to to $2,130 $710 $150

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Janine.Kraemer@dep.state.fl.us

Phone: 407-893-3329

Phone: 407-893-3329

Helpful Web Sites:

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www.dep.state.fl.us