We’ve written several posts about how to determine whether your waste is actually waste and if it’s hazardous waste, using the four EPA lists (F, K, P, U) and testing for the four EPA characteristics of hazardous waste (toxicity, reactivity, ignitability, corrosivity [TRIC]). These are the steps you take to determine if a waste is hazardous using its chemical properties, but there are other types of hazards, including radioactive hazards and biological hazards. It may be surprising, but hazardous waste requirements only apply to listed or characteristic wastes; they don’t apply to radioactive or biohazardous wastes.
Radioactive wastes are produced by the nuclear industry (high-level spent fuel, low-level wastes), in medicine (such as radiation cancer therapy) and in life sciences research. Radioactivity is not included as one of the Resource Conservation and Recovery Act (RCRA) TRIC hazard characteristics; radioactive waste is not regulated under RCRA or state hazardous waste regulations. Even though they are not regulated as “hazardous waste” under RCRA, radioactive wastes are potentially hazardous and are regulated at the federal level by the Nuclear Regulatory Commission (NRC). NRC sets standards in Title 10 of the Code of Federal Regulations (10 CFR) that are enforced by each state.
Radioactive materials decay over time. Some materials with short half-lives (fewer than 120 days) can be stored until radiation decays to background levels (typically 10 half-lives or more). These include radioisotopes used in life science research and nuclear medicine, such as phosphorous-32 (P32; half-life of 14 days) or sulfur-35 (S35; half-life of 87.4 days).
Longer half-life materials can be accumulated on-site for disposal at a regulated radioactive waste disposal site. Because radioactive waste is not regulated under RCRA, specific RCRA accumulation time limits and other hazardous waste management requirements do not apply. Of course, there are other radiation safety requirements that do apply to storage and handling of radioactive waste.
Biohazardous or medical waste
Biohazardous or medical waste refers to wastes containing blood, bodily fluids and potentially infectious materials produced at medical facilities, as well as to wastes potentially contaminated with infectious agents associated with biomedical research. The hazards of these wastes are biological, not chemical, in nature. These wastes are also hazardous, but as with radioactive wastes, they are not regulated as “hazardous waste.”
Medical waste is primarily regulated at the state level, including definitions for what is and isn’t considered medical waste, requirements for accumulating and managing medical waste on-site, and treatment and disposal. For example, California medical waste regulations are found in the California Medical Waste Management Act (CA H&SC Sections 117600–118360), which is enforced by the California Department of Public Health (CDPH).
Definitions of what constitutes medical waste vary among states, but general categories of medical waste include:
- Biohazardous or potentially infectious substances, such as blood or other bodily fluids, as well as potentially infectious micro-organisms (BSL-2). Debris contaminated with these materials would also be considered potentially infectious.
- Pathology waste, including human and animal body parts, specimens and tissues.
- Sharps waste, including needles, syringes, razor blades and scalpels, and other items capable of cutting or piercing skin.
- Many states also regulate other materials, such as chemotherapy waste or certain waste pharmaceuticals as medical waste.
Medical waste is different from hazardous waste and radioactive waste, in that the hazard can be removed through thermal methods (such as heat or steam) or by chemical means (such as the use of bleach or other disinfectants), as well as by incineration. Once “killed” through heat or chemical disinfection, the biological hazard has been removed, and the waste is no longer potentially infectious — therefore, it is no longer considered a biohazardous waste. The EPA regulates disinfectants and substances that claim to have anti-microbial properties through the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). Additionally, many states have regulations requiring medical waste treatment technologies to be certified, licensed or regulated.
ACTenviro has experts available to help you with your waste at each step along the way, from determining what you have to proper disposal. Please reach out to us at [email protected], and let us know how we can help.
James Kapin is Principal Advisor for safety, health and environmental compliance for ACTenviro. Jim is a Certified Industrial Hygienist (CIH) and a Certified Safety Professional (CSP) with over 25 years of workplace safety and environmental protection experience. Do you have any hazardous waste questions for Jim? Or any other workplace safety or environmental compliance questions? Let us know at [email protected]