A Question (way back on February 16th) requesting help with the annual hazardous waste report (Due March 1st!):
I am completing the annual hazardous waste report and am trying to determine whether the material is non-acute or acute. Hopefully you can answer my question and offer a bit more information.
Looking through the forms, I think we are P042.
This may be all I need, however; I would appreciate any articles you may share with me.
I also spoke with this person over the phone to gather additional information. The inquisitor referred to “epi pins” that they discard as a waste.
My answer a few hours later that same day (I knew she was in a rush for the information):
I apologize for my delay, my return to the office took longer than I thought. Your situation calls for more research but I will do my best to answer your question and direct you to additional information.
- Epinephrine is identified as a P-Listed material and possibly a RCRA hazardous waste. See below and Refer to the EPA List of Lists.
- In addition to being listed by name the material must also be one of the below. Also, read What is a P- or U-Listed Hazardous Waste?
- Unused or virgin, or;
- An intermediate product you manufactured, or;
- An off-spec version of a listed material, or;
- Residue in a container that is not “RCRA Empty”, or;
- Residue or recovered spilled material.
- Any P-Listed hazardous waste is also known as an acute hazardous waste. Read: What is an Acute Hazardous Waste?
If the “epi pins” you mentioned meet the above criteria, it is likely you are a generator of an acute hazardous waste and likely a Large Quantity Generator (LQG). Read: Determine Hazardous Waste Generator Status From Acute Hazardous Waste.
- Are you the generator of this waste? If you are gathering this waste from others, then it is possible that you are not the generator of the waste; the ones sending it to you are the generators.
- Who are the “persons” sending you the waste? If they are excluded or exempt from regulation, e.g. a household, it is likely the waste is excluded as well and therefore not subject to reporting.
- If the “persons” sending you the waste are not excluded from regulation, how are they sending it you? Hazardous waste is not usually sent by mail.
- There are other hazardous wastes, both listed and characteristic, associated with medical or pharmaceutical waste. Do you have other hazardous waste to report?
- If not an excluded hazardous waste is it being managed according to the RCRA regulations (state and federal) applicable to a Large Quantity Generator? Requirements include: annual training (I do this!), weekly inspections, emergency preparedness, a Contingency Plan, closed containers labeled and marked, 90 day on-site accumulation time limit, more…
Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste
Daniels Training Services