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HWI Petitions EPA for Regulatory Relief due to Hazardous Waste Incinerator Backlog


(Brookfield, WI – January 24, 2023) PharmEcology Services, WM Sustainability Services
The Healthcare Waste Institute, HWI, is a non-profit trade organization representing a variety of medical    waste transporters and disposers that service the healthcare industry. Due to a variety of factors, including labor shortages, weather related power outages, increased hazardous waste generation due to an uptick in the economy, and decreased hazardous waste facilities, many healthcare facilities are unable to schedule hazardous waste pickups and are at risk of exceeding their respective hazardous waste storage time limitations. Large quantity hazardous waste generators have a maximum of only a three-month storage time limit, whereas small quantity generators of hazardous waste, which includes many hospitals, have a six-month limit with a possible extension based on distance from the incinerator. Even with a six-month timeframe, facilities are often requesting 30-day extensions from their state environmental protection agencies. ASTSWMO (Assn of State and Territorial Solid Waste Management Officials) ® reported at their annual meeting on October 20th, 2022 that state agencies have received more than 3300 hazardous waste storage extension requests from 43 states related to storage times from hazardous waste generators across wide range of industries.
https://astswmo.org/files/Meetings/2022/annual/Presentations/D1-P1-perszyk-bansch.pdf


On October 24, 2022, HWI petitioned EPA for a “no action assurance” for healthcare facilities that currently have a requirement under the Subpart P Hazardous Waste Pharmaceuticals regulation to dispose of all hazardous waste pharmaceutical containers within one year of first use. Due to the hazardous waste pick-up backlog, healthcare facilities are concerned they will be forced to violate the current regulation due to no fault of their own. The “no action assurance” would relieve that concern. To date, EPA has not responded to this request. Healthcare facilities should minimize all hazardous waste generation as much as possible, including hazardous waste pharmaceuticals. Segregating hazardous and non-hazardous pharmaceutical waste in the pharmacy and nursing units would assist in managing this situation, while also significantly reducing hazardous waste disposal costs. HWI has also created a Fact Sheet outlining their concerns which can be accessed at https://wasterecycling.org/wp-content/uploads/2022/10/Haz-waste-incinerator-backlog-factsheet8.pdf.


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