Federal regulation of waste disposal

Because of the varied nature of the products that require disposal in veterinary practices, more than one federal agency is involved in regulating the disposal process. Simply put, the Environmental Protection Agency (EPA) regulates the disposal of products with environmental impact; the Occupational Safety and Health Administration (OSHA) regulates factors associated with potential employee exposure to hazardous substances; the National Institute of Occupational Safety and Health (NIOSH) provides guidance pertaining to products used in the workplace that impact human and public health; and the Drug Enforcement Agency (DEA) regulates the disposal of controlled substances.

However, many veterinarians are not aware that they are also subject to regulation by federal agencies such as the Department of Transportation (DOT), and the Nuclear Regulatory Commission (NRC). Veterinary practices that ship hazardous materials (which can include chemicals used in practice or even laboratory specimens) are subject to DOT regulation. Practices that ship materials via air (such as laboratory specimens) are subject to regulation by the FAA (which enforces DOT regulations), and any practice that provides nuclear scintigraphy or radionuclide therapy is subject to regulation by the NRC.

For more details and access to regulatory materials, visit the links below.

Environmental Protection Agency (EPA)

• Clean Air Act (CAA)
  • National Emission Standards for Hazardous Air Pollutants: Area Source Hospital Ethylene Oxide Sterilizers
• Clean Water Act (CWA)
  • EPA's civil enforcement of the CWA
  • Animal Feeding Operations and the National Pollutant Discharge Elimination System (NPDES)
  • Effluent Guidelines: Aquatic Animal Production Industry
  • Ten Tips to Prepare for EPA Concentrated Animal Feeding Operations Inspections
• Resource Conservation and Recovery Act (RCRA)
  • Provides EPA with the authority to regulate hazardous wastes from "cradle-to-grave" (which includes all aspects from when it is made to when it is disposed and everything in between).
  • Notification of Regulated Waste Activity (EPA Form 8700-12) and RCRA Hazardous Waste Part A Permit Application (EPA Form 8700-23)
    • Provides information to help you determine if you need to notify the EPA or your state authorities about wastes you generate or handle as well as how to properly notify them if you are required to do so.
  • RCRA FAQs
  • RCRA Statute, Regulations & Enforcement
  • RCRA Guidance, Policy, and Resources
  • EPA's Hazardous Waste Regulations website
  • Hazardous Waste Generator Categories and Information
  • Waste – Resource Conservation
  • Definition of Solid Waste (DSW) Rulemakings for RCRA Hazardous Waste Regulations - 2011 Proposed Rule
• Toxic Substances Control Act (TCSA)

Occupational Health and Safety Administration (OSHA)

• OSHA Office Directory
• 29 CFR 1910.1030 Bloodborne Pathogens: Contains regulations pertaining to Regulated Medical Waste (RMW) such as sharps, potentially infectious substances, and other biohazard issues.
• 29 CFR 1910.1200 Hazard Communication Standards (HCS): Covers requirements of Hazard Communication of employers (including veterinarians and those in the human healthcare sectors) who have employees work with or around hazardous chemicals.
• OSHA Q&A related to the HCS and veterinary facilities:
  • Hazard Communications in veterinary practice
  • Hazard Communications pertaining to veterinary drugs
  • OSHA Standards on Bloodborne Pathogens as related to veterinary practices

Department of Transportation (DOT) Pipeline and Hazardous Material Safety Administration

• 49 CFR 171, 172, and 173: Discuss personnel training, packaging, and transporting requirements related to hazardous materials; these regulations are also enforced by the Federal Aviation Administration with regard to shipping specimens.

Center for Disease Control (CDC) National Institute for Occupational Safety and Health (NIOSH)

• NIOSH List of Antineoplastic and Other Hazardous Drugs in Healthcare Settings, 2016 is more inclusive than those regulated under RCRA, and EPA currently recommends that NIOSH-listed items be handled as if they were in the RCRA as well.
• Other Resources
  • Hazardous Drug Exposures In Health Care
  • Preventing Occupational Exposure to Antineoplastic and Other Hazardous Drugs in Health Care Settings
  • Safe Handling of Hazardous Drugs for Veterinary Healthcare Workers

Drug Enforcement Agency (DEA)

• Controlled Substances Act (CSA), among other aspects relative to controlled substances, this act regulates their disposal
• Disposal of Controlled Substances​ (21 CFR 1317)

Nuclear Regulatory Commission (NRC)

• Atomic Energy Act (AEA) regulates military and civilian use of nuclear materials.
• Regulatory Guide 8.18: Information Relevant To Ensuring That Radiation Exposures At Medical Institutions Will Be As Low As Is Reasonably Achievable
• Veterinary Uses Toolkit

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