Questions to Ask Your Recycler

When talking with a potential recycling business partner, use the following list of questions and discussion topics to help guide the conversation.

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What plastics materials can the recycler/ materials recovery facility (MRF) accept?

Are all of the plastics from your waste characterization accepted? This would include:

• Types of plastics (PET, PETG, PE, HDPE, PS, PP)

• Forms of plastics (rigid plastics vs. flexible plastics)

• Shapes of rigid plastics (bottles versus other shapes may affect processing equipment)

• Contamination (paper labels, mixed plastics, glass, cardboard, wet materials, etc.) Mixing and compacting medical plastics waste stream with post-consumer recyclables may result in contamination with broken glass.

In what form can the MRF/recycler accept materials?

Considering the materials the recycler has indicated are acceptable for recycling, must they be collected separately or may they be comingled? May certain types of materials be collected together and others collected separately?

How does the recycler want them packaged?  Is accumulation in polyethylene (LDPE/HDPE) bags acceptable?  How can the materials be temporarily accumulated at the hospital pending shipment offsite? This could be bales, gaylords, truckload, etc. What will the dock-out process be? These questions will help inform hospital dock procedures–see the space guidance section for more information

What about nonconforming materials?

From the hospital perspective, nonconforming materials usually means that infectious materials or sharps are accidentally mixed with the plastics recycling stream. The recycler will expect that the material it receives is not contaminated, so be prepared to discuss measures that you will implement to keep recyclable materials from being contaminated. This should include a description of your hospital’s employee and departmental commitments, training programs, collection procedures, and the QA/QC steps you take to ensure that hazardous materials are not present in in the recycling stream.

From the MRF/ recycler perspective, nonconforming materials usually means hazardous materials and sharps, as well as unacceptable types of plastic, solid waste, and/or other unacceptable materials which may be accidentally mixed in with the plastics recycling stream.

How will they manage nonconforming materials?

Review your recycling partner’s emergency management plan and determine how nonconforming materials will be managed. Discuss the safety issues and control measures in use at their facilities. Establish a process for performing a root cause analysis in the event non-conforming materials are found in the recyclable stream, including corrective measures which will be put in place to prevent recurrence.

What is the final disposition of the plastics?

There might be further downstream processors, and you want to understand the full chain and determine if this information impacts the materials you intend to recycle.

What kind of data will your recycling partner collect and report?

Make sure you are on the same page regarding data and reporting capabilities and expectations.

What type of EHS management system do they have?

Do they have any EHS management system certifications? Can the MRF/ recycler provide you with a statement or certificate that its operations are in compliance with all applicable federal, state, and local regulations? Consider reviewing EHS permits, certifications, registrations, etc.

Where will materials will be recycled?

Will they be handled locally, domestically, or internationally? Which industries and products might the recycled materials ultimately be re-utilized in?

What resources are available for training and education?

Does the recycling partner have staffing or educational materials available to help successfully implement the program?

May there be changes to the recycling program?

Recycling is driven by economics; as economics change, some items may become more or less valuable to recyclers. Establish an understanding of whether the recycler can require a change in acceptable items, at what interval, and what type of resources may be provided to the hospital to institute the change.

Consider establishing a signed contract.

Get everything in writing, including agreement conditions, service deliverables, and legal commitments to cover any liability if improper practices occur.

Invite partner representatives to tour the hospital.

This will help them to understand your recycling operations and the process by which you will collect, sort and ship approved materials.

Spent fluorescent lamps should be recycled by taking them to a household hazardous waste collection event or by shipping to a mercury recycler. If these services are not available, spent fluorescent lamps may be put out with regular household trash. EPA recommends sealing used or broken CFLs in a plastic bag. Hazardous waste from a household is exempt from hazardous waste regulation in Pennsylvania and most other states. For more information, see Fluorescent Lamp Recycling.

The management standards for small and large quantity handlers of universal waste aerosol cans were added in 40 CFR 273.13(e) and 273.33(e), respectively. Universal waste aerosol cans must be managed in a way that prevents releases to the environment. This includes accumulation in a structurally sound container, treatment of damaged cans as described in 273.13(e)(2) and 273.33(e)(2), sorting/mixing intact cans, removing actuators or puncturing/draining.

Handlers that puncture aerosol cans must follow a developed written procedure detailing how to safely puncture and drain aerosol cans. Emptied universal waste aerosol cans must be recycled and handlers must immediately transfer the contents from the emptied aerosol cans to a container or tank meeting the applicable requirements of 40 CFR 262.14, 15, 16, or 17. Hazardous waste generated from puncturing the cans is subject to all applicable RCRA regulations, and the handler is considered the generator of the hazardous waste. Generators of hazardous waste must make hazardous waste determinations. Nonhazardous waste is subject to all applicable federal, state and local solid waste regulations.

The Federal Solvent-Contaminated Wipes Final Rule became effective on January 31, , and Pennsylvania incorporates this by reference at 25 Pa. Code § 260a.3(e). A wipe is defined at 40 CFR § 260.10 as a woven or non-woven shop towel, rag, pad or swab made of wood pulp, fabric, cotton, polyester blends or other material. Solvent-contaminated wipes are wipes that after use or after cleaning up a spill contain one or more F001-F005 solvent, exhibits a hazardous characteristic from a listed solvent or exhibits the hazardous characteristic of ignitability due to one or more non-listed solvents.

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Solvent-contaminated wipes that are being sent for disposal, except for those containing trichloroethylene, are conditionally exempt from the classification of hazardous waste 40 CFR 261.4(b)(18). Also, solvent-contaminated wipes that are sent for cleaning and reuse are conditionally exempt from the classification of solid waste 40 CFR 261.4(a)(26).

The final rule can be found under 40 CFR Part 266 Subpart P, which Pennsylvania incorporates by reference under 25 Pa. Code § 260a.3. The rule became effective on August 21, .

Under the final rule, health care facilities and reverse distributors that generate and manage hazardous waste pharmaceuticals must follow these sector-specific standards for managing hazardous waste pharmaceuticals, instead of the industry-oriented hazardous waste generator regulations. Additionally, health care facilities and reverse distributors that generate or manage FDA-approved over-the-counter nicotine replacement therapy waste (i.e., patches, gum and lozenges) are no longer subject to the P075 listing for nicotine under this final rule.

(Note: The Final Rule includes a prohibition on sewering hazardous waste pharmaceuticals that applies to all reverse distributors and all healthcare facilities, including VSQGs.)

Please refer to EPA's webpage titled "Management Standards for Hazardous Waste Pharmaceuticals and Amendment to the P075 Listing for Nicotine", which includes an informative webinar, for further information and resources in managing hazardous waste pharmaceuticals.

Pennsylvania no longer issues temporary “PADEP” EPA ID numbers. Facilities that normally do not generate hazardous waste but are currently generating hazardous waste as a result of a one-time, non-recurring, temporary event that is not related to normal production processes, should notify as a short-term generator utilizing the EPA Site Identification Form (-12) (see Item 10.A.2. on the form) to obtain an EPA ID number.

Short-term generators produce hazardous waste from a particular activity for a limited time and then cease conducting that activity. Examples of short-term generators include:

1. one-time highway bridge waste generation;
2. underground storage tank removals;
3. generation of off-specification or out-of-date chemicals at a site that normally doesn’t generate hazardous waste;
4. remediation or spill clean-up at sites with no previous EPA ID number; and
5. site or production process decommissions by a new operator.

Short-term generator EPA Id numbers should remain active for no longer than 180 days. If more than 180 days is anticipated to complete the one-time event, the site is not eligible for a short-term generator EPA Id number and the generator should submit an EPA Site Identification Form (-12) as a hazardous waste generator (LQG, SQG or VSQG).

Once the short-term activity is complete, the EPA Site Identification Form (-12) should be completed and notification made that regulated activity is no longer occurring at the site so that the number can be deactivated. Otherwise, the EPA ID number will remain active for the site.

Episodic generators are not short-term generators because episodic generators (i.e., SQGs and VSQGs) regularly generate hazardous waste as a part of normal operations but elevate to a higher generator category as a result of a planned or unplanned event.

Pennsylvania's hazardous waste management regulations allow for "episodic" generation events. Episodic event means an activity, either planned or unplanned, that does not normally occur during routine operations, resulting in an increase in the generation of hazardous wastes that exceeds the calendar month quantity limits. VSQGs and SQGs may maintain their existing generator category for hazardous waste generated during an episodic event provided certain conditions are met 40 CFR 262.232.

Generators must have or obtain an EPA ID number to take advantage of the episodic generator provision via submittal of the EPA Form -12 notification form. Generators are limited to claiming one episodic event per calendar year, unless a petition to manage one additional episodic event is granted by DEP under 40 CFR 262.233. A generator who has already held a planned episodic event may petition for an additional unplanned episodic event. Likewise, a generator who has already held an unplanned episodic event may petition for an additional planned episodic event.

Note: Episodic generation does not apply to “short-term generators.”

For a planned episodic event, a generator must notify the DEP thirty at least (30) calendar days prior to initiating the event using the EPA Form -12. For an unplanned episodic event, the generator must notify DEP within 72 hours of the event via , or fax and subsequently submit EPA Form -12.

Notification of episodic generation events that are not completed correctly may be subject to enforcement action by the Department. Examples may include improper advance notice of an episodic event or a second episodic event notification within a calendar year. Please verify your dates.

Note: The Department does not provide an approval for episodic generation events.

A VSQG or SQG that generates more than their established category amount as part of an episodic event does not become a large quantity generator and does not need to complete a Biennial Report. The episodic generator provision allows a VSQG or an SQG to generate additional quantities of hazardous waste — temporarily exceeding its normal generator category limits — and still maintain its existing generator category, provided the generator complies with the specified conditions.

No, EPA ID numbers are site (location) specific. When a facility relocates, they should notify DEP (via EPA Form -12) so the old number can be inactivated. If the facility moves to a location that has an existing identification number, the regulations require the facility to notify the DEP (via EPA Form -12) so the existing number can be reactivated. If the new location does not have an EPA ID number, the facility must obtain an EPA ID number for the new location. Very small quantity generators (VSQGs) are not required to notify.

The regulations do not specifically prohibit that from happening. It is generally not advantageous for a person or facility to be responsible for the hazardous waste someone else generates at that location. In this case, the facility should differentiate the address for the leased (or sold) space from the rest of the facility, and a different ID number obtained for the leased portion of the facility.

Yes, more than one waste may be accumulated at a satellite location. A total of 55-gallons consisting of non-acute hazardous waste and/or one quart of liquid acute or one kg (2.2 lbs.) of solid acute hazardous waste may be accumulated at a satellite location, but not 55-gallons of each waste. In no instance may more than 55-gallons be accumulated at a satellite location. For example, if three wastes are accumulated at a location, the total volume of the three wastes accumulated at the satellite location cannot exceed 55-gallons.

The term "permit-by-rule" refers to the mechanism whereby the owners or operators of certain types of facilities, which are required to have a permit from the DEP, are deemed to have a permit without proceeding through the entire permitting process. In general, permit-by-rule facilities pose little or no threat to public health or the environment. Treatment of hazardous waste is permitted for wastes generated and treated on-site. Qualification for and retention of permit-by-rule status is contingent upon the operator's compliance with the applicable provisions of the regulations. The DEP may require the owner or operator of a permit-by-rule facility to obtain a written permit when the facility is not in compliance with the applicable provisions of the regulations or is engaged in an activity that harms or presents a threat of harm to public health or the environment.

Generally, treatments that can be performed where the generator accumulation units are being managed in compliance with the applicable hazardous waste generator regulations are acceptable and may be performed under this permit-by-rule. Other types of treatment for which specific standards have otherwise been developed (i.e. thermal treatment, incineration, etc.) are not eligible to be performed in generator accumulation units. Permit-by-rule treatment must be performed within the applicable generator accumulation period (generally 90 or 180 days after the waste has been generated).

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