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Regulations: Hospitals and Healthcare Systems

Definitions

The terms “hazardous waste” and “hazardous material” refer to items that meet certain criteria under the federal Resource Conservation and Recovery Act (RCRA) and associated regulations. It is important to understand the difference between hazardous waste and hazardous material:

  • Hazardous Materials
    Generally applies to certain raw materials or products, purchased from outside suppliers, that are stored and used at your facility.
  • Hazardous Wastes
    Defined as materials that are discarded and meet one of the following criteria: 1) the waste is listed by EPA due to its toxic nature, or 2) the waste meets one of four characteristics: it is reactive, ignitable, corrosive, or toxic. These wastes may be generated from processes carried out at your facility.

Some common hazardous materials in healthcare facilities that may be hazardous waste when disposed of include:

  • cleaning chemicals
  • laboratory chemicals
  • mercury
  • pesticides
  • pharmaceuticals
  • radiologicals
  • sterilants and disinfectants

Facilities that generate hazardous wastes are subject to detailed rules concerning:

  • How the Wastes Must be Stored on Site
  • How Long the Waste May Be Stored,
  • Who is Allowed to Transport and Receive Hazardous Waste
  • The Kinds of Records that must be Maintained at the Facility

For more information on managing hazardous waste, the U.S. Environmental Protection Agency has prepared, Managing Your Hazardous Waste: A Guide for Small Businesses, a useful guide to help you understand and comply with the hazardous waste rules.

DEQ‘s Division of Waste Management and Radiation Control (DWMRC) is responsible for implementing RCRA requirements in Utah. For more information on RCRA requirements, visit the DWMRC’s Website.

Universal Waste

The Universal Waste Rule was written by the U.S. Environmental Protection Agency (EPA) to streamline environmental regulations for wastes generated by large numbers of businesses in relatively small quantities. It is designed to reduce the amount of hazardous waste in municipal solid waste, encourage the recycling and proper disposal of certain common hazardous wastes, and reduce the regulatory burden for businesses that generate these wastes.

Some common items (batteries, thermostats, lamps, and pesticides) may be exempt from the hazardous waste rules. See EPA’s guide Managing Your Hazardous Waste A Guide for Small Businesses for more information.

Regulated Medical Waste

To protect human health and the environment, the Infectious Waste Requirements (Utah Administrative Code Rule R315-316 of the Utah Solid Waste Permitting and Management Rules) became effective on July 15, 1993. These requirements are applicable to infectious waste after the waste has been removed from the healthcare facility and is stored, transported, or disposed. DEQ’s Division of Waste Management and Radiation Control has prepared guidance on how to manage infectious waste in Utah, including the definition of “infectious waste” for the State of Utah.

Mercury Resources

Mercury can be found in many healthcare devices, including fever thermometers, blood pressure cuffs, and esophageal dilators. Mercury is also found in many chemicals and measurement devices used in health care laboratories. If these products are spilled, broken or disposed of improperly, there is a potential for significant harm to human health and the environment.

By federal law, mercury is a regulated waste; as a result, its management can be quite expensive. By using non-mercury alternatives, healthcare facilities can avoid the risk of mercury management altogether. Mercury-containing wastes must be managed and disposed of as a hazardous waste if they meet the toxicity characteristics for mercury. Mercury-containing batteries, thermostats, and lamps may be managed under the Universal Waste Program (see Universal Waste section above).

For information on mercury spill clean-up and notification requirements, DEQ has prepared Get the Mercury Out! a useful pamphlet that provides step-by-step instructions.

Air Pollution

Many hospitals operate industrial boilers, which can generate criteria pollutants, such as nitrogen oxides (NOx), sulfur dioxide (SO2), particulate (dust), and hazardous air pollutants (HAPs). Most hospital boilers are subject to the federal New Source Performance Standards (NSPS) regulations, part of the federal Clean Air Act (CAA). Depending on the type of fuel combusted, the NSPS regulations have emission standards for sulfur dioxide, nitrogen oxides, and particulate matter.

The Utah Division of Air Quality (DAQ) is responsible for implementing the federal CAA by enforcing rules specifying that boilers and incinerators are operated under a permit by DAQ. In addition, DAQ oversees whether asbestos-containing materials and refrigerants are properly managed.

Wastewater

Water regulations establish different permitting programs for direct and indirect wastewater discharges.

  • “Direct discharge” refers to wastewater discharged directly into a stream or other receiving body. Direct discharges are regulated under the National Pollutant Discharge Elimination System (NPDES) program.
  • “Indirect discharge” refers to wastewater that is sent to a sanitary sewer. Indirect discharges are subject to regulations by the local sewer authority.

Most hospitals are indirect dischargers.

A permit, issued by the Publicly Owned Treatment Works (POTW), is needed to discharge into municipal sanitary sewers if the hospital or clinic meets one of the following requirements:

  • Is a categorical industrial user,
  • Has the potential to cause harm to the POTW,
  • Has a load to the POTW that is greater than 5% of the POTW’s designed load, or
  • Has a flow greater than 25,000 gallons a day (g/day).

A permit can only be issued if the POTW has an approved pretreatment program. For more information, contact the Utah Division of Water Quality.

Instead of disposing mercury and pharmaceuticals to the municipal sanitary sewer, adopt pollution prevention practices which include source reduction, product substitution, and on-site recycling.

X-Ray Radiation

Medical x-rays account for the majority of the average citizen’s exposure to man-made radiation. The Division of Waste Management and Radiation Control (DWMRC) is responsible for overseeing registration and inspection of x-ray units to protect the public and environment from significant sources of radiation.

State law requires that all x-ray tubes in the state be registered every year with the Division by July 1, if they are attached to a control unit. Registration forms are sent to all registrants on file each year. Even x-ray units in storage must be registered if they are not in a retail sales facility. The rules also require the Division to be notified within 14 days of the acquisition, transfer or disposal of an x-ray system. For more information on x-ray unit requirements, visit the DWMRC’s Website.

Questions?

Eleanor Divver, Business Assistance Coordinator: (801) 536-0091