Hazardous waste disposal and the clinical laboratory

Negligent, unregulated hazardous waste management has resulted in real and potential threats to public health and safety. The federal government has responded with laws and regulations aimed at the producers of hazardous waste, including clinical laboratories. Clinical laboratory managers must understand how the requirements apply to their facilities and how to comply with them, or risk violating the law. The Resources Conservation and Recovery Act (RCRA) imposes controls on hazardous waste management through the Code of Federal Regulations (CFR). The Environmental Protection Agency (EPA) and the Department of Transportation (DOT) regulate these activities through 40 CFR and 49 CFR, respectively. 49 CFR specifies the characteristics of hazardous waste and lists more than 400 toxic chemicals, including several commonly used in clinical laboratories. Laboratories must conduct chemical inventories to determine if they should obtain an EPA identification number as a hazardous waste generator. Most clinical laboratories can operate satellite accumulation points and accumulate, store, transport, and dispose of waste in accordance with EPA and DOT regulations. Regulations pertaining to infectious waste, sure to affect many clinical laboratories, are being developed now by the EPA. The tracking system mandated by the federal government can be supplemented by state and local authorities and poses a significant regulatory challenge to clinical laboratory managers.