Notice

This guide has been subjected to U.S. Environmental protection Agency's peer and administrative review, and approved for publication. Approval does not signify that the contents necessarily reflect the views and policies of the U.S. Environmental protection Agency, nor does mention of trade names or commercial products constitute endorsement or recommendation for use. This document is intended as advisory guidance only to hospitals in developing approaches for pollution prevention. Compliance with environmental and occupational safety and health laws is the responsibility of each individual medical institution and is not the focus of this document

Worksheets are provided for conducting waste minimization assessments of hospital facilities. Users are encouraged to duplicate portions of this publication as needed to implement a waste minimization program.

Foreword

This guide provides an overview of hospital waste generating processes and presents options for minimizing waste generation through source reduction and recycling. Reducing the generation of these materials at the source, or recycling the wastes on or off site, will benefit hospitals by reducing disposal costs and lowering the liabilities associated with hazardous waste disposal.

The hazardous wastes generated by general medical and surgical hospitals are small in volume relative to those of industrial facilities; however, the wastes are of a wide variety. Some of the hazardous materials used by hospitals that become part of their waste streams include chemotherapy and antineoplastic chemicals; solvents; formaldehyde; photographic chemicals; radionuclides; mercury; waste anesthetic gases; and other toxic, corrosive and miscellaneous chemicals. Additional wastes such as infectious waste, incinerator exhaust, laundry-related waste, utility wastes, and trash are not addressed in this guide.

Acknowledgments 

This guide is based in part on waste minimization assessments conducted by Ecological and Environment, Inc. For the California Department of Health Services (DHS). Contributors to these assessments include: Benjamin Fries, and Eric Workman of the Alternative Technology Section of DHS. Jacobs Engineering Group Inc. edited and developed this version of the waste minimization assessment guide, under subcontract to Radian Corporation (USEPA Contract 68-02-4286).

Jacobs personnel contributing to this guide include: Carl Fromm, project manager; Michael Callahan, Sally Lawrence, and Andrew Nelson, project group members.

Lisa M. Brown of the U.S. Environmental Protection Agency, Office of Research and Development, Risk Reduction Engineering Laboratory, was the project officer responsible for the preparation and review of this guide. Other contributors and reviewers include: Mark Ellefson, Health and Safety, University of Washington; M.C. Hull, Chemical Safety Officer, Research and Occupational Safety, University of California- Los Angeles; and Michael Todd, Assistant Manager of Engineering, Huntington Memorial Hospital, Pasadena. Information about waste anesthesia gases, ethylene oxide, and mercury recyclers was provided by ECRI, publisher of Hospital Hazaraous Materials Management ^(TM).

This guide was prepared to provide general medical and surgical hospitals with guidelines and options to minimize hazardous waste in selected waste streams. However, the waste minimization assessment approach described here can be used in efforts to minimize all wastes generated at a facility. The guide is intended primarily for use by hospitals, particularly administrators and environmental compliance personnel. Others who may find this document useful are regulatory agency representatives, hospital service organizations, and consulting firms.

The worksheets and the waste minimization options were developed through assessments of three San Francisco Bay Area hospitals commissioned by the California Department of Health Services (Calif. DHS 1988). The hospitals' operations and waste generation and management practices were surveyed and their existing and potential hazardous waste minimization options characterized for the following selected waste streams: 

• solvents

• chemotherapy wastes

• photographic chemicals

• formaldehyde wastes

• radioactive wastes

• mercury

• other toxics and corrosives

The scope of the assessments did not include infectious waste, incinerator exhaust, laundry-related waste, utility wastes, and trash. Information about waste anesthetic gases has been added for this EPA guide.

Waste minimization is a policy specifically mandated by the U.S. Congress in the 1984 Hazardous and Solid wastes Amendments to the Resource Conservation and Recovery Act (RCRA). As the federal agency responsible for implementing RCRA, the U.S. Environmental Protection Agency (EPA) hasan interestin ensuring that new methods and approaches are developed for minimizing hazardous waste and that such information ir made avallable to the institutions concerned. This guide is one of the approaches EPA ir using to provide institution-specific information about hazardous waste minimization. The options and procedures outlined can also be used in efforts to minimize other wastes generated.

EPA has also developed a general manual for waste minimization. The Waste Minimization Opportunity Assessment Manual (USEPA 1988) tells how to conduct a waste minimization assessment and develop options for reducing hazardous waste generation. It explains the management strategies needed to incorporate waste minimization into institutional policies and structure, how to establish a facility-wide waste minimization program, conduct assessments, implement options, and make the program an on-going one. The elements of a waste minimization assessment are explained in the Overview, below.

In the following sections of this manual you will find:

• An overview of general medical and surgical hospitals and the hazardous chemicals they employ (Section Two);

• Waste minimization options for hospitals (Section Three);

• Waste Minimization Assessment Guidelines and Worksheets (Section Four)

• An Appendix, containing:

• Case studies of waste generation and waste minimization practices of the three hospitals studied; and

• Where to get help: Sources of useful technical and regulatory information.

In the working definition used by EPA, waste minimization consists of source reduction and recycling. Of the two approaches, source reduction is usually considered preferable to recycling from an environmental perspective.

A Waste Minimization Opportunity Assessment (WMOA), sometimes called a waste minimization audit, is a systematic procedure for identifying ways to reduce or eliminate waste. The steps involved in conducting a waste minimization assessment are outlined in Figure 1 and presented in more detail in the next paragraphs. Briefly, the assessment consists of a careful review of an institution's operations and waste streams and the selection of specific areas to assess. After a particular waste stream or area is established as the WMOA focus, a number of options with the potential to minimize waste are developed and screened. The technical and economic feasibility of the selected options are then evaluated. Finally, the most promising options are selected for implementation.

To determine whether a WMOA would be useful in your circumstances, you should first read this section describing the aims and essentials of the WMOA process. For more detailed information on conducting a WMOA, consult the Waste Minimization Opportunity Assessment Manual.

Assessment process

The four phases of a waste minimization assessment, described briefly below, are:

• Planning and organization

• Assessment phase

• Feasibility analysis phase

• Implementation

Planning and Organization

Essential elements of planning and organization for a waste minimization program are: getting management commitment for the program; setting waste minimization goals; and organizing an assessment program task force. The importance of getting management support for waste minimization cannot be overstated.

Assessment Phase

• The assessment phase involves a number of steps:

• Collect process and facility data

• Prioritize and select assessment targets

• Select assessment team

• Review data and inspect site

• Generate options

• Screen and select options for feasibility study

Collect process and facility data. The waste streams at the facility should be identified and characterized. Information about waste streams may be available on hazardous waste manifests, lab pack packing lists, National Pollutant Discharge Elimination System (NPDES) reports, routine sampling programs and other sources.

Developing a basic understanding of the activities that generate waste at a hospital facility is essential to the WMOA process. Flow diagrams should be prepared to identify the quantity, types and rates of waste generating activities. Also, preparing material balances for various processes can be useful in tracking various process components and identifying losses that may have been unaccounted for previously. This may be especially useful when attempting to differentiate between infectious and hazardous wastes.

Prioritize and select assessment targets. Ideally, all waste streams in a facility should be evaluated for potential waste minimization opportunities. However, with limited resources, a hospital administrator may need to concentrate waste minimization efforts in a specific area. Such considerations as quantity of waste, hazardous properties of the waste, regulations, safety of employees, economics, and other characteristics need to be evaluated in selecting a target stream.

Select assessment team. The team should include people with direct responsibility for and knowledge of the waste streams or activities that generate the wastes. Use of consultants should be considered when no internal expertise is available.

Review data and inspect site. The assessment team evaluates activity data inadvance of the site inspection. The inspection should follow the target activities from the point where raw materials enter the facility to the points where wastes leave. The team should identify the suspected and known sources of waste. For hazardous waste this may include laboratories, pharmacies, pathology, radiology, surgery, dialysis, embalming, nursing units, nuclear medicine, mercury from broken or obsolete equipment, "red bag" (infectious) wastes; maintenance operations; and storage areas for raw materials and wastes. The inspection may result in the formation of preliminary conclusions about waste minimization opportunities. Full confirmation of these conclusions may require additional data collection or analysis.

Generate options. The objective of this step is to generate a comprehensive set of waste minimization options for further consideration. Since technical and economic concerns will be considered in tile later feasibility step, No options should be ruled out at this stage. Information from the site inspection, as well as medical associations, government agencies, technical and medical reports, equipment vendors, consultants, and facility engineers and technicians may serve as sources of ideas for waste minimization options.

Both source reduction and recycling options should be considered. Source reduction approaches include:

• Good operating practices

• Eliminating or reducing use of carcinogenic chemicals such as benzene and chloroform

• Increased use of analytical instrumentation -this can decrease the use of chemicals

• Improved inventory control utilizing computerized tracking and inventory systems, also use of central purchasing

• Elimination of use of oil based paints in maintenance

Recycling includes:

• Use and reuse of waste

• Reclamation

Screen and select options for further study. This screening process is intended to select the most promising options for full technical and economic feasibility study. Through either an informal review or a quantitative decision-making process, options that appear marginal, impractical or inferior are eliminated from consideration.

Feasibility Analysis

An option must be shown to be technically and economically feasible in order to merit serious consideration for adoption. A technical evaluation determines whether a proposed option will work in a specific application. Both operational and equipment changes need to be assessed for their overall effects on waste quantity. Also, any new products or raw materials need to be tested for efficacy.

An economic evaluation is carried out using standard measures of profitability, such as payback period, return on investment, and net present value. As in any project, the cost elements of a waste minimization project can be broken down into capital costs and operating costs. Savings and changes in revenue need also to be considered.

Implementation

An option that passes both technical and economic feasibility reviews should then be implemented. It is then up to the WMOA team, with management support, to continue the process of tracking wastes and identifying future opportunities for waste minimization throughout a facility by way of period reassessments. Both the ongoing reassessments and an initial investigation of waste minimization opportunities can be conducted using this guide.

Hospital hazardous waste is unique in several ways. There is a large variety of wastes but the volumes are small relative to industrial facilities. Hospitals employ toxic chemicals and hazardous materials for numerous diagnostic and treatment purposes. The hazardous materials include:

• Chemotherapy and antineoplastic chemicals

• Formaldehyde

• Photographic chemicals

• Radionuclides

• Solvents

• Mercury

• Waste anesthetic gases

• Other toxic, corrosive, and miscellaneous chemicals

Based on audits of three hospitals conducted for this study, chemotherapy wastes, including concentrated antineoplastic chemicals mixed with other inert materials, represented the highest volume of hazardous waste at each hospital. This was followed by spent photographic chemicals and formaldehyde solutions used for disinfecting equipment. Other significant and potentially significant sources of hazardous wastes noted were solvents, radioactive wastes, mercury, waste anesthetic gases and other toxic and corrosives. The scope of the assessments did not include infectious waste, incinerator exhaust, laundry-related waste, utility waste and trash.

Procurement of antineoplastic, or cytotoxic, agents that are used to produce chemotherapy solutions is generally conducted through a central clinic or pharmacy. Quantities kept on hand at the hospitals audited were generally sufficient to last less than two weeks. Chemicals are mixed or compounded within a hood, which recirculates air through a filter. Chemotherapy wastes account for the largest volume of hazardous wastes produced by surveyed hospitals. Only a small percentage of these wastes contain concentrated amounts of chemotherapy compounds. Much of the waste volume is associated with lightly contaminated items such as personal protective clothing and gauze pads. Sharp items such as needles ("sharps") are also discarded, but may be separated and handled as infectious waste.

Waste materials are placed into plastic bags or plastic containers that are either replaced daily, or when they are full. An average of 2 to 8 cubic feet of chemotherapy wastes per week were generated by the hospitals surveyed. These wastes are either transported off-site to a Class 1 landfill or incinerated as infectious waste. However, it should be noted that the latter may not be an acceptable alternative under some state hazardous waste regulations. Landfilling of hazardous wastes is discouraged or prohibited in many areas of the country and should not generally be considered a viable disposal option for hospital hazardous wastes.

FORMALDEHYDE

Formaldehyde is used in pathology, autopsy, dialysis, embalming, and nursing units. Occupational exposure to airbone concentrations of formaldehyde is regulated by OSHA. New regulations limit the permissible exposure to 1.0 ppm as an 8-hour time weighted average (TWA), with an action level of 0.5 ppm (ECRI, Jan, 1988).

Formaldehyde also represents a significant source of hazardous waste at many hospitals. For use in dialysis, formaldehyde is generally purchased as a 37 percent formaldehyde-in-water solution (formalin). It is subsequently diluted with filtered, deionized water to achieve a final formaldehyde concentration of 2-4 percent. The formalin is either pumped or poured into dialysis machines to disinfect the membranes and the effluent is discharged to the sewer. In other departments, formaldehyde is generally used to preserve specimens with small quantities of waste generated and discharged to the sewer. Discharging a hazardous material to the sewer may be illegal and is generally an undesirable management practice, even if sanitation authorities allow such disposal.

PHOTOGRAPHIC CHEMICALS

Full-service hospitals generally have a radiology department. The photographic developing solutions used in X-ray departments consist of two parts, a fixer and a developer. The fixer normally contains 5-10 percent hydroquinone, 1-5 percent potassium hydroxide, and less than 1 percent silver. The developer contains approximately 45 percent glutaraldehyde. Acetic acid is a component of stop baths and fixer solutions. These two chemical solutions usually are obtained in 30- or 55-gallon drums. The contents are routed from these drums directly to the developing machine.

Silver-containing effluent from the fixer solution is passed through a steel wool filter or otherwise treated to recover this precious metal. The remaining aqueous waste, containing approximately 1.4 percent glutaraldehyde, 0.3 percent hydroquinone, and 0.2 percent potassium hydroxide, is typically discharged to the sewer. Some hospitals utilize X-ray services that also provide silver recovery as part of the package.

RADIONUCLIDES

Radioactive wastes are generated in nuclear medicine and clinical testing laboratory departments. At the hospitals surveyed, radioactive materials in nuclear medicine were retained on site until they decayed to nonhazardous levels. In clinical testing laboratories, solvents are also used for radioactive tagging. Wastes at the audited hospitals are generated at a rat of about 800 cubic centimeters per week. The radioactive wastes are transported off site for land disposal.

SOLVENTS

Solvent wastes are typically generated in various departments throughout a hospital. These include pathology, histology, engineering, embalming, and laboratories. Volumes of solvent wastes generated at the hospitals surveyed were small. Specific solvents used in medical settings include halogenated compounds such as methylenechloride, chloroform, freons, trichloroethylene, and 1,1,1-trichloromethane. Other solvents include nonhalogenated compounds such as xylene, acetone, ethanol, isopropanol, methanol, toluene, ethyl acetate, and acetonitrile. Xylene, methanol, and acetone were the most frequently used solvents at the audited hospitals.

Xylene and ethanol are used in histology and cytology laboratories of hospital anatomic pathology departments. In tissue processing, ethanol dehydrates and xylene clears tissue prior to paraffin infiltration and embedding. Then xylene is used to remove paraffin and ethanol to hydrate sections before staining. Ethanol and xylene are again used to dehydrate and clear sections before the cover slip is applied to the microscope slide preparation (L. McGlothlin, histology supervisor at UC Davis, cited in Roark 1989). 

While acetone and methanol waste are usually evaporated or discharged to the sewer, the xylene wastes are normally handled as hazardous materials. Some of these wastes are absorbed in specimens which are then treated instead as infectious wastes. Solvent wastes are typically stored in 30- or 55-gallon drums and are either recycled or transported off site for incineration. In the past, small quantities of solvent wastes were routinely disposed of via lab packs to landfills. This alternative is becoming increasingly less desirable due to higher disposal costs, long-term liability, and limitations introduced by new, more stringent regulations.

MERCURY

The primary sources of mercury waste at most hospitals include broken or obsolete equipment. Mercury wastes are decreasing in quantity due to the substitution of solid state electronic sensing instruments (thermometers, blood pressure gauges, etc.) for those containing mercury.

Mercury from broken equipment is recovered and reused (if uncontaminated). Mercury losses due to spillage may not be frequently recovered; no mercury spill kits were present in any of the three surveyed hospitals.

ANESTHETIC GASES

Nitrous oxide and the halogenated agents halothane (Fluothane), enflurane (Ethrane), isoflurane (Forane), and other substances are used as inhalation anesthetics. Exposure of health care personnel to these substances may result in acute toxic effects and, possibly, reproductive disorders and carcinogenesis (ECRI Feb. 1988).

Nitrous oxide is supplied as a gas in cartridges or cylinders that are attached directly to the anesthetic administering equipment. Used containers are returned to the supplier. The halogenated anesthetic agents are supplied in liquid form, in glass bottles. Once empty, the bottles are handled as hazardous waste.

Waste anesthetic gases are generally removed from the operating room, or the site of application, in one of two ways. At some of the larger hospitals, a scavenging unit is attached to the anesthesia unit to remove the waste gases. The scavenging unit may have a charcoal filter which would adsorb halogenated anesthetic gases but not nitrous oxide. Spent charcoal filters are sent off site as hazardous waste. If there is no scavenging unit, or if the scavenging unit does not have a filter, then vacuum lines are used to collect waste anesthetic gases and vent them to the outside.

TOXICS, CORROSIVES, AND MISCELLANEOUS CHEMICALS

Poisons, oxidizers, and caustics are used throughout most hospitals, generally in small quantities. Waste oils and solvents from maintenance may also be considered hazardous wastes as may some boiler water conditioning chemicals. Although many of these types of wastes are considered hazardous materials, only ethylene oxide was used at the surveyed hospitals in large quantities. All of the audited hospitals currently discharge this gas to the atmosphere but may soon be required to treat it. Many facilities in California are already required to "scrub" these emissions.

Listed below are some major toxic, corrosive, and miscellaneous chemical wastes and their sources of origin:

Ethylene oxide (EtO), used to sterilize medical devices, is used in central supply areas, respiratory therapy, and at times, in operating rooms. This colorless and odorless gas can cause a number of acute toxic reactions and is a probable human carcinogen (ECRI Jan. 1989).

Ethylene oxide is purchased in cartridges or cylinders that can be attached directly to specially designed sterilized. Equipment that has been sterilized in a EtO sterilizer is transferred to an EtO aeration chamber. Both EtO sterilizers and aerators are connected to ventilation systems which duct the exhaust to the outside. Used ethylene oxide cylinders are returned to the supplier. Some hospitals are going to bulk storage of ethylene oxide, using large tanks.

A large variety of hazardous materials is used in hospitals; however, overall waste quantities generated are relatively low. Tracking of hazardous wastes in hospitals is often complicated by a lack of available records on waste generation. This results from hazardous wastes being mixed with infectious wastes and from disposal of potentially hazardous wastes into the sewer.

The Medical Waste Tracking Act is a demonstration program (participants are New York, New Jersey, Connecticut, Rhode Island, Louisiana, and the District of Columbia) that will require generators of more than 50 pounds of waste monthly to use a four-copy manifest tracking system. Included in "medical waste", for the purposes of the Act, will be cultures and stocks of infectious agents and associated biologicals; pathological waste; human blood and blood products; used sharps; contaminated animal carcasses; surgery or autopsy waste; laboratory wastes; dialysis wastes; discarded medical equipment; and isolation wastes.

MWTA is expected to lead eventually to a broader tracking program that will affect all states. It may also provide impetus to hospitals to incinerate many types of waste on site. With this possibility in view, EPA expects to establish medical waste incineration regulations under the Clean Air Act (Roy 1989).

Although recently awareness has increased regarding the need for proper disposal of medical waste, there has been a misconception at some hospitals regarding the need to apply proper hazardous waste disposal practices for wastes containing both infectious and hazardous components. By current law, any waste mixture of nonhazardous and hazardous or infectious and hazardous wastes must be handled as a hazardous waste. Many items that are routinely handled as infectious waste (gauze pads, gowns, etc. that are contaminated with hazardous waste) should be handled as hazardous waste. The lack of manifesting requirements for infectious wastes makes accurate determinations of hazardous components in these waste streams even more difficult. The generation and disposal of infectious wastes were excluded from the scope of the assessments.

SEWER USE AND PRETREATMENT

The diluted nature and/or low volume of certain hazardous liquid wastes has resulted in some hospitals obtaining permission from the local sanitary district to discharge these solutions to the sewer. For instance, formaldehyde solutions from dialysis and pathology departments are routinely discharged to the sewer. Wastes from these departments contain between 4 and 10 percent formaldehyde, respectively. Permission by the sanitary districts to discharge these wastes to the sewer is normally granted only for non-bioaccumulative wastes.

This section discusses recommended waste minimization methods for general medical and surgical hospitals. These methods were identified through waste minimization assessments of hospitals and through reference to technical literature. Hospitals' primary waste streams are listed in Table 1 along with recommended control methods. Infectious wastes, incinerator exhaust, laundry-related waste, utility wastes and trash are not addressed. The control methods can be classified generally as source reduction methods which can be achieved through material substitution, process or equipment modification, or better operating practices; or as recycling. Treatment of hazardous waste is not the focus of this guide.

The waste minimization options are presented for specific waste streams, following a discussion of better operating practices that can be used in overall hospital waste management.

Better operating practices are procedures and institutional policies that result in a reduction of waste. Improved management oversight, tracking, and inventory control can effectively reduce waste generation. Computerized data base tracking systems provide a very effective and efficient method of tracking and inventory control.

Key overall operating strategies include:

• Keep individual waste streams segregated.

• Keep hazardous waste segregated from nonhazardous waste. All waste contaminated with a hazardous substance becomes hazardous.

• Keep hazardous chemical wastes segregated from infectious wastes.

• Keep recyclable waste segregated from non-recyclable waste.

• Minimize dilution of hazardous waste.

• Assure that the identity of all chemical and wastes is clearly marked on all containers.

Improved management and control practices include:

• Centralize purchasing and dispensing of drugs and other hazardous chemicals.

• Monitor drug and chemical flows within the facility from receipt as raw materials to disposal as hazardous wastes. This may be partially or fully automated by the use of computer systems and computer-readable barcoded labels for incoming chemicals, similar to those used in supermarkets.

• Apportion waste management costs to the departments that generate the wastes.

• Improve inventory control by:

  • Requiring users of chemicals with limited shelf life to use up old stock before ordering or using new stock.

  • Ordering hazardous chemicals only when needed and in minimal quantities to avoid outdated inventory.

• Provide employee training in hazardous materials management and waste minimization. The major generating departments should have a training program for all staff who may generate or handle hazardous materials. Training should include:

  • Chemical hazards.

  • Spill prevention.

  • Preventive maintenance.

  • Emergency preparedness and response, including spill clean-up.

  • Implement an institution-wide waste reduction program.

   

Table 1. Waste Minimization Methods for general Medical and Surgical Hospitals

• Establish an internal recycling program. Package stills are available that are capable of recycling histology and other solvents to reagent grade purity.

Other approaches that will improve hazardous waste management in hospitals include:

• Requiring that all new materials (cleaning compounds, process chemicals, etc.) that may result in hazardous waste generation be tested in small quantities before being purchased in bulk to assure that large quantities of unused materials that do not perform as expected do not need disposal.

• Encouraging drug and chemical suppliers to become responsible partners in a waste minimization program by ordering from suppliers who will provide quick delivery of small orders, will accept return of unopened stock, and are willing to offer off-site waste management outlets or cooperatives for hazardous wastes.

These practices apply to all waste streams. In addition, specific better operating practices that apply to certain waste streams are identified in the appropriate sections that follow.

The toxicity of antineoplastic agents is inherent, because of their efficacy against cancer. The hazards associated with the handling of a given antineoplastic drug are usually of secondary concern compared with its pharmaceutical effectiveness. Because individual responses to drugs in this category vary widely, many different antineoplastics have been marketed.

The greatest volume of antineoplastic wastes is generated from drug dispensing devices, contaminated protective clothing, and associated paraphernalia. At surveyed hospitals, there is significant potential for reducing waste volumes through administrative controls. These include waste segregation, minimizing clean-up waste volume, and employee training. Other methods include:

• Segregate chemotherapy wastes from other wastes. Adherence to this procedure is facilitated through training and by providing separate containers with distinctive labels in chemotherapy drug handling areas.

• Disposable garments may be disposed of with nonhazardous refuse if no chemotherapy agents were spilled during handling. However, gloves should be assumed to be contaminated.

• Minimize the cleaning frequency and volume of gauze material used for the compounding hood.

OSHA has a publication 8-1.1 (January 29, 1986) regarding health and safety when handling antineoplastic drugs. In it, OSHA recommends that hoods be wiped down daily with 70 percent alcohol and be decontaminated weekly with a high-pH (basic) solution. The actual cleaning frequency required depends on drug handling volume and the amount of spillage which occurs in the hood. Proper handling practices should be emphasized to minimize hood cleaning requirements.

• Purchase drug volumes according to need.

Over-purchasing results in the generation of out-of date materials that must be disposed of. Reducing the generation of residual material may be accomplished by computing daily compounding requirements of each drug and ordering appropriately sized containers. In addition, obtain pre-scored ampule containers. This will minimize spillage associated with breaking open unscored ampule necks.

• Employ proper spill containment and cleanup procedures.

Spill containment and clean-up kits should be readily available in the compounding area(s). These kits, usually available from the drug suppliers, should contain both small and large absorbent devices.

• Proper training.

Effective administrative and engineering control requires ongoing employee training and supervision. Surveyed hospitals reported that chemotherapy drug handling training is primarily limited to health and safety. However, employees also need to be trained in methods to minimize generation of chemotherapy wastes.

• Return outdated drugs to the manufacturer.

• Centralize the location of chemotherapy compounding areas.

For use in dialysis, formaldehyde is generally purchased as a 37% formaldehyde-in-water solution (formalin). It is subsequently diluted with filtered, deionized water to achieve a final formaldehyde concentration of 3-4%. The formalin is either pumped or poured into dialysis machines, and the effluent is discharged to the sewer. Ways to minimize this waste include installation of reverse osmosis water supply equipment, using minimium effective cleaning procedures, recycling and reusing waste solutions, and proper waste management.

Since the cleaning of dialysis equipment is the major reason for formaldehyde waste, any measures that help to reduce the need for cleaning will help reduce waste generation. Hospitals reported that use of RO units allows a reduction in the cleaning frequency requirements of dialysis machines. While RO water treatment units also are typically flushed with formalin, they can be cleaned instead with hydrogen peroxide, which is less persistent in the environment.

At the surveyed hospital is, a significant variation was observed in the cleaning frequency of the hemodialysis machines and of the reverse osmosis (RO) water supply equipment. Since waste generation rates are directly related to cleaning frequency and formalin strength, the potential exists for minimizing these wastes by optimizing both variables. There is an apparent need to develop consistent standards for formalin solutions, based upon microbial culture studies. These studies should compare microbial residues with variations in formalin strength, cleaning frequency, and water supply systems.

The diluted formalin waste stream contains approximately 4 percent formaldehyde, 1 percent methanol, and 95 percent water. Surplus or absolute dialysis units could possibly be used to concentrate the formaldehyde for reuse. Dialysis has been used to recover organic material in rayon manufacturing (Sawyer and McCarty 1967). 0ff-spec dialysis membranes could possibly be used to extract and concentrate the formaldehyde wastes for eventual reuse, recycle, or incineration.

Recovery of waste formalin through distillation is also theoretically feasible. However, none of the surveyed hospitals is recycling formaldehyde wastes through distillation. The tendency for formaldehyde to polymerize and form azeotropes with water and methanol may affect recovery efficiencies. Moreover, a high purity extract is required for reuse in dialysis to ensure that there are no pathogenic contaminants in the aqueous fraction. For these reasons, distillation would need to be monitored carefully.

In autopsy and pathology laboratories, depending upon the type of specimen, direct reuse of formaldehyde solutions may be feasible. These solutions retain their desired properties for periods far longer than the usual holding times for specimens. In addition, the desired preservative properties may be effective at lower concentrations than the 10 percent formaldehyde solutions typically used. Reuse of hospital formaldehyde wastes through an open market waste exchange does not appear feasible. This is because of the potential presence of pathogens in the waste stream.

All waste management methods should stress control of airborne emissions since formaldehyde is a suspected carcinogen of the upper respiratory system (ACGIH 1987). The OSHA permissible exposure level (PEL) for formaldehyde was recently reduced from 10 ppm to 1 ppm.

The major waste stream associated with image processing at hospital radiology departments is wastewater that contains photographic chemicals and silver removed from film. Other wastes include spoiled chemicals and scrap film. Ways to reduce these wastes include:

Many photo-processing chemicals are sensitive to temperature and light. Photosensitive film and paper storage areas should be designed for economical and efficient use. Chemical containers list there commended storage conditions. Meeting the recommended conditions will increase their shelf life.

It is a current practice in the photo processing and printing industry to send used and/or spoiled film to professional recyclers for recovery of silver (USEPA 1986). However, this option might not be practical to small-scale operations or available to facilities located far away from recyclers.

Materials having expired shelf life should not automatically be thrown out. Instead, this material should be tested for effectiveness. The materials may be usable, rather than becoming a waste. Are cycling outlet should be found for left over raw material that is no longer wanted.

Wastes from photographic processing can be reduced by extending the life of fixing baths. Techniques include (1) adding ammonium thiosulfate, which doubles the allowable concentration of silver buildup in the bath; (2) using an acid stop bath prior to the fixing bath; and (3) adding acetic acid to the fixing bath as needed to keep the pH low.

Accurately adding and monitoring chemical replenishment of process baths will cut down chemical wastage. Stored process bath chemicals should be protected from oxidation by reducing exposure to air. Some smaller photo developers store chemicals in closed plastic containers. Glass marbles are added to bring the liquid level to the brim each time liquid is used. In this way, the amount of chemical subject to degradation by exposure to air is reduced, thereby extending the chemical's useful life and the life of the bath.

Use Squeegees.

Squeegees can be used in non-automated processing Systems to wipe excess liquid from the film and paper. This can reduce chemical carryover from one process bath to the next by 50 percent (Campbell and Glenn 1982). Minimizing chemical contamination of process bath increases recyclability, enhances the lifetime of the process baths, and reduces the amount of replenisher chemicals required. Most firms, however, use automated processors. Also, using squeegees may damage the film image if it has not fully hardened, so a squeegee should be used after the film image has hardened.

In photographic processors, countercurrent washing can replace the commonly used parallel tank system. This can reduce the amount of wastewater generated. In a parallel system, fresh water enters each wash tank and effluent leaves each wash tank. In countercurrent rinsing, the water from previous rinsing is used in the initial film washing stage. Fresh water enters the process only at the final stage, at which point much of the contamination has already been rinsed off the film. However, a countercurrent system requires more space and equipment.

Basically, photo processing chemicals consist of developer, fixer, and rinse water. Keeping the individual process baths as uncontaminated as possible is a prerequisite to the successful recycling of these chemicals. Silver is a component in most photographic films and paper and is present in the wastewater produced. Various economical methods of recovering silver are available (e.g. metallic replacement, chemical precipitation, electrolytic recovery), and a number of companies market equipment that will suit the needs of even the smallest generator.

The most common method of silver recovery employed by hospitals is metallic replacement. The spent fixing bath is pumped into a cartridge containing steel wool. An oxidation reduction reaction occurs and the iron in the wool replaces the silver in solution. The silver settles to the bottom of the cartridge as sludge.

Another, more efficient, method of silver recovery is electrolytic deposition. In an electrolytic recovery unit, a low voltage direct current is created between a carbon anode and stainless steel cathode. Metallic silver-plates onto the cathode. Once the silver is removed, the fixing bath may be able to be reused in the photographic development process by mixing the desilvered solution with fresh solution. Recovered silver is worth about 80% of its commodity price.

Some of the companies that buy used film or cartridges containing recovered silver can be located under "Goldand Silver Refiners and Dealers" in a business telephone directory. These firms may pick up directly or may purchase through dealers. To recycle used film, it may be worth while to sort the film into "largely black" versus "largely clear" segments, since the rate of payment for mostly black film may be twice that for mostly clear.

Technologies for reuse of developer and fixer are available and include ozone oxidation, electrolysis, and ion exchange.

Radioactive wastes cannot be treated or neutralized. Therefore, source reduction and substitution are the primary waste minimization strategies for such materials. Knowledge of the physical and biological properties of the various nuclides is required to enable assessment of environmental hazards associated with waste products.

Table 2 lists properties of common nuclides used in hospital research and treatment. The type of radiation emitted, energy, physical and effective half lives, and decay products are the factors, which must be considered when choosing among various nuclides. The objective is to choose a nuclide, which has a short half-life, low energy, a stable, non-toxic decay product and emits minimal amounts of extraneous radiation. Extraneous radiation refers to the production of a type of radiation, which is not required in the test or procedure. For example, if a beta emitter is required for a certain test, a nuclide which produces minimal gamma radiation should be chosen. This is because gamma radiation is hazardous to the patient and is more difficult to contain during handling.

Radium-226 is probably the most hazardous radionuclide used in hospitals. Its physical and effective half-lives are extremely long and its decay products are unstable. Radium-226 needles used in cancer treatment are being phased out at many hospitals in favor of iridium-192 or cesium-137 needles.

Table 2. Properties of Radionuclides Used In Hospitals

Waste minimization assessments were conducted at three hospitals. The assessments were used to develop the waste minimization questionnaire and worksheets that are provided in this section.

A comprehensive waste minimization assessment includes a planning and organizational step, an assessment step that includes gathering background information and development of waste minimization options, a feasibility study on specific waste minimization options, and an implementation phase.

The worksheets provided in this section are intended to assist hospital managers in systematically evaluating waste generating processes and in identifying waste minimization opportunities. These work sheets include only the assessment phase of the procedure described in the Waste Minimization Opportunity Assessment Manual. For a full description of waste minimization assessment procedures, refer to the EPA Manual.

Table 3 lists the worksheets that are provided in this section. Table 3. List of Waste Minimization Assessment Worksheets

Appendix A. Facility assessments of three hospitals

In 1986 the California Department of Health Services commissioned a waste minirnization study (DHS 1988) of three general medical and surgical hospitals. The objectives of the waste minimization assessments were to:

• Gather site-specific information concerning the generation, handling, storage, treatment, and disposal of hazardous waste;

• Evaluate existing waste reduction practices;

• Develop recommendations for waste reduction through source control, treatment, and recycling techniques; and

• Assess costs/benefits of existing and recommended waste reduction techniques.

In addition, the results of the waste assessments were used to prepare waste minimization assessment worksheets to be completed by other hospitals in a self-audit process.

The first steps in conducting the assessments were the selection of the three hospitals, and contacting them to solicit voluntary participation in the audit study. During each of the hospital audits, the audit team observed a variety of hospital operations; inspected waste management facilities; interviewed the hospital managers, environmental compliance personnel, and laboratory supervisors; and reviewed and copied records pertinent to waste generation and management. Tile audits were performed by one or two engineers over a one- to three-day period depending on the size and complexity of the formulating and waste management operations.

This Appendix section presents the results of the assessments of the hospitals here identified as A, B and C and the potentially useful waste minimization options identified through the assessments. Also included are the practices already in use at the facilities that have successfully reduced waste generation from past levels.

Findings of Waste Audit of Hospital A

Hospital A is a general surgical hospital with 323 beds and 2,000 employees. The types of in-house departments are typical for a full-service hospital, although much of the laboratory work is performed through a regional laboratory at a separate location. This regional laboratory manages

some of the hazardous waste streams that the hospital would otherwise be required to manage itself. Outpatient clientele consists of approximately 125 to 150 persons per day.

Procurement of hazardous materials is conducted through a central clinic and separate general purchasing department. Hazardous waste manifests are maintained by the housekeeping department. The hospital has conducted an internal environmental compliance audit and has inventoried hazardous materials on site. Waste minimization, however, has not been specifically addressed.

The laboratory and pathology departments generate primarily xylem and formaldehyde waste, in the amount of about one gallon each per month. In both cases, this waste is discharged to the sewer. Reagents are used in "contained packs" for unit applications. These are disposed of as infectious waste.

Hazardous wastes generated by the radiology imaging department consist of fixer, developer, and mercury on occasion. Silver from the fixer is extracted and 20% of the solution is recycled. Although mercury disposal does not occur on a routine basis, it is handled regionally.

The central sterile supply department generates only ethylene oxide, which is vented to the atmosphere and sewer.

The engineering department handles various hazardous materials. It generate only about three gallons per month of used oil, which is transported off site for disposal. This department also uses solvents, aerosols, and water-based latex paints, which are consumed. Boiler/ water treatment compounds are also consumed.

The pharmacy generates antineoplastic wastes, which are hauled off site for incineration. It also generates outdated drugs, which are returned to the regional pharmacy (see Figure A-1).

The respiratory therapy department generates approximately 16 ounces of 70% alcohol per day, which is discharged to the sewer.

The hemodialysis department generates 4% formaldehyde waste, which is disposed of to the sewer at a rate of about 8 liters per week. It also generates 5.25% sodium hypochlorate, which is also discharged to the sewer, at a rate of about 10 liters per week (see Figure A-2).

Findings of Waste Audit of Hospital B

Hospital B is a general surgical hospital with 415 beds. In-house departments include a laboratory, pathology, engineering, radiology, histology, dialysis, and a pharmacy. Primary sources of hazardous wastes include hemododialysis, the clinical testing laboratory, and the pharmacy. Outpatient clientele consists of approximately 100 persons per day. Hospital B has not conducted any in-house environmental compliance or waste minimization audits.

The pharmacy purchases antineoplastic chemicals, which are inventoried through a computerized central receiving system. Supplies kept in-house at a given time are inventoried to last two weeks. Antineoplastic drugs used as chemotherapy agents are the hospital's largest source of hazardous waste by volume. Approximately two five-gallon disposal cans are filled with liquid chemotherapy waste each week. Gowns, gloves, and other articles contaminated by cytotoxic drugs are bagged and placed in 55-gallon steel drums. All chemotherapy wastes are transported off-site for disposal (see Figure A-3).

Hazardous waste generated through hemodialysis includes 4% formaldehyde that has been pumped through 18 individual dialysis units, at the rate of 250 cc's per day. Effluent lines from these machines are connected to the municipal sewer system. Tubing from the units is discarded as infectious waste (see Figure A-4).

Radioactive tagging in the clinical testing laboratory is also a source of hazardous waste at Hospital B. Approximately 800 ml per week of radioactive water, or tritium, are generated. About five gallons per month of radioactive solid waste are also generated. Tritium is a beta-emitter with a half-life of 57 years. An additional 200 ml per week of toluene are evaporated under a hood. Radioactive wastes are transported off site for disposal (see Figure A-5).

Hospital C is a general surgical hospital with 280 beds. The types of in-house departments are typical for a full-service hospital, except that hemodialysis, histology work, and certain blood tests are contracted to outside films. The inner-city location attracts a significant out patient clientele of approximately 150 to 175 persons each weekday.

Hazardous materials are procured in two central areas: the materials management department and the pharmacy. The inventory system has recently been computerized, and all chemotherapy drugs are ordered by one pharmacist.

At Hospital C, a product evaluation committee has been established to review product toxicity and investigate substitution with less hazardous compounds. For example, disinfectants containing glutaraldehyde were recently replaced with an alcohol compound formulated in a nonflammable water mixture. 

The hospital has approached the disposal of obsolete or expired supplies in a unique manner: materials that are unusable are shipped to Third World countries in need of such materials. For instance, pharmaceutical drugs that cannot be used in the U.S. when their potency decreases to less than 95% are usable in many other countries where such drugs are in very scarce supply.

Hospital C has just begun to initiate its hazardous materials right-to-know training. The sessions include spill clean-up techniques but do not address waste minimization or spill prevention techniques.

The hospital has not yet developed a master listing of its hazardous waste types. These wastes are stored in the areas where they are generated; a single person is in charge of arranging for disposal. Small quantities of alcohols, formaldehyde, and aromatic hydrocarbons are routinely discharged to the sewer.

The local sanitation district prohibits discharge of flammable petroleum solvents. However, small quantity discharges of alcohol and formaldehyde may be permitted if the wastes are adequately dilut ed.

Antineoplastic residues are the only hazardous wastes routinely disposed of at a permitted facility. The hospital's chemotherapy drug handling practices result in minimal generation of these wastes (less than 7 cubic feet per month), which are currently landfilled. Hazardous waste controls involving these chemical agents include the following:

• Compounding is done by a single individual who is highly experienced.

• Compounding is performed under a Type A biological safety cabinet which draws vapor sandaerosolsaway from the operator. This reduces the potential for

• Contaminating protective gowns.

• All antineoplastic drugs are administered in a designated wing of the hospital. This reduces the potential for spills and handling of drugs by unqualified persons.

• Drug containers are ordered in specified sizes designed to reduce or eliminate unused residues.

• Spill clean-up kits are readily available in antineoplastic drug handling areas.

The hospital has not implemented any programs specifically designed to minimize waste. However, in the laboratory, waste quantities have decreased in recent years. This reduction is due to automation of equipment and reduction in the quantity of analyses and reagents required for analyses. The laboratory director has obtained information on solvent distillation units. However, the director did not purchase this equipment due to the small quantities of solvents that the hospital generates.

Some steps have been taken to eliminate high hazard chemicals. For example, in recent years, the laboratory has substituted xylene for benzene and has discontinued the use of ether. The hospital does not dispose of radioactive wastes. Radioisotopes are stored in a leadlined receptacle until they disintegrate to nonhazardous levels. These receptacles are then returned to the manufacturer.

Additional information on source reduction, reuse and recycling approaches to pollution prevention is available in EPA reports listed in this section, and through state programs (listed below) that offer technical and/or financial assistance in the areas of pollution prevention and treatment.

In addition, waste exchanges have been established in some areas of the U.S. to put waste generators in contact with potential users of the waste. Four waste exchanges are listed below. Finally, EPA's regional offices are listed.

EPA REPORTS ON WASTE MINIMIZATION

U.S. Environmental Protection Agency. "Waste Minimization Audit Report: Case Studies of Corrosive and Heavy Metal Waste Minimization Audit at a Specialty Steel Manufacturing Complex." Executive Summary.*

U.S. Environmental Protection Agency. "Waste Minimization Audit Report: Case Studies of Minimization of Solvent Waste for Parts Cleaning and from Electronic Capacitor Manufacturing operation." Executive Summary.*

U.S. Environmental Protection Agency. "Waste Minimization Audit Report: Case Studies of Minimization of Cyanide Wastes from Electroplating Operations." Executive Summary.

U.S. Environmental Protection Agency. Report to Congress: Waste Minimization, Vols. 1 and II. EPA/530-SW-86-033 and -034 (Washington, D.C.: U.S. EPA, 1986).

U.S. Environmental Protection Agency. Waste Minimization - Issues and Options, Vols. 1-111 EPA/ 530-SW-86-041 through -043. (Washington, D.C.: U.S. EPA, 1986).**

WASTE REDUCTION TECHNICAL/ FINANCIAL ASSISTANCE PROGRAMS

The EPA's Office of Solid Waste and Emergency Response has set up a telephone call-in service to answer questions regarding RCRA and Superfund (CERCLA): 

(800) 242-9346 (outside the District of Columbia)
(202) 382-3000 (in the District of Columbia)

The following states have programs that offer technical and/or financial assistance in the areas of waste minimization and treatment.

Alabama
Hazardous Material Management and Resources Recovery Program
University of Alabama
P.O. Box 6373
Tuscaloosa, AL 35487-6373
(205) 348-8401

Alaska
Alaska Health Project
Waste Reduction Assistance Program
431 West Seventh Avenue, Suite 101
Anchorage, AK 99501
(907)276-2864

Arkansas

Arkansas Industrial Development Commission
One State Capitol Mall
Little Rock, AR 72201
(501) 371-1370

California

Alternative Technology Section
Toxic Substances Control Division
California State Department of Health Service
714/744 P Street
Sacramento, CA 94234-7320
(916) 324-1807

Connecticut
Connecticut Hazardous Waste Management Service
Suite 360
900 Asylum Avenue
Hartford, CT 06105
(203) 244-2007 

Connecticut Department of Economic Development
210 Washington Street
Hartford, CT 06106
(203) 566-7196

Georgia

Hazardous Waste Technical Assistance Program
Georgia Institute of Technology
Georgia Technical Research Institute
Environmental Health and Safety Division
O'Keefe Building, Room 027
Atlanta, GA 30332
(404) 894-3806 

Environmental Protection Division
Georgia Department of Natural Resources
Floyd Towers East, Suite 1154
205 Buder Street
Atlanta, GA 30334
(404)656-2833

Illinois

Hazardous Waste Research and Information Center
Illinois Department of Energy of Energy and Natural
Resources
1808 Woodfield Drive
Savoy, W 61874
(217) 333-8940 

Illinois Waste Elimination Research Center
Pritzker Department of Environmental Engineering
Alumni Building, Room 102
Illinois Institute of Technology
3200 South Federal Street
Chicago, IL 60616
(313) 567-3535

Indiana

Environmental Management and Education Program
Young Graduate House, Room 120
Purdue University
West Lafayette, IN 47907
(317) 494-5036

Indiana Department of Environmental Management
Office of Technical Assistance
P.O. Box 6015
105 South Meridian Street
Indianapolis, IN 46206-6015
(317) 232-8172

Iowa

Center for Industrial Research and Service
205 Engineering Annex
Iowa State University
Ames, IA 50011
(515) 294-3420 

Iowa Department of Natural Resources
Air Quality and Solid Waste Protection Bureau
Wallace State Office Building
900 East Grand Avenue
Des Moines, IA 503194)034
(515) 281-8690

Kansas

Bureau of Waste Management
Department of Health and Environment
Forbes Field, Building 730
Topeka, KS 66620
(913) 269-1607

Kentucky

Division of Waste Management
Natural Resources and Environmental
Protection Cabinet
18 Reilly Road
Frankfort, KY 40601
(502) 564-6716

Louisiana

Department of Environmental Quality
Office of Solid and Hazardous Waste
P.O. Box 44307
Baton Rouge, LA 70804
(504) 342-1354

Maryland

Maryland Hazardous Waste Facilities Siting Board
60 West Street, Suite 200 A
Annapolis, MD 21401
(301) 974-3432

Maryland Envilonmental Service
2020 Industrial Drive
Annapolis, MD 21401
(301) 269-3291
(800)492-9188 (in Maryland)

Massachusetts

Office of Safe Waste Management
Department of Environmental Management
100 Cambridge Street, Room 1094
Boston, MA 02202
(617)727-3260

Source Reduction Program
Massachusetts Department of Environmental Quality Engineering
1 Winter Street
Boston, MA 02108
(617)292-5982

Michigan

Resource Recovery Section
Department of Natural Resources
P.O. Box 30028
Lansing, MI 48909
(517) 373-0540

Minnesota

Minnesota Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Road
St. Paul, MN 55155
(612)296-6300

Minnesota Technical Assistance Program
W- 140 Boynton Health Service
University of Minnesota
Minneapolis, MN 55455
(612) 625-9677

(800)247-0015 (in Minnesota)
Minnesota Waste Management Board
123 Thorson Center
7323 Fifty-Eighth Avenue North
Crystal, MN 55428
(612) 536-0816

Missouri

State Environmental Improvement and Energy
Resources Agency
P.O. Box 744
Jefferson City, MO 65102
(314) 751-4919

New Jersey

New Jersey Hazardous Waste Facilities Sitting Commission
Room 614
28 West State Street
Trenton, NJ 08608
(609) 292-1459
(609) 292-1026

Hazardous Waste Advisement Program
Bureau of Regulation and Classification
New Jersey Department of Environmental Protection
401 East State Street Trenton, NJ 08625

Risk Reduction Unit
Office of Science and Research
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625

New York

New York State Environmental Facilities Corporation
50 Wolf Road
Albany, NY 12205
(518) 457-3273

North Carolina

Pollution Prevention Pays Program
Department of Natural Resources and
Community Development
P.O. Box 27687
512 North Salisbury Street
Raleigh, NC 27611
(919) 733-7015

Governor's Waste Management Board
325 North Salisbury Street
Raleigh, NC 27611
(919) 733-9020 

Technical Assistance Unit
Solid and Hazardous Waste Management Branch
North Carolina Department of Human Resources
P.O. Box 2091
306 North Wilmington Street
Releigh, NC 27602
(919) 733-2178

Ohio

Division of Solid and Hazardous Waste Management
Ohio Envilonmental Protection Agency
P.O. Box 1049
1800 WaterMark Drive
Columbus, OH 43266-1049
(614)481-7200

Ohio Technology Transfer Organization
Suite 200
65 East State Street
Columbus, OH 43266-0330
(614)466-4286 

Oklahoma

Industrial Waste Elimination Program
Oklahoma State Department of Health
P.O. Box 53551
Oklahoma City, OK 73152
(405) 271-7353

Oregon

Oregon Hazardous Waste Reduction Program
Department of Environmental Quality
811 Southwest Sixth Avenue
Portland, OR 97204
(503) 229-5913

Pennsylvania

Pennsylvania Technical Assistance Program
501 F. Orvis Keller Building
University Park, PA 16802
(814) 865-0427

Center of Hazardous Material Research
320 William Pitt Way
Pittsburgh, PA 15238
(412) 826-5320 

Bureau of Waste Management
Pennsylvania Dcpartment of
Envilonmental Resources
P.O. Box 2063
Fulton Building
3rd and Locust Streets
Harrisburg, PA 17120
(717) 787-6239

Rhode Island

Ocean State Cleanup and Recycling Program
Rhode Island Department of Envilonmental Management
9 Hayes Street
Providence, Rl 02908-5003
(401) 277-3434
(800) 253-2674 (in Rhode Island)

Center for Envilonmental Studies
Brown University
P.O. Box 1943
135 Angell Street
Providence, Rl 02912
(401) 863-3449

Tennessee

Center for Industrial Services
102 Alumni Hall
University of Tennessee
Knoxville, TN 37996
(615) 974-2456

Virginia

Office of Policy and Planning
Virginia Department of Waste Management
1 th Floor, Monroe Building
101 North 14th Street
Richmond, VA 23219
(804) 225-2667

Washington

Hazardous Waste Section
Mail Stop PV-11
Washington Department of Ecology
Olympia, WA 98504-8711
(206)459-6322

Wisconsin

Bureau of Solid Waste Management
Wisconsin Department of Natural Resources
P.O. Box 7921
101 South Webster Street
Madison, WI 53707
(608)267-3763

Wyoming

Solid Waste Management Program
Wyoming Department of Environmental Quality
Herchíer Building, 4th Floor, West Wing
122 West 25th Street
Cheyenne, WY 82002
(307) 777-7752

WASTE EXCHANGES

 Northeast Industrial Exchange
90 Presidential Plaza, Syracuse, NY 13202
(315) 422-6572

Southern Waste Information Exchange
P.O. Box 6487, Tallahassee, FL 32313
(904) 644-5516

California Waste Exchange
Department of Health Services
Toxic Substances Control Division
Alternative Technology & Policy Development Section
714 P Street
Sacramento, CA 95814
(916) 324-1807

Region 1 (VT, NH, ME, MA, CT, Rl)
John F. Kennedy Federal Building
Boston, MA 02203
(617) 565-3715 

Region 2 (NY, NJ)
26 Federal Plaza
New York, NY 10278
(212) 264-2525 

Region 3 (PA, DE, MD, WV, VA)
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-9800

Region 4 (KY, TN, NC, SC, GA, FL, AL, MS)
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727

Region 5 (WI,MN, Mí, IL, IN, OH)
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2000

Region 6 (NM, OK, AR, LA, TX)
1445 Ross Avenue
Dallas, TX 75202
(214) 655-6444

Region 7 (NE, KS, MO, IA)
756 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2800

Region 8 (MT, ND, SD, WY, UT, CO)
999 18th Street
Denver, CO 80202-2405
(303) 293-1603

Region 9 (CA, NV, Az, HI)
215 Fremont Street
San Francisco, CA 94105
(415) 974-8071 

Region 10 (AK, WA, OR, ID)
1200 Sixth Avenue
Seattle, WA 98101
(206)442-5810