RCRA - 4 Letters You Better Understand
Once Regulated Medical Waste leaves your facility, it is still your responsibility
The Resource Conservation and Recovery Act of 1976 (pronounced as “rik-rah”; see below for details) clearly states that a hospital, clinic, private practice or research facility has “cradle-to-grave” responsibility for the regulated medical waste it produces—even after it has left your back door! If you are relying on a third-party to pick up your waste and (hopefully) dispose of it in a proper manner, the thought of your organization’s potential exposure to lawsuits and other legal action riding in the back of truck somewhere should be enough to keep you up at nights worrying.
So what is a healthcare facility to do? We’d like to think that by employing Peerless Waste’s CFA technology,(continuous feed batch autoclaving), for on-site RMW processing is a first great step. On top of almost certain hard cost savings on a per pound basis, are abundant soft cost savings from process improvement. For example, the “cradle to grave” tracking of hazardous waste for on-site processing requires less than 20% of the bookkeeping and reporting requirements compared to utilizing 3rd party haulers. Numerous other process improvements for the waste stream between generation and on-site processing are realized as you determine how your facility treats RMW and where it ultimately goes. Self-processing becomes an extremely attractive option when considering the cost savings, process efficiencies, and the limited liability delivered by a custom solution built around the way you generate and desire to handle your medical waste. And, don’t forget the added benefit of a good night’s sleep.
What is RCRA?
The Resource Conservation and Recovery Act (RCRA), enacted in 1976, is a Federal law of the United States contained in 42 U.S.C. §§6901-6992k. It is usually pronounced as “rick-rah” or “Wreck-rah.” RCRA is the United States’ primary law governing the disposal of solid and hazardous waste. Congress passed RCRA on October 21, 1976 to address the increasing problems the nation faced from our growing volume of municipal and industrial waste. RCRA, which amended the Solid Waste Disposal Act of 1965, set national goals for:
- Protecting human health and the environment from the potential hazards of waste disposal.
- Conserving energy and natural resources.
- Reducing the amount of waste generated.
- Ensuring that wastes are managed in an environmentally-sound manner.
EPA waste management regulations are codified at 40 C.F.R. pts. 239-282. Regulations regarding management of hazardous waste begins at 40 C.F.R. pt. 260. As noted below, most states have enacted laws and promulgated regulations that are at least as stringent as the federal regulations. Furthermore, the statute authorizes states to carry out many of the functions of RCRA through their own agencies, if such programs have been approved by the EPA.
While RCRA handles many regulatory functions of hazardous and non-hazardous waste, arguably its most notable provisions regard the Subtitle C program which tracks the progress of hazardous substances from their generation, to their treatment, their transport, and their disposal. Due to the extensive tracking elements at all points of the life of the hazardous waste, the acts have become known as the “cradle to grave” system. The program exacts stringent bookkeeping and reporting requirements on generators, transporters, and operators of disposal facilities handling hazardous waste.