Madison Environmental Resourcing, Inc. (MERI) will offer a RCRA and DOT Hazardous Waste Training Certification Class on October 29, 2019. It will be from 9:00 a.m. until 3:00 p.m. at MERI’s facility at 800 Uniek Drive in Waunakee, WI.

Click to register here or email this HAZTRAININGFORM to info@meriinc.com if you’d like to be added to the class list.

Hospital, Medical Clinic, Facilities, Environmental Service, Plant Operations, and Safety Department employees should attend, especially those in need of RCRA and DOT Hazardous Certification.

WHAT: RCRA/DOT Hazmat Training

WHEN:     Tuesday, October 29, 2019

WHERE:   Madison Environmental Resourcing, Inc. 800 Uniek Drive, Waunakee, WI  53597

Check-In:  8:45 a.m. – 9:00 a.m.

Class: 9:00 a.m. – 3:00 p.m.

Cost: $250 person.  Continental Breakfast,  Lunch and Afternoon Beverages will be provided.

Certification: All who successfully complete the course test will receive their certification at the end of the day.

Payment: USE THIS LINK TO PAY BY PAYPAL OR CREDIT CARD. Invoices can be sent ahead of the training day by contacting info@meriinc.com and noting the name(s) of those attending from your organization. Or, payment can take place on the day of the training. Make checks payable to MERI. Receipts will be available.

RCRA/DOT Hazardous Waste Certification Class 10/29/2019 COURSE DESCRIPTION 

RCRA COMPLIANCE FOR HAZARDOUS WASTE GENERATORS OVERVIEW
(MORNING SESSION)
This RCRA compliance course is for large and small quantity generators. The Resource Conservation and Recovery Act (RCRA) requires that facility personnel be trained to “perform their duties in a way that ensures the facility’s compliance” with hazardous waste regulations.

DOT HAZMAT TRANSPORTATION OVERVIEW
(AFTERNOON SESSION)
Comprehensive training for shippers, handlers & transporters. Students receive regulatory changes and training in the use and application of the 49 CFR manual. Are you meeting hazmat training requirements? Every employee involved in shipping, transporting, or handling hazardous materials must receive training to be certified. And, the training must take place at least every 36 months. Also, the training must update whenever there is a regulation change affecting an employee’s job duties. All employees must train in hazmat compliance before performing hazmat activities in the workplace. This course will also provide train-the-trainer basics

WHO SHOULD ATTEND

All employees who are responsible for hazmat employee training; preparing/signing shipping papers; placarding; security; marking and labeling; packaging; loading and unloading of vehicles; and other activities that are regulated under the DOT hazmat regulations.

Reverse Distributor: HAZ Pharma Flow Chart

EPA Disposal Guidelines in Iowa have changed regarding hazardous pharmaceutical waste. Don’t worry. It’s a good thing – and a better fit for healthcare. It will provide regulatory relief for hospitals and other large quantity generators of hazardous waste pharmaceuticals. Part of this sweeping legislation is 40 CFR 266 Subpart P. Below is are recap of this federal ruling, who needs to comply, and how.

Iowa First to Adopt New EPA Rules                                                                                                                             

The new EPA rules became effective August 21, 2019 in Iowa, Alaska, the US Territories, and the Indian Country.

All other states have some leeway (until July 2021) when they adopt these new federal regulations. This chart gives an idea of the timing of when it may take place, such as in Wisconsin and Illinois. Note that some states’ current regulations may actually be even more stringent than the new EPA laws, and will follow those instead.

That said, there is one aspect of Subpart P that every state must follow as of August 21, 2019 — the nationwide Sewer Ban, which we’ll discuss in more detail below. Iowa healthcare facilities must prepare for the Sewer Ban and a few other changes. If you work for or manage one of these facilities in Iowa, it’s important to comply to these new regulations. For all others, follow your state’s existing regulations until these new rules become a state law.

Does My Iowa Healthcare Facility Need to Comply to Subpart P?

If you’re unsure of whether or not your facility is a “healthcare facility” under this new rule, please consult with your local regulator.

Healthcare facilities often fall into three buckets:

  1. If you provide preventative, diagnostic, therapeutic, rehabilitative, maintenance or palliative care to humans or animals.
  2. Your facility provides counseling services, assessments or procedures, with respect to patients’ physical, mental condition, or functional status.
  3. You distribute, sell, or dispense pharmaceuticals, including over-the-counter pharmaceuticals, dietary supplements, homeopathic drugs, or prescription pharmaceuticals.

With that in mind, here are some examples of healthcare facilities who might be impacted by this rule:

  • Hospitals
  • Health Clinics
  • Psychiatric and Substance Abuse Centers
  • Ambulatory Services and Ambulatory Surgical Centers
  • Physicians’ Offices
  • Optical and Dental Providers
  • Chiropractors
  • Veterinary Clinics and Hospitals
  • Long-Term Care Facilities (administer pharmaceuticals to one or more individuals there)
  • Pharmacies (including Mail-Order and Long-Term Care)
  • Retailers of Pharmaceuticals
  • Wholesale Distributors
  • Third Party Logistics Providers that serve as forward distributors

New EPA Disposal Guidelines Will Affect These Facilities

Ultimately, this rule will affect these three types of healthcare facilities that regularly accrue hazardous waste pharmaceuticals. Namely:

  • Large Quantity Generators (LQG): Generate more than 2,200 lbs. of hazardous waste per month.
  • Small Quantity Generators (SQG): Generate more than 220 lbs. of hazardous waste but less than 2,200 lbs. per month. 
  • Reverse Distributors: Those who receive or take back prescription pharmaceuticals from another organization to verify a manufacturer’s credit

Very Small Quantity Generators (VSQGs), or those who generate less than 220 lbs. of hazardous waste pharmaceuticals per month, are not beholden to Subpart P, (except for the Sewer Ban). They can continue to follow their previous way of handling their pharmaceuticals and acutely hazardous P waste.  However, they may opt into Subpart P.  Or, they can also send their hazardous waste pharmaceuticals off to an affiliate site that operates under Part 266 Subpart P.

What is a “Hazardous Pharmaceutical Waste?”

A review of the formulary list from the pharmacy will help you determine what is a hazardous pharmaceutical waste — and what isn’t. Your pharmacist will know – and may likely even tell you that a majority of what’s on the shelf is actually non-hazardous. The whole point of Subpart P is to make sure pharmaceutical hazardous waste gets properly disposed. Most importantly, not flushed down the sewer, where it can pollute the waterways.

Commingling of hazardous and non-hazardous waste pharmaceuticals in the same container is acceptable. But remember then, the whole container must be disposed of as hazardous waste.

Changes to Comply with Subpart P in Iowa

We’ve discussed who might be affected, now let’s dive into the nuts and bolts of the upcoming changes. Here are six big new changes from what you might be used to that are included in Subpart P and the new Nicotine Amendment

1. Sewer Ban – 266.505

In the past, many healthcare facilities have flushed hazardous waste pharmaceuticals down the sink or in the toilet.  This practice will soon be met with harsh penalties. In short, all states will no longer be able to sewer hazardous pharmaceutical waste as of August 21, 2019.

If you’re unsure of where to start, begin by obtaining a formulary list from your designated pharmacist or pharmaceutical provider to make you aware of what hazardous pharmaceutical waste you have on site.

2. Controlled Substances – 266.506

Here are five controlled substances that are also RCRA Hazardous Waste Pharmaceuticals. They must not be sewered:

5 Controlled Substances Can't Sewer

The five DEA hazardous substances noted above are EXEMPT from RCRA if they are:

  • Not flushed down the drain,
  • Managed in compliance with DEA Regulations,
  • Destroyed by a method that the DEA has deemed in writing to meet their non-retriable standards, or
  • Thermally destroyed at a permitted hazardous waste disposal facility.

3. “RCRA Empty” – 261.7 & 266.507

The new 266 Subpart P Regulations cover other areas, including defining “RCRA Empty”, as shown in the chart below.

RCRA EMPTY PHARMA CONTAINERS

As noted in the above chart, “RCRA Empty” means fully remove medicine from dispensing bottles. For syringes, fully depress the plunger. And, for IV bags, fully administer contents before disposing of it. Basically, once you’ve removed everything from it by pouring, pumping, and aspirating the medicine, it is “RCRA Empty”.  Residues remaining inside of a container will no longer be regulated as hazardous waste pharmaceuticals.

What does this “RCRA EMPTY” change mean for you?  In the past, many healthcare facilities triple rinsed containers when there was still a trace amount of hazardous waste pharmaceuticals in them. No more. As of August 21, 2019, triple rinsing of RCRA pharmaceutical empty containers with acute hazardous pharmaceutical waste is not required/allowed.

4. Nicotine Disposal Amendment

The nicotine disposal amendment has been adopted by Iowa. It is effective August 21, 2019. Other states have to adopt this amendment. Over the counter nicotine items such as nicotine gum, patches, wrappers and lozenges are no longer considered acutely hazardous (P075) waste. They will now be considered non-hazardous waste.  

Keep in mind that nicotine in its purest form will still be acutely hazardous and must be disposed of as such. This includes unused formulations of nicotine that can be found inside e-cigarettes, cartridges and vials.

5. Reverse Distribution – 266.500

In years past, healthcare facilities have typically given most or all of their pharmaceutical waste to Reverse Distributors. This was regardless of whether they thought they could get credit for their expired medication. Subpart P changes things.

The EPA now says healthcare facilities can only give Reverse Distributors “potentially creditable” pharmaceutical waste. Furthermore, pharmaceutical waste must be identified on site as potentially creditable or non-creditable pharmaceutical waste, and not hauled off site and identified elsewhere. Finally, it must be evaluated within 30 days to determine its creditability.

Below are a couple lists to help you determine what waste is potentially creditable.

  • Potentially Creditable Waste:
    • Drugs in the original manufacturer packaging (except recalls)
    • Undispensed pharmaceutical waste
    • Unexpired waste or less than 1 year past expiration date
  • Non-Creditable Waste:
    • Broken or leaking container
    • Repackaged
    • Dispensed
    • Expired (greater than 1 year past expiration date)
    • Investigational new drugs
    • Contaminated PPE
    • Floor Sweepings
    • Clean-up Material
  • Evaluated (“Creditable”) Waste:
    • Manufacturer credit already determined/verified
    • Pharmaceuticals destined for TSDF

Non-creditable waste will no longer be able to flow through a Reverse Distributor. It must be disposed of by a permitted waste facility.

The flow chart below can help your healthcare facility determine the proper disposal method for its pharmaceutical waste.

Reverse Distributor: HAZ Pharma Flow Chart

6. Shipping Evaluated Vs. Non-Creditable Hazardous Pharmaceutical Waste

For evaluated and potentially creditable hazardous waste pharmaceuticals, the reverse distributor is exempt from RCRA Rules. Follow your reverse distributor’s shipping requirements. You must receive confirmation of delivery from the distributor.

Healthcare facilities need to have a manifest when shipping non-creditable hazardous waste pharmaceuticals.  The good news is, as part of the August 21st changes, this process will become a little easier. Rather than having to write various hazardous waste codes on manifests, you will only need to write the word “PHARMS.”  Remember though, that if the receiving state’s treatment facility has not adopted the rule, waste codes will still be required on the manifest.  You’ll need to follow your facility’s internal procedures for collection containers and DOT Regulations when shipping the waste.

Summing Up 266 Subpart P

The following matrix will help both healthcare facilities and reverse distributors. It summarizes the timing for on-site accumulation and shipping standards for potential creditable pharmaceuticals.

266 Subpart P Summary

Now that You Know…

Iowa healthcare facilities, we get it. It’s a lot to wrap your head around. Understanding the key changes above is a good start in avoiding harsh penalties after the new regulations go into effect August 21, 2019. Now that you’ve had a chance to get an overview, you have to do one more thing to do to demonstrate your knowledge….

Create a One Time Report

To let the EPA know you will be operating under Subpart P, it is requiring the submission of a one-time notification using this site EPA ID form: 8700-12

Large Quantity Generators must submit this form during normal biennial reporting cycle. For Iowa and Alaska, this means the form is due March 1, 2020.

Small Quantity Generators need to complete this form within 60 days of the rule going into effect. For Iowa, that means the form is due Oct. 20, 2019.

Very Small Quantity Generators must complete form 8700-12 only if they decide to opt into Subpart P. There is no timeline for submittal.

While it’s a lot to take in, these changes clarify hazardous waste pharmaceutical disposal for healthcare facilities. And, help them be a better friend to the environment.     

As always, if you have any questions, give us a call at 608-257-7652 or contact us at meriinc.com.  

###

Wondering how your Wisconsin healthcare facility can avoid hazardous disposal violations and sail through a surprise inspection by the WI DNR?

This Wisconsin Department of Natural Resources presentation highlights six areas to concentrate on to ensure a compliant hazardous waste management program. If you’re counting, we’re adding a seventh one in the list below, as the August 21, 2019 Sewer Ban is just around the corner.

To clarify, the WI DNR lists healthcare facilities as: hospitals, clinics, community-based residential facilities, residential care apartment complexes with centrally managed medications, in-patient hospice care and nursing homes with five or more beds.

The WI DNR defines hazardous waste as material being discarded (solid waste), which has any of these characteristic properties:

  • Ignitable (D001) – alcohol, solvents
  • Corrosive (D002)  – acids
  • Reactive (D003) – reacts violently with water, explosive
  • Toxic (D004 – D043) – regulatory levels (lead, mercury, silver)

Acute hazardous wastes are highly toxic in the environment. This includes things like U-listed wastes (nitroglycerin), and P-listed wastes, like warfarin and nicotine.

Now let’s get to the meat of the matter.

Most Common Hazardous Waste Disposal Violations

According to the WI DNR, the most common compliance violations and issues they see in Wisconsin healthcare facilities’ hazardous waste disposal process include:

  1. Incorrect Waste Determinations
  2. Inaccurate information on Land Disposal Restriction Notifications
  3. Insufficient Manifests recording cradle-to-grave hazardous waste disposal process
  4. Missing March 1 deadline for the WI DNR’s Annual Hazardous Waste Report
  5. Improper Hazardous Container Management
  6. Inadequate Training Documentation for Employees Handling Hazardous Waste

And, effective August 21, 2019, add:

  • Illegally Pouring Hazardous Waste Pharmaceuticals Down the Drain

Here’s a deeper dive into each:

Waste Determinations

It’s crucial to evaluate and properly characterize each hazardous waste stream for proper disposal. WI DNR publication WA1259, Table of Common Healthcare Wastes, is good to have on hand when sorting. Another guide, WI DNR’s Publication WA1152, Waste Determinations and Record Keeping, can also help when evaluating, characterizing and documenting each waste.

For pharmaceutical wastes, work with your pharmacist to get an updated formulary list to determine hazardous from non-hazardous. Commingling of hazardous and non-hazardous waste pharmaceuticals in the same container is acceptable. You must dispose of it as hazardous waste pharmaceuticals.

Beyond hazardous waste pharmaceuticals, you’ll need to keep in mind other hazardous waste streams. Spent hazardous materials from a lab (formalin), maintenance area (corrosive cleaning chemicals) and power plant (used oil and boiler chemicals) count too.

Keep track of universal waste. This includes hazardous lead items from protective x-ray clothing (aprons, shields, gloves). And, it includes shielding or wallboard from former X-ray rooms, or x-ray film foil wrapping.

If your facility has a dental clinic, keep track and properly dispose of wastes that contain silver. These include items like silver tipped catheters, X-ray film, plates and negatives. Dental amalgam should be sent to special mercury recycling center.

In Wisconsin, chemotherapy waste needs to be thermally destroyed. Be sure to document this for trace and bulk chemo destruction.

Land Disposal Restriction Notifications

From the moment hazardous waste is generated onward, it is subject to land disposal restrictions. If a hazardous waste generator produces more than 220 pounds of hazardous materials or 2.2 pounds of acute hazardous waste in a calendar month, it must identify the type and nature of the waste on a Land Disposal Restriction (LDR) Notification. And, it also must determine the course of applicable treatment before land disposal.

LDR Notifications must be kept on file for three years, per NR 668.07 Wis. Adm. Code. Being able to quickly retrieve them is important. The inspector will likely want to review them to see that all of the information is correct on them.

Hazardous Waste Manifests

Unless exempted, large quantity and small quantity generators (those who produce more than 220 lbs of hazardous waste or 2.2 lbs of acute hazardous waste per month) must use a paper or electronic manifest when shipping their hazardous waste. This Guide for Hazardous Waste Generators outlines more about this topic.

Retrieving these manifests from the past three years is key. They must document the cradle to grave destruction of your hazardous waste. Plus, they must also include proper waste codes, volumes, as well as the name of the transporter and receiving facility for the waste. Signatures must document each step of the way on a paper or electronic manifest.

Annual Hazardous Waste Reporting

By March 1, Wisconsin healthcare facilities must complete a hazardous waste annual report if they meet any of these three qualifications in any one month during the previous year. If they had:

  • 220 pounds of hazardous waste,
  • 2.2 pounds of acutely toxic waste, or
  • 220 pounds of acute hazardous waste as part of a spill cleanup.

Large Quantity Generators (more than 2,200 pounds of hazardous waste in any one month, or 2.2 pounds of acutely hazardous waste) must also submit a waste management plan in odd numbered years.

Container management

Here are a few questions inspectors might address regarding your hazardous containers.

Are:

  • Your containers in a secure area and labeled hazardous waste?
  • You tracking how much you are generating?
  • The lids securely closed on the containers?
  • Arrival dates on container labels?
  • You doing weekly inspections of the satellite accumulation area to ensure your containers are in good working condition and the covers are closed?

It’s always smart to have your hazardous containers near the point of generation. But, move them when they full. Remember, you have only three days to move them to main accumulation areas.

Very Small Quantity Generators (less than 220 pounds of hazardous waste a month) don’t have a time limit to when they need to dispose of their hazardous waste. As a best practice, we suggest to dispose of it at least once per year.

Small Quantity Generators have 180 days to remove their full hazardous waste containers. Large generators have only 90 days to remove their full containers from the main accumulation storage area.

Finally, make sure your staff knows which type of container is appropriate for each type of hazardous waste. Having a medical waste map that outlines what waste goes in each container could demonstrate to the inspector that your facility is on top of it. MERI offers a template of a medical waste map to our customers which offers a guideline as to which waste goes where.

Training and Emergency Response

It is not only vital to provide training for employees managing hazardous waste, but also to have a record of when and where the training took place. All facility personnel must understand the emergency evacuation portion of the contingency plan.

In addition, an agreement must be made with an emergency response contractor who understands ahead of time the types of hazardous wastes they could be handling if a spill were to take place. 

To sum up, would you be able to find the number of who to call should a hazardous spill occur on the premise? Could the folks who are cleaning up quickly be given information about what they are dealing with?

Sewer Ban Begins August 21, 2019

We’ve covered six common violations the DNR may site you for. Yet, one that will likely be addressed in the near future is what gets flushed down your facility’s drain. Medical facilities should have a letter from their Public Owned Treatment Works (POTW). It should explain what is currently being disposed of via the sink or toilet. Remember, take into account the new Sewer Ban before flushing.

The August 21, 2019 EPA sewer ban will affect healthcare facilities nationwide. Read our recent blog to learn more. Hazardous pharmaceutical waste cannot be disposed of down the sink or toilet. The following five DEA controlled substances are hazardous waste. They must not be flushed down the drain. They must be made non-recoverable. Or, a DEA Registrant needs to handle them.

  • Chloral/ Chloral Hydrate
  • Fentanyl Sublingual Spray
  • Phenobarbital
  • Testosterone gels/solutions
  • Valium injectable/gel

It Pays to Be in Compliance

Simply put, the consequences of not being in compliance are steep. Penalties can run up to tens of thousands of dollars, depending on the type and seriousness of the violation. Be sure to avoid this by educating yourself, and your staff!

As always, MERI is here for you. We often help our customers pull together key information they need to have at their fingertips. It is helpful to have on should an inspector come calling.

Give us a call at 608-257-7652 if you have any questions, or email us at info@meriinc.com

###

Madison Environmental Resourcing Inc. (MERI) will offer a RCRA/DOT Hazardous Waste Certification Class 6/24/2019. It will be from 9:00 a.m. until 3:00 p.m. at MERI’s facility at 800 Uniek Drive in Waunakee, WI.

Hospital, Medical Clinic, Facilities, Environmental Service, Plant Operations, and Safety Department employees should attend, especially those in need of RCRA/DOT Certification. Email info@meriinc.com if you’d like to be added to the class list or have any further questions.

WHAT: RCRA/DOT Hazmat Training

WHEN:     June 24, 2019

WHERE:   Madison Environmental Resourcing, Inc. 800 Uniek Drive, Waunakee, WI  53597

Check-In:  8:30 a.m. – 9:00 a.m.

Class: 9:00 a.m. – 3:00 p.m.

Cost: $250 person.  Continental Breakfast,  Lunch and Afternoon Beverages will be provided.

Certification: All who successfully complete the course test will receive their certification at the end of the day.

Payment: USE THIS LINK TO PAY BY PAYPAL OR CREDIT CARD. Invoices can be sent ahead of the training day by contacting info@meriinc.com and noting the name(s) of those attending from your organization. Or, payment can take place on the day of the training. Make checks payable to MERI. Receipts will be available.

RCRA/DOT Hazardous Waste Certification Class 6/24/2019 COURSE DESCRIPTION 

RCRA COMPLIANCE FOR HAZARDOUS WASTE GENERATORS OVERVIEW
(MORNING SESSION)
This RCRA compliance course is for large and small quantity generators. The Resource Conservation and Recovery Act (RCRA) requires that facility personnel be trained to “perform their duties in a way that ensures the facility’s compliance” with hazardous waste regulations.

DOT HAZMAT TRANSPORTATION OVERVIEW
(AFTERNOON SESSION)
Comprehensive training for shippers, handlers & transporters. Students receive regulatory changes and training in the use and application of the 49 CFR manual. Are you meeting hazmat training requirements? Every employee involved in shipping, transporting, or handling hazardous materials must receive training to be certified. And, the training must take place at least every 36 months. Also, the training must update whenever there is a regulation change affecting an employee’s job duties. All employees must train in hazmat compliance before performing hazmat activities in the workplace. This course will also provide train-the-trainer basics

WHO SHOULD ATTEND

All employees who are responsible for hazmat employee training; preparing/signing shipping papers; placarding; security; marking and labeling; packaging; loading and unloading of vehicles; and other activities that are regulated under the DOT hazmat regulations.

Madison Environmental Resourcing, Inc. (MERI) will offer a RCRA/DOT Hazardous Waste Training Certification Class 5/14/2019. It will be from 9:00 a.m. until 3:00 p.m. at MERI’s facility at 800 Uniek Drive in Waunakee, WI.

Hospital, Medical Clinic, Facilities, Environmental Service, Plant Operations, and Safety Department employees should attend, especially those in need of RCRA/DOT Certification.

Click to register here or email this HAZTRAININGFORM to info@meriinc.com if you’d like to be added to the class list.

WHAT: RCRA/DOT Hazmat Training

WHEN:     May 14, 2019

WHERE:   Madison Environmental Resourcing, Inc. 800 Uniek Drive, Waunakee, WI  53597

Check-In:  8:45 a.m. – 9:00 a.m.

Class: 9:00 a.m. – 3:00 p.m.

Cost: $250 person.  Continental Breakfast,  Lunch and Afternoon Beverages will be provided.

Certification: All who successfully complete the course test will receive their certification at the end of the day.

Payment: USE THIS LINK TO PAY BY PAYPAL OR CREDIT CARD. Invoices can be sent ahead of the training day by contacting info@meriinc.com and noting the name(s) of those attending from your organization. Or, payment can take place on the day of the training. Make checks payable to MERI. Receipts will be available.

RCRA/DOT Hazardous Waste Certification Class 5/14/2019 COURSE DESCRIPTION 

RCRA COMPLIANCE FOR HAZARDOUS WASTE GENERATORS OVERVIEW
(MORNING SESSION)
This RCRA compliance course is for large and small quantity generators. The Resource Conservation and Recovery Act (RCRA) requires that facility personnel be trained to “perform their duties in a way that ensures the facility’s compliance” with hazardous waste regulations.

DOT HAZMAT TRANSPORTATION OVERVIEW
(AFTERNOON SESSION)
Comprehensive training for shippers, handlers & transporters. Students receive regulatory changes and training in the use and application of the 49 CFR manual. Are you meeting hazmat training requirements? Every employee involved in shipping, transporting, or handling hazardous materials must receive training to be certified. And, the training must take place at least every 36 months. Also, the training must update whenever there is a regulation change affecting an employee’s job duties. All employees must train in hazmat compliance before performing hazmat activities in the workplace. This course will also provide train-the-trainer basics

WHO SHOULD ATTEND

All employees who are responsible for hazmat employee training; preparing/signing shipping papers; placarding; security; marking and labeling; packaging; loading and unloading of vehicles; and other activities that are regulated under the DOT hazmat regulations.

To run the event we will need a minimum of 10 people in attendance. Spread the word so we have a good attendance!

RCRA/DOT Hazardous Training –  SAVE THE DATE – Thursday, November 9, 2017  

Save Thursday, November 9, 2017  for our upcoming RCRA and DOT hazardous training class in South Central, WI.  Email us today at info@meriinc.com if you’d like to be added to the class list or fax us the registration form below.  

Training Opportunities Available
Attention Hospital and Medical Clinic Environmental Services, Facilities, Plant Operations or Safety Department Employees:

RCRA/DOT Hazardous Training

When: Thursday, November 9, 2017

Where: Madison Environmental Resourcing, Inc. 800 Uniek Drive, Waunakee, WI

Agenda: Check-In 8:30 a.m. – 9:00 a.m.

Class: 9:00 a.m. – 2:00 p.m.

Cost: $250 person. 

Continental Breakfast,  Lunch and Afternoon Beverages will be provided.

Register:  fax this  HAZTRAININGFORM  with the info below to  608-257-7656 by Monday, November 6. Or, email us with who will be attending at info@meriinc.com

Payment: Invoices and electronic payments available ahead of the training. Contact info@meriinc.com with each registrant’s name, organization and email address. Or, for the day of the conference, receipts will be available for checks (make payable to MERI) or cash.

Certification: Attendees will receive a certificate of completion after passing the course tests at the end of the day.

HAZARDOUS TRAINING COURSE DESCRIPTION

RCRA COMPLIANCE FOR HAZARDOUS WASTE GENERATORS OVERVIEW
(MORNING SESSION)
This RCRA compliance course is designed for large and small quantity generators. The Resource Conservation and Recovery Act (RCRA) requires that facility personnel be trained to “perform their duties in a way that ensures the facility’s compliance” with hazardous waste regulations.

DOT HAZMAT TRANSPORTATION OVERVIEW
(AFTERNOON SESSION)
Comprehensive training for shippers, handlers & transporters. Students will receive updates on regulatory changes and training in the use and application of the 49 CFR manual. Are you meeting hazmat training requirements? Every employee involved in shipping, transporting, or handling hazardous materials must receive training to be certified. Training should take place at least every 36 months. And, the training must take place whenever there is a regulation change affecting an employee’s job duties. Finally, all employees must be trained in hazmat compliance before performing hazmat activities in the workplace. This course will also provide train-the-trainer basics

WHO SHOULD ATTEND HAZARDOUS TRAINING

All employees who are responsible for hazmat employee training; preparing/signing shipping papers; placarding; security; marking and labeling; packaging; loading and unloading of vehicles; and other activities that are regulated under the DOT hazmat regulations.
– – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – –

ATTENDEE INFORMATION Fax registration form below by Monday, November 6  to 608-257-7656

Clearly write how the attendees would like their name to appear on their course completion certificate. They will receive it after they take their RCRA/DOT test on Thursday, November 9, 2017

NAME    ORGANIZATION          EMAIL            PHONE

_____________________________________________________

_____________________________________________________

_____________________________________________________

RCRA/DOT Hazardous Training –  SAVE THE DATE – Friday, May 19, 2017 

We know that you often have a lot to juggle so helping to make sure that you are compliant is one small way we can keep you and your staff safe.  That’s why we want you to save Friday, May 19  for our upcoming RCRA and DOT hazardous training class in the Madison, WI.  Email us today at info@meriinc.com if you’d like to be added to the class list or fax us the registration form below.  

Training Opportunities Available
Attention Hospital and Medical Clinic Environmental Services, Facilities, Plant Operations or Safety Department Employees:

RCRA/DOT Hazmat Training

When: Friday, May 19, 2017

Where: Meriter Business Center (2650 Novation Parkway, Madison, WI 53713)

Agenda: Check-In 8:30 a.m. – 9:00 a.m.
Class: 9:00 a.m. – 4:00 p.m.

Cost: $250 person. This is a MERI sponsored event

Companies who send 9 attendees will receive the tenth registrant for free
Continental Breakfast,  Lunch and Afternoon Beverages will be provided.

Register:  fax this  HAZTRAININGFORM  with the info below to  608-257-7656 by Monday, May 15. Or, email us with who will be attending at info@meriinc.com

Payment: Invoices can be sent and electronic payments made ahead of the training day. Contact info@meriinc.com with each registrant’s name, organization and email address. Or, for the day of the conference, receipts will be available for checks (make payable to MERI) or cash.

Certification: Attendees will receive a certificate of completion after passing the course tests at the end of the day.

COURSE DESCRIPTION

RCRA COMPLIANCE FOR HAZARDOUS WASTE GENERATORS OVERVIEW
(MORNING SESSION)
This RCRA compliance course is designed for large and small quantity generators. The Resource Conservation and Recovery Act (RCRA) requires that facility personnel be trained to “perform their duties in a way that ensures the facility’s compliance” with hazardous waste regulations.

DOT HAZMAT TRANSPORTATION OVERVIEW
(AFTERNOON SESSION)
Comprehensive training for shippers, handlers & transporters. Students will receive updates on regulatory changes and training in the use and application of the 49 CFR manual. Are you meeting hazmat training requirements? Every employee involved in shipping, transporting, or handling hazardous materials must receive training to be certified; training must take place at least every 36 months; and the training must take place whenever there is a regulation change affecting an employee’s job duties. All employees must be trained in hazmat compliance before performing hazmat activities in the workplace. This course will also provide train-the-trainer basics

WHO SHOULD ATTEND

All employees who are responsible for hazmat employee training; preparing/signing shipping papers; placarding; security; marking and labeling; packaging; loading and unloading of vehicles; and other activities that are regulated under the DOT hazmat regulations.
– – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – –

To run the event we will need a minimum of 10 people in attendance. Spread the word so we have a good attendance!

ATTENDEE INFORMATION Fax registration form below by Monday, May 15  to 608-257-7656
Please clearly note the following information for certificate at the end of the RCRA/DOT test completion on Friday, May 19, 2017

NAME    ORGANIZATION          EMAIL            PHONE

_____________________________________________________

_____________________________________________________

_____________________________________________________

MERI looks out for my hospital’s best interest. I like doing business with MERI because they are honest and trustworthy.”  

Gail Reichling, Housekeeping Supervisor, Upland Hills Health

Thank you, Gail, for your testimonial for what we do for you and your team at Upland Hills. We’re going to proudly add it to our growing list of testimonials.

Notes like these mean a lot to us, because we like to take care of our customers.

We’ve heard from many of you that our electronic manifests and customer portal have made reporting a lot easier. Hospital and surgical center administrators have also thanked us for helping them to be more sustainable, and reduce their waste numbers, by recycling their surgical blue wrap and repurposing their medical devices.

Because medical waste has its own ebb and flow, we’ll make it a priority to get you picked up, even if it’s not your scheduled date. Find yourself needing more containers and bags? No worries about going over an allotment. We’ll get them to you free of charge.

We’ll also help you save time and money by being your one source for picking up not only infectious waste, but also pharmaceutical and hazardous chemical waste, or universal materials like batteries, fluorescent light bulbs and medical devices.

We know that you often have a lot to juggle so helping to make sure that you are compliant is one small way we can keep you and your staff safe.  That’s why we want to have you save the date for our upcoming RCRA and DOT hazardous training class on October 11, 2016 in the Wisconsin Dells.  Email us today at info@meriinc.com if you’d like to be added to the class list.  

 SAVE THE DATE – TUESDAY OCT. 11, 2016 — RCRA AND DOT HAZARDOUS TRAINING

 

With increased enforcement, nursing home compliance is critical. MERI’s Free Infectious and Hazardous Waste Review Helps Midwestern Nursing Homes Quickly Assess if They Are Compliant. 

If a DNR inspector audited your nursing home today, would it pass with flying colors?

Skilled Nursing Administrators, Environmental Services and Compliance Officers take note: Proposed EPA rules and increased enforcement means it’s time for you to check if your facility has any compliance issues when handling and disposing its pharmaceutical and medical waste.

From previous reviews we’ve conducted, we’ve noticed many skilled nursing facilities are in non-compliance, especially when dealing with their pharmaceuticals. This is worrying for three reasons.

  • you could be faced with thousands of dollars in fines if audited,
  • you may inadvertently creating an unhealthy workplace, and
  • you could be unnecessarily polluting our water stream.

MERI (short for Madison Environmental Resourcing Inc.) is currently offering a FREE Nursing Home Compliance REVIEW for Midwestern Nursing Homes to help flag any potential compliance issues.

Our quick, 10-question survey can help you determine if your infectious, hazardous, pharmaceutical and universal wastes are being properly stored, collected, treated and disposed. We’ll also talk to you about how you document every step of your waste disposal process, from cradle to grave, and how quickly you can access your manifests.

Click here to email us with a time that works best for you to conduct the survey, or or give Lisa, Jim or Zac a call at 608-257-7652.

After the 20-minute conversation, we’ll review your answers and pull together a report with our findings shortly after. MERI will note where you may currently be out of compliance on issues that may put you at greater risk of fine. Our goal of doing this is to help you get these issues fixed before an inspector shows up at your door with a list of violations that could quickly add up to more $27,500 per violation/per day.

We’ve helped skilled nursing and assisted living facilities stay on top of changing regulations for more than 30 years. Licensed and owned by three major hospitals, MERI understands your world. As a not-for-profit, we know how important it is to be compliant and to keep your costs low, so that you can focus your financial resources on what’s truly important – focusing your resources on those you are caring for.

###

Mercury Reduction in Waterstream

Environmentally-Friendly Madison, WI Dentists Keep Amalgam — and Mercury — from Going Down the Drain

Throughout the country, it’s been estimated that dentists handle about one to two pounds of amalgam each year, mainly in the form of old silver-colored fillings removed from teeth. In Wisconsin, amalgam waste cannot be flushed down the drain due to regulations from local municipal wastewater authorities.  How do you dispose of amalgam compliantly yet cost-effectively? 

Before we get into inexpensive ways to properly dispose amalgam, here is a recap of why it can’t go down the drain.

What’s Wrong With Amalgam? 

The problem with amalgam is that it is about 50 percent mercury by weight. Even those with limited chemistry knowledge generally know one thing about mercury: It’s bad for the environment.

Once mercury enters the water stream, microorganisms convert it into methyl mercury – a highly toxic compound that then accumulates in fish, shellfish and any animals that eat them. This exposure rises straight to the top of the food chain, leading to methyl mercury exposure in humans.

EPA studies showed that, unless there was a large industrial source in a community, dental offices using silver amalgam were the single largest source of mercury discharged to Publicly Owned Treatment Works (POTW), accounting for nearly half of the mercury it received.

Madison Metropolitan Sewerage District (MMSD) in Wisconsin was one of the first municipal wastewater authorities in the state to regulate dental amalgam. By working with the local dental community, MMSD was able to significantly reduce mercury in its discharge. The dotted line represents the deadline for dental clinics in MMSD’s service area to install amalgam separators to capture amalgam from dental wastewater, preventing it from entering the sewer.However, changes like at MMSD can only be effective if dentists everywhere understand the importance of being good environmental stewards. 

It will likely not be as much of a problem in the future as dentists are switching from using amalgam fillings to safer alternatives, such as resin composites. But, since so many existing fillings may contain mercury, it could take a generation for amalgam fillings to fully disappear as a mercury source at dental clinics. 

Even if your local municipality does not currently have amalgam regulations, it’s possible that the Environmental Protection Agency will mandate all dentists to have special mercury collection devices in the next few years.

Disposing Your Amalgam Compliantly and Inexpensively

Many environmentally friendly dentists now have a chair-side vacuum line that collects large chunks of the alloy drilled out of teeth. The installation of filters or gravity separators remove 95% or more of the remaining amalgam in the sludge of water, saliva and other fluids suctioned out of a mouth.  This material is collected in a special trap or canister.

At MERI, we pick up amalgam from chair-side traps and mercury capsules, at the same time we pick up other hazardous waste from dental offices. Besides amalgam, MERI also collects hazardous materials like lead aprons, fixer, developer and pharmaceuticals such as Lidocaine.

Because MERI picks up hazardous materials at the time we are picking up sharps and other biohazard materials, there is no additional stop fee. 

Just give us a call ahead of time to make sure that the proper hazardous paperwork is prepared ahead of time before arriving to collect your amalgam or other hazardous materials.

If you’ve yet to find a compliant, inexpensive way to dispose of amalgam, give us a call!

###