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.


  • 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


infectious waste

It’s time to report your 2018 infectious waste numbers to the WI DNR. You can access the link here.  March 1, 2019 is the deadline to submit your Wisconsin facility’s 2018 infectious waste numbers.

For those who generated more than 50 lbs. of sharps and medical waste in a calendar month during 2018, this task should go more quickly now that the WI DNR has automated the process. If you did one before, a lot of the electronic fields will already be filled in for you. Be sure to check them and make any necessary changes.

Does your healthcare facility need to file an infectious waste annual report?

State law requires businesses and institutions to separate and manage infectious waste safely. It requires hospitals, clinics and nursing homes to implement plans to reduce medical waste. To verify compliance with these requirements, infectious waste generators must file a report regarding waste sent off-site for infectious waste treatment. This is also know as the “Off-site Treatment Report.” In addition, hospitals, clinics and nursing homes must file the “Medical Waste Reduction Progress Report.” The DNR’s infectious waste annual report combines both reports in the same online form.

To determine whether your facility must file the infectious waste annual report, go to dnr.wi.gov and search “infectious waste.” If you have questions, please contact Ariana Mankerian (608-266-6965).

MERI makes it easy to pull your infectious waste numbers

MERI customers can quickly get their numbers by using the online portal.  All you have to do is:
1)   log into: https://merigenesis.com
2)   Type in your customer ID (if you can’t remember it, just give us a call and we can remind you what we have on file)
3)   Enter your password. Can’t remember it? Don’t worry. You can create a new one. Just click on the green button and follow the instructions in the email that will come your way.

If you are a generator of infectious waste in Wisconsin and have not yet received an email from the DNR notifying you of instructions to ensure everything gets filed correctly, be sure to email them at DNRMedicalWaste@wisconsin.gov. This is especially important if your facility has a new contact person.


infectious waste

Are you wondering if it’s time to file your WI DNR Infectious Waste Report? Or even if you need to file this year?

The Wisconsin Department of Natural Resources’ Infectious Waste Report applies to all Wisconsin infectious waste generators. It’s not just for medical facilities, such as hospitals, clinics or nursing homes. It verifies that both generators and treatment facilities throughout the state are in compliance with regulatory manifesting requirements.

If your Wisconsin location(s) shipped 50 pounds or more of medical waste to an infectious waste treatment facility in one or more months during the calendar year, you will need to complete the Wisconsin Department of Natural Resources Infectious Waste Report.

This Infectious Waste Off-Site Treatment report is the first of an annual two-part electronic document within the WI DNR annual Infectious Waste Report. Only hospitals, clinics and nursing homes should complete the second part of the annual filing, also known as the medical waste reduction progress report.

Are You Exempt?

Not sure if you have to file either one or both of documents in the annual WI DNR Infectious Waste Report?

Use this handy worksheet to determine if you are exempt from having to file the infectious waste report with the Wisconsin Department of Natural Resources.

Even if you don’t file an infectious waste report, according to WI DNR Annual Reports Exemptions and Records  you should keep on file any of the following:

  • Your infectious waste manifests or records of waste sent off-site for treatment (hospitals, clinics and nursing homes must retain for five years, all others for three years).
  • Your certificates of destruction or treatment (hospitals, clinics and nursing homes must retain for five years, all others for three years).
  • Logs of the amounts sent off-site for treatment and the destination facility.
  • Logs of the amounts generated.
  • Records related to on-site treatment (see s. NR 526.12, Wis. Adm. Code).

Being Exempt In Past Doesn’t Reflect Your Future

Veterinarians, dentists, acupuncturists, tattoo artists, laboratory researchers, manufacturers and small businesses, take note: Just because you may have been exempt from filing the WI DNR Infectious Waste Off-Treatment Report in the past, it doesn’t mean you will be this year — especially if your facility expanded, or had an incident, and generated more medical waste.

Wisconsin funeral home directors also should be aware that they might need to file.  While the WI Regulation’s NR 526.04(5) states: Human tissue that is interred or cremated on site is exempt from reporting”, this doesn’t mean that you are exempt as you may have sharps or other infectious waste.

Just ask yourself: Did 50 pounds or more of infectious waste get removed from my premises during the calendar month? If you answered YES, then an infectious waste off-site treatment report must be filed.

Note that 50 pounds is not an average monthly total in any a calendar year. Whenever 50 pounds or more is removed from the premises for treatment elsewhere, during any month during the calendar year. This is according to manifests, shipping papers or other records.

The DNR has a great list of what is and isn’t infectious waste. You can find it this guide, Basic Infectious Waste Requirements for Generators of Small Amounts.

Medical Waste Reduction Plan

Funeral homes and smaller infectious waste generators are exempt from completing the second part of the Infectious Waste Off-Treatment Report, also known as the medical waste reduction plan.

However, hospitals, clinics and nursing homes will likely have to complete the medical waste reduction plan. This addressees not only previous waste management practices, but also strategies being put into place to reduce your future waste production. The plan needs to be reviewed annually and updated at least every five years.

WI DNR Infectious Waste Report Date

An electronic version of the DNR’s Infectious Waste Annual Report form, first launched in late 2015, asked all generators to submit their infectious waste numbers for 2014.

In 2017, the Wisconsin DNR hopes to catch up by asking for 2015 numbers. Then, shortly after that, 2016 numbers, in order to get everyone up to date, according to Barb Bickford, WI DNR’s Medical Waste Coordinator.

Bickford did not specify a date when the upcoming filing of 2015 numbers will take place.  Backend testing is currently taking place. However, once it goes live, the process should be quicker for repeat filers.

She noted that those who submitted in the past should automatically get an email notifying them when it’s time to file the report. You an also check the DNR’s reporting web page for updates at http://dnr.wi.gov/topic/HealthWaste/IWReport.html

If you’ve had changes in your staff, your facility has changed its name or has a new owner, or if you think that you might need to file for the first time, you should notify the DNR at: dnrmedicalwaste@wisconsin.gov. This will avoid delays of the correct person being notified. And, will save future typing. You won’t have to change pre-populated information.

Reports will be due six weeks from the DNR’s release date.

We’ll Keep You Informed

MERI will keep you informed once the WI DNR’s reporting feature is available.

Our handy customer portal keeps track of your infectious waste numbers and makes it easy to retrieve the information you need to file your reports quickly.

This software allows you to:

  • Retrieve manifests that include cradle-to-grave documentation of infectious waste.
  • Receive a report detailing the total weight of treated waste over a specific date range.
  • Update your contact information.

We’ve already sent every MERI customer a link to the portal along with the required password. If you’re having trouble accessing the portal, please contact us by phone or email and we’ll be happy to assist you.

# # #

It’s time for infectious waste producers to file their annual report(s)

MERI’s online customer portal helps you to easily retrieve info needed for your 2014 WI DNR Infectious waste annual report – due by 11:59 p.m. on Jan. 22, 2106.

The Wisconsin Department of Natural Resources 2014 Infectious Waste Annual Reporting is now OPEN!

This is the first time the DNR is requiring infectious waste generators to submit their reports online.  This process must be started – and, if possible, all information inputted – by January 22, 2016 at 11:59 p.m.

By now, you should have received an email from the DNR notifying you of instructions to ensure everything gets filed correctly and on time.  If not, Please email DNRMedicalWaste@wisconsin.gov. Also, follow this link to inform the DNR if your facility has a new contact person or to make changes to the existing contact.

Who Needs to File Infectious Waste Report

If your business or institution generates infectious waste, you may need to file one or two different reports to the DNR: A Medical Waste Reduction Plan and/or an Infectious Waste Annual Report. Whether you need to file one or both reports depends on the type/amount of waste you produce and your disposal techniques.

In our earlier post we outlined how you can determine whether you are exempt or need to file. We also included some tips to walk you through when creating a waste reduction annual plan and an infectious waste annual report.

Easy Way for MERI Customers to Get Needed Info

MERI’s online customer portal makes it easy to retrieve the waste information you need to file your reports quickly. This software allows you to:

* Retrieve manifests that include cradle-to-grave documentation of infectious waste.

* Receive a report detailing the total weight of treated waste over a specific date range.

* Update your contact information.

We’ve already sent every MERI customer a link to the portal along with the required password. If you’re having trouble accessing the portal, please contact us by phone or email and we’ll be happy to assist you.

Still Have Questions About Your Infectious Waste Report?

If you have any questions about filing your reports in general, please contact the Wisconsin’s DNR website, which provides a full list of requirements and exemptions for filing both reports.

Learn how to easily track, properly handle, and affordably dispose your biohazard or infectious waste.

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Infectious Waste Compliance Guide