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🧠 How to Determine the Right Waste Type and Disposal Service for Generators

Learn step-by-step how waste generators can identify waste types, assess volume, and choose compliant mail-back or pickup disposal services.

Updated over 2 months ago

🔎 Step 1: Waste Identification

Proper waste identification is the foundation of compliance. This includes:

A. Classify the Waste Type

Identify what kind of waste is being generated. The most common regulated waste types include:

Waste Type

Examples

Key Regulations

Medical/Regulated Waste

Sharps, red bag waste, cultures

OSHA 1910.1030, DOT, state health departments

Pharmaceutical Waste

Expired meds, chemotherapy agents

DEA, EPA Subpart P, RCRA

Hazardous Waste

Solvents, corrosives, ignitables

EPA (RCRA), DOT

Universal Waste

Batteries, lamps, mercury devices

EPA Universal Waste Rule

Household Hazardous Waste (HHW)

Paints, cleaners, aerosols

Local solid waste authority rules

B. Determine If the Waste is Regulated

Use the EPA hazardous waste determination process (40 CFR 262.11) or relevant medical waste rules to classify:

  • Is the waste infectious, hazardous, pharmaceutical, or sharps?

  • Is it regulated by OSHA, RCRA, DEA, or state/local authorities?

PureWay offers tools like waste stream analysis and regulatory consultation to help with this step.


🏢 Step 2: Site Risk Assessment

Evaluate the risk and exposure potential at the generation site:

  • Is the waste generated by employees, patients, or residents?

  • Are workers at risk of bloodborne pathogens exposure?

    • If yes, OSHA’s Bloodborne Pathogens Standard (29 CFR 1910.1030) applies.

  • Are pharmaceutical controls or drug diversion risks present?

    • DEA compliance may be needed (especially for controlled substances).

  • Does the site lack regular waste pickups?

    • Consider storage safety, spill potential, and volume overflow risks.

PureWay provides onsite compliance evaluations to assist with exposure control and service planning.


⚖️ Step 3: Volume Assumptions and Waste Generation Frequency

Understanding the quantity and frequency of waste generation helps narrow down the service type:

  • Low-Volume Generators:

    • Small clinics, dentists, tattoo studios, home healthcare

    • Typically produce <50 lbs of regulated waste per month

  • Medium/High-Volume Generators:

    • Hospitals, nursing homes, large labs, vet clinics

    • Generate waste daily or weekly, including multiple waste streams

Document:

  • Types and quantity of each waste stream

  • Frequency of generation (daily, weekly, monthly)

Use this to calculate storage capacity needs, container sizes, and service intervals.


♻️ Step 4: Select a Waste Disposal Method

Option A: Mail-Back Service

Best for: Low-volume, remote, or small generators

Advantages:

  • Fully compliant, pre-labeled systems (UN3291 for medical waste)

  • No DOT registration or manifesting required by the generator

  • No minimum pickup volume or contract

  • Convenient for home health, small clinics, residential sharps users

PureWay’s Mail-Back Benefits:

  • Systems for sharps, red bag waste, pharmaceuticals, and DEA-controlled substances

  • Prepaid return shipping via USPS

  • Includes waste tracking documentation and manifests

  • OSHA-compliant sharps containers

Option B: Contracted Hauler (Pickup Service)

Best for: High-volume, complex waste streams, or facilities requiring frequent service

Advantages:

  • Scalable for large volumes

  • Can handle multiple waste types under one provider

  • Often includes manifests, container supply, and documentation support

PureWay’s Pickup Service Benefits:

  • Scheduled pickups for regulated medical waste, hazardous waste, and universal waste

  • Full-service documentation and compliance management

  • Custom service frequencies and staff training options

  • Supports RCRA and Subpart P compliance


📄 Summary: Key Considerations

Criteria

Mail-Back

Contracted Pickup

Volume

Low

Medium to High

Frequency

Infrequent

Regular

Location

Remote, residential, or small site

Commercial, large facilities

Waste Types

Sharps, small RMW, non-controlled meds

All types, including bulk and hazardous

Regulatory Simplicity

High

Requires more oversight (DOT, manifests)


🔖 Final Notes

  • Ensure all staff are trained in OSHA Bloodborne Pathogens Standard if handling RMW.

  • Controlled substances must be handled per DEA destruction rules.

  • EPA generator status (e.g., CESQG, SQG, LQG) influences hazardous waste options.

👉 For a state-specific compliance guide, visit PureWay’s interactive map: 🔗 https://www.pureway.com/resources/map-temp

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