CHSP Environmental Safety and Waste Management — Questions and Answers
Question 1: Under EPA regulations, a healthcare facility that generates between 100 kg and 1,000 kg of hazardous waste per calendar month is classified as a:
- Very Small Quantity Generator (VSQG)
- Small Quantity Generator (SQG) (Correct answer)
- Large Quantity Generator (LQG)
- Conditionally Exempt Small Quantity Generator (CESQG)
Correct answer: Small Quantity Generator (SQG)
EPA's generator classification thresholds under RCRA are: VSQG ≤100 kg/month, SQG 100–1,000 kg/month, and LQG >1,000 kg/month. Generator status determines storage time limits, emergency planning requirements, and manifest obligations. CESQG is the old term replaced by VSQG under the 2018 Generator Improvements Rule.
Question 2: Regulated Medical Waste (RMW) in a hospital must be tracked using a manifest system in most states primarily because:
- OSHA requires manifests for all biohazardous materials leaving the facility
- State environmental agencies require documentation of RMW from point of generation to final disposal (Correct answer)
- The CDC mandates manifests to prevent infectious disease outbreaks
- The Joint Commission requires manifest documentation for accreditation
Correct answer: State environmental agencies require documentation of RMW from point of generation to final disposal
Regulated Medical Waste tracking (manifests/tracking forms) is required by state environmental agencies — not OSHA, CDC, or TJC — to ensure a documented chain of custody from generator to licensed treatment and disposal facility. While OSHA regulates occupational exposure to bloodborne pathogens, it does not mandate RMW manifests.
Question 3: A hospital pharmacy is disposing of unused chemotherapy drugs. These pharmaceutical wastes are BEST classified and managed as:
- Regulated Medical Waste disposed of in red biohazard bags
- RCRA P- or U-listed hazardous pharmaceutical waste requiring proper manifesting and licensed disposal (Correct answer)
- Solid waste that can be disposed of in regular trash if the containers are empty
- Universal waste eligible for the streamlined universal waste management standards
Correct answer: RCRA P- or U-listed hazardous pharmaceutical waste requiring proper manifesting and licensed disposal
Most antineoplastic (chemotherapy) drugs are listed RCRA hazardous wastes (P- or U-listed) and must be managed under full RCRA hazardous waste regulations, including manifesting and disposal at a licensed facility. They cannot go in red bags (RMW pathway), regular trash, or universal waste streams. EPA's 2019 Pharmaceutical Hazardous Waste Rule formalized this pathway.
Question 4: Which regulatory framework primarily governs the use, storage, and disposal of radioactive materials used in nuclear medicine departments?
- OSHA 29 CFR 1910 Subpart Z (Toxic and Hazardous Substances)
- EPA Resource Conservation and Recovery Act (RCRA)
- Nuclear Regulatory Commission (NRC) 10 CFR Parts 19, 20, and 35 (Correct answer)
- Department of Transportation (DOT) 49 CFR Parts 171–178
Correct answer: Nuclear Regulatory Commission (NRC) 10 CFR Parts 19, 20, and 35
The NRC (or Agreement State equivalent) regulates radioactive materials in healthcare under 10 CFR Part 35 (Medical Use of Byproduct Material), Part 20 (Standards for Protection Against Radiation), and Part 19 (Notices, Instructions, and Reports to Workers). OSHA, EPA RCRA, and DOT play secondary roles in occupational protection and transport, but the NRC is the primary regulator for use and disposal.
Question 5: During an environmental rounds inspection, a healthcare safety professional notices sharps containers that are three-quarters full but have not been picked up for exchange. The MOST immediate concern is:
- Regulatory non-compliance with TJC storage time limits for regulated medical waste
- Increased risk of needlestick injury to staff forced to compress or overfill containers (Correct answer)
- Violation of EPA pharmaceutical waste storage requirements
- Failure to meet NFPA 101 occupancy load requirements
Correct answer: Increased risk of needlestick injury to staff forced to compress or overfill containers
Overfilled sharps containers are a direct, immediate occupational safety hazard — needlestick injuries significantly increase when containers are compressed or overfilled. OSHA's Bloodborne Pathogen Standard (29 CFR 1910.1030) requires containers to be replaced before they reach the fill line. Regulatory non-compliance is also a concern, but the immediate patient/worker safety risk from needlestick exposure ranks highest.
Question 6: A healthcare facility's spill of a mercury-containing sphygmomanometer in a patient room requires response under which primary framework?
- OSHA Hazard Communication Standard (HazCom) — update the SDS file
- EPA mercury reduction guidelines and state environmental notification requirements if the spill exceeds threshold quantities (Correct answer)
- NFPA 472 — treat as a flammable liquid spill requiring fire department notification
- CDC guidelines for bloodborne pathogen exposure control
Correct answer: EPA mercury reduction guidelines and state environmental notification requirements if the spill exceeds threshold quantities
Mercury is a toxic heavy metal regulated by EPA under RCRA and by many states as a reportable hazardous substance. Even small mercury spills require proper cleanup with specialized equipment (mercury vacuum, not a regular vacuum) and may require state environmental notification if they exceed reportable quantities. It is not a bloodborne pathogen, not flammable, and updating an SDS is not the primary response action.
CHSP Environmental Safety and Waste Management
Under EPA regulations, a healthcare facility that generates between 100 kg and 1,000 kg of hazardous waste per calendar month is classified as a: