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- Any non-pharmaceutical hazardous waste generated by a healthcare facility must still be managed under the hazardous waste generator regulations.
A healthcare facility should first count up all of its hazardous wastes, including hazardous waste pharmaceuticals. If the facility generates below all of the very small quantity generator (VSQG) limits, then it is not subject to Subpart P, except for the ban on dumping pharmaceutical wastes into the sewer and the empty container standards.
If, however, the facility generates above the VSQG limits, then the healthcare facility is subject to the provisions in Subpart P for its hazardous waste pharmaceuticals.
Any non-pharmaceutical hazardous waste generated by a healthcare facility must still be managed under the hazardous waste generator regulations at 40 CFR Part 262.
At this point, the healthcare facility should count up its non-pharmaceutical hazardous waste to determine its hazardous waste generator category, but it does not need to include any pharmaceutical waste in the determination. In other words, a healthcare facility managing its hazardous waste pharmaceuticals under subpart P does not have a generator category for the hazardous waste pharmaceuticals, but it will be a VSQG, small quantity generator (SQG), or large quantity generator (LQG) for its non-pharmaceutical hazardous waste.
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