1

Conference Call with John Kelsey of Clean Harbors

Re: Hazardous Waste Management 

August 17, 2012

Participants:

John Kelsey, VP, Clean Harbors

David Metz, Industrial Economics (IEc)

Tripp Burwell, IEc

Patricia Kessler, DPRA

David Gustafson, DPRA

Questions from IEc and DPRA for Clean Harbors

1. Q: Can you describe the process of hazardous waste management from cradle to grave? 

What is involved in sorting?

A: There are mainly 2 different models utilized by hospitals, sorting and not sorting. For 

the sorting model, healthcare employees, including nurses, separate waste into different 

bins—black for hazardous waste, blue for non-hazardous waste, or purple for dual waste 

streams. Less than 1 percent of our clients choose the sorting solution, because it is more 

difficult for nurses. The non-sorting model has a few different options. The key

differences are the number of waste streams and container placement.

Almost 100 percent of our clients choose the non-sorting model. The majority do not 

want to sort because they want a simpler program for nursing as they believe that nursing 

cannot properly sort. With thousands of different drugs and hundreds to over 1,000 

healthcare employees involved in handling pharmaceutical waste, these customers 

realize, often through sorting pilots, that sorting at the point of generation is not feasible 

nor compliant They feel they are non compliant as hazardous drugs still make their way

into the non hazardous bins. Our non-sorting option focuses on the one-container model, 

which we have found to be market neutral (+/-10% lower/higher price than sorting). We 

have won many hospital contracts, several 25-30 hospital system contracts, and dozens of 

5-10 hospital system contracts on this one-bucket system. Our pricing for small facilities 

(i.e. physicians’ offices) is the same as for hospitals.

Container placement options include:

a) A locked box on the wall of patient rooms – the most rare option 

b) A workstation on wheels (WOWs or COWs) – options a) and b) together 

account for 2 to 5 percent of hospitals; these are easier options for nurses.

c) All waste is brought to a central repository (medication dispensing areas or 

soiled linen closets) with containers – approximately 95 percent of hospitals 

use this option.
2

Satellite storage areas each have an 18-gallon barrel with a liner inside to collect waste.

There is typically one satellite storage area per hospital wing per floor. We try to keep a 

ratio of 0.12 - 0.20 containers per bed per waste container, so we can have dozens per 

floor. A seven story hospital with four wings would have 28 generation areas, plus 

additional containers in pharmacy, OR, ED and other departments. Waste is then brought 

to a primary storage site (typically in the basement) where it is combined or sorted. Eight 

to ten 18-gallon barrels will fit into a 55-gallon drum, which will then go to the 

incineration facility. The 55-gallon drums are picked up on a weekly or monthly basis, 

ranging from 15 drums a month for smaller hospitals to 40 drums a week for larger 

hospitals. Smaller facilities (e.g., physicians’ offices) generally have one primary storage 

area, but no separate satellite storage areas, and have drums picked up on a quarterly or 

bi-annual basis.

Pharmacies will give us a copy of their formulary, so we will know which have various 

D, U, and P-listed waste codes. Some hospitals will separate out these different waste 

codes in order to remain an SQG (e.g., sorting out P-listed waste codes). About 0.5

percent of clients, DOT outliers, do sort, for inhalers. We have found that 95%+ percent

of aerosol hazardous waste is generated in pharmacies.

2. Q: What percentage of hospital waste comes from floor waste versus pharmacy waste?

A: This is an estimate, but I believe that pharmacy waste accounts for 10-20% of waste, 

and other departments (including the ER and OR) account for 80-90% of waste.

3. Q: Do hospital buy or rent barrels?

A: Hospitals buy these containers at the start of collection, often from Covidien, Becton 

Dickenson or Clean Harbors, and they experience about a 10 percent replacement rate per 

year (due to contamination or improper placement of medical waste into a container). 

Many hospitals don’t realize that they have cradle-to-grave liability.

4. Q: For RCRA-compliant hospitals, what percentage incinerate versus sewer? What 

percentage of physician’s offices/health clinics?

A: To be RCRA-compliant, all hospitals must incinerate RCRA waste nationally. In 

some states like California, all pharmaceutical wastes must be incinerated, including non 

hazardous. We have noticed an increase in incineration recently, as opposed to sewering

or placement with medical waste as more hospitals have started Pharmaceutical Waste 

programs.

5. Q: What are the average costs of hazardous waste incineration?

A: Our costs are below $1/pound for hazardous and non-hazardous waste or less than 

$2/pound for dual streams. 80 percent of our non-sorting clients pay between $155 and 

$225 per bed per year, for full cradle-to-grave service including the sorting, containers, 

labor, and transportation. WOWs, COWs, and in patient room collection have higher 

costs, because more labor is necessary to collect all the bins. On the low end, customers 
3

who on package RCRA Pharmaceutical Waste pay between $10 and $25 per bed per 

year. Customers who combine their hazardous and medical waste into a dual waste 

stream will pay more in the $500 to $800 range per bed, because they have more volume 

and dispose of the waste at a higher rate.

6. Q: Under current regulations, manifests require wastes codes – do incinerators use these 

waste codes to track emissions or make sure they don’t violate any regulations?

A: We are required by permit to look at this information. You have to look at the codes 

and know what you’re burning. Arsenic trioxide, a chemo drug of last resort, is the one 

pharmaceutical you have to separate out and make sure you don’t burn, although most 

hospitals do not have it. All waste is typically incinerated within 30 days of receipt at the 

hazardous waste incinerator. Note: there is no QA/QC of blue containers (nonhazardous), which go to medical waste incinerators as they are not RCRA regulated Part 

B facilities.

7. Q: How do hospitals typically manage primary and satellite storage sites?

A: The on-site storage areas for 18-gallon containers are considered satellite storage sites; 

there may be as many as 75 to 100 storage sites per hospital. These will be consolidated 

into one main area (typically the basement), which would be the primary storage site. 

Smaller facilities may not have satellite storage sites, their 18-gallon containers and main 

accumulation areas may be in the same section of the facility.

8. Q: How do hospitals conduct training under RCRA Subtitle C? Who is trained (e.g. 

nurses)?

A: The nurses typically get an awareness training program, where we will usually come 

in and train the trainer. We will spend 3-5 days onsite, rotating through shifts, to assist 

with that. We will also make sure that the hospital’s environmental services staff are 

trained to move containers from the satellite storage sites to the primary storage facility

(but not sort them).
4

Follow-up questions per e-mail from Industrial Economics on August 23, 2012

1) Does the $1 to $2 per pound incineration cost estimate include transportation and other 

costs?

The below $1 per pound for RCRA Pharma and below $2 per pound for Dual Waste does 

not include transportation and other costs. Those are variable based on options chosen as 

well as distance from local service center.

2) Does the 10 to 20 percent of waste that comes from pharmacies include pharmaceuticals 

sent to reverse distributors (i.e., for manufacturer credits)?

No, those are inventory items that are not included in this discussion. 

3) Do hospitals also purchase the 55-gallon drums to transport waste or are those included in 

the overall costs? If so, do you know how much those cost?

Yes, the hospitals do purchase the 55 gallon drums and they vary from $20-40 based on if 

they choose fiber or metal. 

4) Can you provide an estimate of the cost of sorting (excluding transportation and 

incineration), a) if the hospital sorts on its own and/or b) Clean Harbors sorts? (possibly

in terms of time in hours and materials) 

Generally it takes 15 minutes to properly sort an 18-gallon container. So from a labor 

standpoint 4 containers would be sorted in an hour. If each 18-gallon had 25 pounds of 

waste, that would be 100 pounds in an hour. Based on a fully loaded employee of a 

hospital at $25 per hour, that would be $0.25 per pound. Based on a contractor employee 

that is at $50 an hour that would be $0.50 per pound.