Question 1

What waste management documentation do AAAHC surveyors review?

Accepted Answer

AAAHC surveys assess whether your facility properly segregates, labels, stores, and disposes of all waste categories. Surveyors typically review waste management policies, staff training records, manifest documentation from your licensed transporter, and pharmaceutical disposal certificates. Exodus provides all required manifests and certificates.

Question 2

How is chemotherapy waste classified in ambulatory surgery centers?

Accepted Answer

Trace chemo waste (gloves, drapes, IV bags with residuals from non-RCRA-listed drugs) is typically treated as biohazardous regulated medical waste. RCRA P-listed chemo drugs (e.g. cyclophosphamide, mitomycin) must be disposed of as RCRA hazardous waste. Exodus classifies each waste stream correctly and maintains separate disposal chains.

Question 3

Can ASCs dispose of propofol as regular pharmaceutical waste?

Accepted Answer

Propofol is not DEA-scheduled but contains preservatives that may make it RCRA hazardous. Unused propofol should be treated as pharmaceutical waste and disposed of through a licensed pharmaceutical waste program — not poured down drains, which violates the EPA Pharmaceutical Waste Rule.

Question 4

How are sharps handled between procedures in an ASC?

Accepted Answer

Sharps must be placed in puncture-resistant, leak-proof containers at the point of use — on the surgical field or in the OR immediately following use. Containers should be exchanged when ¾ full and never moved once sealed. Exodus provides properly labeled containers in appropriate sizes for OR environments.

Question 5

Do ASCs need to file a biennial RCRA hazardous waste report?

Accepted Answer

SQG and LQG generators must file biennial reports. Most ASCs qualify as VSQGs or SQGs for pharmaceutical RCRA waste. The EPA Pharmaceutical Waste Rule introduced the "healthcare facility" designation — an Exodus specialist can assess your generator status and reporting obligations.

Surgery Center Medical Waste Disposal Florida