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Waste Manifest should have two waste codes; one of which should be an EPA Hazardous <br />Waste Number, the other code should be the appropriate California Waste Code. The State <br />Waste Code 311 should be applied only to such RCRA hazardous wastes having an organic <br />chemical composition — not to inorganic RCRA hazardous wastes (e.g., P012/141 hazardous <br />waste). (It should be noted that although DTSC utilizes its information data systems to register <br />medical waste transporters and to store medical waste manifest data, the use of these systems <br />should not be construed as meaning that these manifested "medical wastes" are "hazardous <br />wastes.") <br />Finally, generators may self -declare one or more of their wastes as hazardous wastes. If they do <br />so, the wastes must be managed in accordance with all applicable laws and regulations for <br />hazardous wastes. As can be seen from the above, DTSC regulates (as hazardous wastes) only <br />"RCRA hazardous waste" pharmaceutical wastes. Therefore, if a generator self -declares their <br />pharmaceutical wastes to be hazardous wastes, the generator must do so by declaring the waste <br />to be RCRA hazardous waste; and acting accordingly, they must then assign both an EPA <br />Hazardous Waste Number and an applicable California Waste Code to the wastes. <br />Summary: <br />The California Medical Waste Management Act's definition of pharmaceutical waste excludes <br />items that are regulated by RCRA. A Generator may self -declare one or more of their wastes as <br />RCRA hazardous and manage those in accordance with all applicable laws and regulations. <br />Within the state of California, DTSC regulates only "RCRA hazardous waste" as hazardous <br />waste, so the generator could declare the waste to be RCRA hazardous and act accordingly by <br />assigning both an EPA Hazardous Waste Number and an applicable California Waste Code. The <br />result would be that non-RCRA pharmaceutical wastes would be combined into the existing <br />hazardous waste pharmaceutical profile and managed as RCRA hazardous, shipping on a <br />Uniform Hazardous Waste Manifest. <br />