In the eyes of the US EPA, a hospital is no different than any other industrial facility when it comes to hazardous waste regulations. However, hospitals are just as guilty as other hazardous waste generators when it comes to the proper disposal and treatment of hazardous waste.
The Atlanta VA Medical Center was recently fined $13,600 after inspectors discovered more than one ton of hazardous waste packed floor to ceiling in unsafe conditions.
According to the Atlanta Journal Constitution, "A portable building was stuffed so full of the hazardous waste that there was no room for inspectors to enter, much less firefighters or emergency equipment, an inspection report said."
There were also issues with containers of hazardous waste not being labeled properly.
Compliance with State and Federal regulations is critical. And, lack of understanding or knowledge of potential violations is not an adequate defense.
In order to help you, we have compiled a list of the top 10 most common hazardous waste violations that are found in hospitals.
1. Lack of or Improper Labeling of Hazardous Waste – This is often overlooked, but yet so important. Having containers of chemicals with no label or improper labeling is not only a safety hazard for your facility and employees, but also a hazardous waste violation. Hospitals that don't label their storage containers appropriately are cited for violation during inspection.
2. Improper or Failure to Perform Hazardous Waste Determinations – As hazardous waste generators, hospitals must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations. If you overlook this, you will be in violation of regulations.
3. Throwing Hazardous Waste down the Drain – This may seem like a no-brainer, but as we all know human beings are human. Short cuts can be tempting, especially if you are trying to cut costs. But chances are that you will get caught and it isn't worth it.
4. Inadequate or No Hazardous Waste Manifests – Unless you are a conditionally exempt small hazardous waste generator, a uniform hazardous waste manifest must be used for all hazardous waste shipments. It is not enough to just have someone else transport it out of your hospital, you must make sure that the proper paperwork is filled out or you are in violation.
5. Improper Management of Expired Hazardous Waste - Even expired waste is subject to the hazardous waste determination process. Hospitals often mismanage chemicals, and pharmaceuticals, which can lead to them being unused prior to their expiration date. These must also be disposed of properly.
6. Lack of a Contingency Plan – Hospitals are typically large quantity generators of hazardous waste and must have a contingency plan in place. A contingency plan sets out an organized, planned, and coordinated course of action that is to be followed in case of a fire, explosion, or release of hazardous waste which could threaten human health or the environment.
7. Inadequate or No Training of Employees in Hazardous Waste Management – Without adequate training, employees won’t know the regulations and proper ways to dispose of hazardous waste. Not only is inadequate training a violation in and of itself, but failure to properly train employees is the first step a hospital should take to prevent injuries and reduce exposure and liability.
8. Improper Consolidation of Hazardous Wastes from Nearby Facilities – You must use caution when consolidating wastes from other facilities and your own.
9. Improper Management of Mercury – All of these waste containing items could be handled as universal waste at a greatly reduced regulatory burden. They include, but are not limited to:
10. Infrequent or No Weekly Inspections of Hazardous Waste Storage Areas – Hazardous waste storage areas should be inspected every 7 days. It does not matter if you are a large or small quantity generator, weekly inspections means weekly.
As State and Federal Hazardous Waste Regulations get more and more restrictive in nature, the proper handling and disposing of hazardous waste materials is even more critical to a business operation’s success. Proper identification and labeling of hazardous waste, appropriate training of employees, and putting into place the correct contingency plans and procedures, will protect yourself and hospital from potential liability.