Rethinking Management Practices for Hazardous Waste in Healthcare

Recent federal Resource Conservation and Recovery Act (RCRA) hazardous waste regulation changes are increasing the regulatory oversight and scrutiny of the healthcare and hospital industry. Accompanying this additional regulatory scrutiny is an increase in the environmental risks this industry is facing. Since every hospital facility or healthcare campus is a hazardous waste generator, knowing the environmental compliance requirements your facility or campus is subject to is important but unfortunately very complicated given the hundreds if not thousands of wastes and waste streams generated.  In addition, your facility is also subject to state and sometimes local government hazardous waste regulations which are often more stringent than the federal RCRA rules. Sorting through and understanding these regulations and the corresponding hazardous waste program compliance requirements is step number one in minimizing the environmental, legal, financial and other risks inherent in being a hazardous waste generator. Given the nature and complexity of these
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The Most Common Hazardous Waste Management Mistakes and How to Avoid Them

Hazardous waste management mistakes are unfortunate, can amount to costly fines, and lead to a tarnished reputation in your community. Fortunately, hazardous waste management mistakes are avoidable. The following errors are a few of the most common violations noted during inspections: 1. Improper Container Labeling Improperly labeling hazardous waste containers can create an unsafe workplace and lead to costly fines. Knowing how to label containers correctly and how to identify waste management mistakes will help your facility stay in compliance and help prevent workplace accidents. The identification and labeling of waste containers notify individuals who may encounter container of its contents and associated hazards. 2. Open Containers Waste containers that are not correctly closed, latched, or sealed are not only a RCRA violation but a workplace safety hazard. Ensuring that employees are trained on the container closure requirements and immediately addressing open containers will keep your facility/site safe and prevent costly
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What is Air Quality? Definitions and Pollution Sources

Earlier this year, a very interesting New Yorker article was published regarding the air pollution commonly found in homes.  The article provided details about an indoor air quality study conducted in a ranch house on the engineering campus of the University of Texas at Austin.  This study prompted discussion amongst several W&M staffers about the different terminology and services related to ‘air quality’ that happens at W&M and how it can be very confusing to differentiate between each type if you aren’t “in the business”! Depending upon the goal of a project, the term ‘air quality’ may or may not be technically correct and it has different meanings depending upon the specifics of the project being requested.  W&M offers many different services to its industrial, oil & gas, education, and real estate clients, and each of these business sectors requires different types of ‘air quality’ support.  Industrial compliance is one
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Cleaning Up Your Act: Key Determinants in Successful Spill Response

What words come to mind when you hear the word spill? Emergency, disaster, mistake, and dangerous may be among the first few, and there isn’t much to think about positively. However, with proper spill prevention preparation, no matter how big or small the event, the spill response can be cost and time-efficient. Nobody wants to believe their company could be the next victim of an environmental spill or release, but the unexpected is always possible. If your company has plans in place to mitigate potential threats, instill safety, and identify appropriate preparation from the beginning, it can reduce the possibility of an unfortunate spill event. WHAT IS THE FIRST STEP IN MITIGATING SPILLS? Make sure they don’t happen. I know, it sounds obvious. It is certainly easier said than done but preventing spills from happening is the best line of defense. One of the best ways to foster prevention strategies
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Are you an Industrial or Hazardous Waste Generator?

The EPA recently issued an update to the hazardous waste generator regulations under Resource Conservation and Recovery Act (RCRA). This update provides greater flexibility in how hazardous waste is managed and closes gaps in its regulation. Improvements include provisions for episodic generation, name change (and options) from CESQG to VSQG, and other changes. Understanding Regulatory Changes Keeping up to date with these changes is an important part of environmental compliance. Consider the following real-life example: Recently, W&M Environmental was contacted by a local business requesting help with waste compliance issues documented during an unannounced regulatory inspection. The inspector noted multiple alleged violations related to improper hazardous waste management and incomplete waste disposal recordkeeping. Upon review, W&M discovered that the facility had been improperly coding their waste and was erroneously documenting universal wastes as hazardous wastes. The business was under the assumption that their facility was a small quantity generator (SQG)
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Options & Tools Available in Addressing Historical Site Contamination Issues

Once you have documented your property is contaminated, what are your options? Once you receive that Phase II Investigation report that shows your property has some contamination issues, don’t panic yet. Everyone has heard the horror stories about millions spent on cleaning up site contamination that occurred half a century ago. Fortunately, we have come a long way in understanding behavior, fate and transport of chemicals in the environment.  Additionally, site cleanup decisions are almost entirely risk-based, meaning contaminated soil does not need to be remediated to background conditions, and groundwater does not always require treatment to potable water standards. In Texas, most contaminated sites are subject to the technical regulations under the Texas Risk Reduction Program (TRRP) or the Petroleum Storage Tank (PST) rules. Both of these programs have evolved in pragmatic ways to rely heavily on evaluating individual exposure pathways and requiring response actions only for those pathways
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How to Plan for (and Survive) an Unexpected Spill or Release

The thought of having a spill, release, overflow, or explosion at a facility is always in the back of our minds, but we never genuinely expect it to happen.  Despite the best precautions, accidents happen, systems fail, and employees and facilities need to be prepared.  Time is of the essence during the initial stage of a disaster, and the first 24 hours of the response can change the outcome of the project dramatically.  Are your employees trained and are your facilities outfitted for when that disaster occurs? Emergency response, spill response, and rapid response teams are critical pieces to be included in preparation for a potential spill or disaster. For oil and gas facilities, metal manufacturing facilities, and even food manufacturers, an unexpected spill or disaster could occur at any moment.  Several regulatory agencies govern spills or discharges in Texas and across the United States.  However, what they all have
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The Heat Is On – So Be Cool and Stay Safe

We are few weeks into summer and it’s time to remind your workers about the hazards of heat stress and how to protect themselves from it.  Heat-related injuries can be avoided if workers and supervisors are properly trained and know the symptoms and actions to take. There are many factors that can cause or contribute to heat-related illness.  Here are just a few: High temperature and humidity, Low fluid consumption, Direct sun exposure or extreme heat, Limited air movement, Increased or excessive physical exertion, Bulky protective clothing or equipment, Health problems, Some medications, Pregnancy Failure to acclimate to hot workplaces, and Previous heat-related illness. There are four primary health issues that are caused by heat exposure.  Here are the most dangerous with a brief explanation of the signs or symptoms and actions to take should the symptoms manifest themselves. Heat Rash is the most common heat-related illness in hot work environments. 
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Don’t Be Another Viral Video…Have Inspections!

June is National Safety Month so we’re highlighting another safety area you and those in your facility should be mindful of. Most EHS professionals have seen videos of catastrophic mobile crane and construction crane failures.  While not as visually impressive, the results of bridge/jib crane or sling failures can be just as damaging. You probably don’t have time to verify all of the OSHA inspection items for cranes and slings during an area tour.  However, there are a few items which can be visually checked quickly and easily, and most workers can be trained to perform these routine inspections of bridge/jib cranes and slings.  These visual assessments can help keep employees safe. While you are inspecting your facility make sure that your overhead/jib cranes inspections are addressing the following: The load rating of the overhead bridge/jib crane must be marked on both sides. The controls on the pendant or remote
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Listen Up: Protecting Your Workers from Hazardous Noise

Noise is one of, if not the most common workplace hazard. OSHA reports that at least 22 million workers are exposed to damaging noise at work each year. Not only can noise permanently damage an employee’s hearing, but it is generally very costly for employers to pay compensation claims for occupational hearing loss. For those reasons, the Occupational Safety and Health Administration (OSHA) mandates that employees exposed to a time-weighted average (TWA) of 85 decibels A-weighted (dBA) for an 8-hour shift shall be put into a hearing conservation program as lined out in 29 CFR §1910.95.  At W&M, we help employers evaluate their high noise exposure areas, monitor employee exposure, develop hearing conservation programs, and help with regulatory compliance. While in the field, we have noticed a common problem with noise monitoring activities conducted by employers. Many employers like to do their own noise monitoring, which is a viable option that
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