Regulatory Changes Impacting Healthcare Hazardous Waste Generators

When the Resource Conservation and Recovery Act (RCRA) was initially signed into law in 1976, it largely and rightly focused on the generally easily distinguishable chemical wastes generated by industrial facilities.  Where most waste streams generated by the average industrial facility are predictable, those from hospitals and healthcare facilities are far more varied in type and amount. Additionally, the protocol for identifying, managing and disposing of them properly can be especially complex. To help address the complexity of these regulatory compliance requirements for one particular hospital and healthcare facility waste stream — pharmaceuticals — the United States Environmental Protection Agency adopted on August 21, 2019, the Management Standards for Hazardous Waste Pharmaceuticals.   Below are just a few of the major changes taking effect that are intended to provide greater clarity and consistency in managing hazardous waste pharmaceuticals across states: Waste Determinations Hazardous waste pharmaceuticals are generated by many different employees
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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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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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Is Your Hospital Campus Complying with RCRA Hazardous Waste Regulations?

  • RCRA Hazardous Waste Regulations for Hospitals
    October 24, 2019
    11:30 am - 12:30 pm

Hospitals generate thousands of unique wastes and waste streams and leaders often struggle with meeting regulatory compliance requirements related to RCRA Hazardous Wastes. Often systemic issues are only uncovered during a government agency compliance inspection or a waste or chemical management incident. Since no single department typically is responsible for waste management, hospital risk management, (more…)


Streaming From, Allen, Texas, 75002, United States

TRI and P2 APR – Successfully Closing Out This Reporting Season

March reporting deadlines are still on the horizon. While you still have time, watch our uploaded January webinar and review our slides to assist in your first round of reporting. While you’re still finalizing your March reports, be mindful of the July 1st TRI and P2 Annual Progress Report just around the corner. We will host a live lunchtime webinar on March 28th to help you prepare for report requirements, report submittal and best methods for reducing waste and TRI releases. Texas’ Waste Reduction Policy Act of 1991 was adopted to prevent pollution in Texas. The Texas Commission on Environmental Quality (TCEQ) adopted the corresponding rule under 30 TAC 335 Subchapter Q, which requires small and large quantity generators of hazardous waste and TRI reporters to prepare a five-year P2 Plan and submit an Executive Summary of the plan to TCEQ. Large quantity generators and TRI reporters are also required
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VA Pharmacy Waste Program

The Veterans Administration (VA) contracted with W&M Environmental through it's GSA Schedule Contract to review the Pharmacy Waste Program of the Dallas VA Hospital. Pharmacy waste is a growing problem in the US and proactive organizations, such as the VA, have begun to implement programs to eliminate improper disposal of hazardous pharmaceuticals. W&M reviewed the current plans and processes and developed an implementation plan that meets the national VA and EPA directives, while at the same time saving the Dallas VA hospital a significant amount of money in disposal costs.

Houston Registration – Hazardous Waste Mangement Training

When:    Wednesday, October 1, 2014 Where:   Bay Oaks Country Club 14545 Bay Oaks Blvd., Houston Price:     $495 before August 31 $550 after September 1 Registration includes:  Training materials, breakfast, lunch buffet, and afternoon snack will be provided.

EPA reports that Wal-Mart admits violating Hazardous Waste Laws

Wal-Mart Stores Inc. pleaded guilty today in cases filed by federal prosecutors in Los Angeles and San Francisco to six counts of violating the Clean Water Act by illegally handling and disposing of hazardous materials at its retail stores across the United States. The Bentonville, Ark.-based company also pleaded guilty today in Kansas City, Mo., to violating the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) by failing to properly handle pesticides that had been returned by customers at its stores across the country. As a result of the three criminal cases brought by the Justice Department, as well as a related civil case filed by the U.S. Environmental Protection Agency (EPA), Wal-Mart will pay approximately $81.6 million for its unlawful conduct. Coupled with previous actions brought by the states of California and Missouri for the same conduct, Wal-Mart will pay a combined total of more than $110 million to resolve
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EPA releases Hazardous Waste Determination Evaluation

EPA conducted a survey to evaluate compliance with RCRA Hazardous Waste determination and has recently released the results of that study and we wanted to share key information with you. EPA’s Resource Conservation and Recovery Act (RCRA) Subtitle C regulations are designed as a cradle-to-grave system to ensure proper hazardous waste (HW) management and thereby protect human health and the environment. RCRA’s HW determination regulations (40 CFR 262.11), require entities that generate waste to determine if it is a HW. The average non-compliance rate with RCRA HW determination regulations across the United States is 34 percent, based on an analysis of HW determination violations identified during EPA or EPA-contractor led comprehensive evaluation investigations recorded in RCRAInfo over the last 10 years. The following five sectors have the highest HW determination non-compliance rates: 1. Printed circuit board manufacturing 2. Copper foundries 3. Hospitals 4. Colleges, universities, and professional schools 5. Fabricated structural metal manufacturing
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