Compliance Management in Hospital Systems

Hospital facilities generate thousands of waste streams (and many in significant quantities) that are all subject to RCRA and State hazardous waste laws. These laws can be difficult to understand and comply with, and it is not uncommon for facilities to lack the proper hazardous waste management training and structure to achieve compliance. However, a zero violation program is possible. W&M, a Division of Braun Intertec, provides environmental consulting services for the hospital and healthcare sector, including: RCRA and Rx Waste Management Organizational/Management System Consulting for Managing Hazardous Wastes RCRA Compliance Audits and Assessments Permits, Registration, and Reporting Tanks and Contamination Investigation Due Diligence (Property & Business)





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…)

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Streaming From, Allen, Texas, 75002, United States





Hazardous Waste in the Healthcare Industry

W&M’s Lori Siegelman and Pat Larkin, an Environmental Attorney and Partner with Strasburger & Price, LLP, conducted a lunchtime webinar on hazardous waste management in the healthcare industry.  Medical and laboratory professionals may not be  well-versed about the intricacies and potential complexities of State and Federal regulations applicable to waste being generated in the pharmacy, clinic, laboratory, or hospital.   Listen to experts explain how hazardous waste generated in the healthcare industry should be identified and properly managed.





Decreasing Financial Liability and Solid Waste One Exclusion At A Time

Given the complex structure of RCRA and the extensive exemptions and exceptions to the Solid Waste rules, there are great opportunities to decrease the potential legal and financial liabilities associated with waste management. The authors will explore ways to reduce solid waste and hazardous waste, decrease generator status (e.g., “large”, “small” and “very small”), and use the new episodic generation rules to the generators benefit. The author will also discuss how correctly classifying and managing waste can greatly affect the amount of effort (money) it takes to comply with RCRA, and how it can reduce liability. Finally, the authors will explore how remedial work and remediation, can play into or out of generator status, onetime waste codes, episodic generation, annual/biennial waste reporting, Tier 2, and Toxics Release Inventory reporting. The presentation will include reporting advisements for commonly missed reporting requirements associated with annual reporting when undergoing remediation treatment. If you
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Need Help Making Sure Your Business Is In Compliance?

You don’t know what you don’t know.  With environmental regulations constantly changing it can sometimes feel overwhelming.  W&M’s environmental compliance experts can help guide you through the maze of regulations to  show you where those gaps might be in your environmental program. A Regulatory Applicability Screen (RAS) is a quick and valuable service that provides our clients with a list of potential regulatory concerns ranging from air permits, water supply, wastewater, stormwater, hazardous waste, and various other environmental reporting requirements.  In each of these regulatory areas, W&M outlines the gaps and potential corrective actions that you could undertake to eliminate  those gaps. The process begins with an information gathering meeting to understand the nature of the facility.  Then one of our environmental experts conducts the RAS to determine regulatory applicability and potential compliance gaps with U.S. Environmental Protections Agency (EPA), Resource Conservation and Recovery Act (RCRA), and other state and
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Great Tips On Environmental Reporting

Do Annual Waste Summaries, Air Emission Inventory, storm water, Tier II and TRI Reports give you headaches?  If so, watch our webinar on tips on completing accurate environment reports hosted by Heather Woodward. Topics include: Reporting Due Dates – On Time Completion Data Collection Techniques Common Reporting Mistakes Reporting Resources