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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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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Buyer, Be Calm: Effectively Navigating Contaminated Sites and Site Closures

What should you do when you find out your property is contaminated? Which Texas program and regulations apply to your site? First, you need to determine what type of operations are/were conducted at your site. Different programs need to be followed depending on the type of operations that have taken place. 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. Second, you should determine which program is appropriate to seek regulatory approvals and closure. Programs regulated by TRRP include the Voluntary Cleanup Program (VCP), Innocent Owner/Occupant Program (IOP), Drycleaner Remediation Program (DCRP), and Corrective Action (CA), while PST rules and regulations apply to Leaking Petroleum Storage Tank (LPST) cases. For example, a filling station will need to be addressed under the PST Program, while a dry cleaner will need to be addressed under the
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The Best Fit – Selecting Remediation Technology for Site-Specific Conditions and Client Goals

Do any of these situations sound familiar to you? Gasoline floating on groundwater, vinyl chloride in saturated sands, hexavalent chromium leaching into a creek, perfluorooctanesulfonic acid (PFOS) heading towards a drinking water well, trichlorethylene (TCE) dense non-aqueous phase liquid (DNAPL) in weathered bedrock. If so, you probably have been around a site with soil and/or groundwater contamination or you’ve picked a really unusual hobby.  If you are a responsible party, a stakeholder, or an environmental manager responsible for handling the regulatory aspects of a contaminated site, the goal is generally to reach the cleanup finish line (closure) with the best possible results for the least possible cost. Consider this analogy. We know three things about fingerprints. 1) They are found on fingers, 2) they are generally arranged on the surface of the fingertips, and 3) each fingerprint is different from all others in the fine detail.  Remediation can be viewed
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What’s Firestopping and Why Might We Need It?

Firestopping? – Oh, that’s easy! Goop some red caulk at a joint or around that pipe and you are good to go! Right? Well, not anymore. Building code and fire inspection officials recently began strict enforcement of code requirements for firestopping inspections. The International Building Code (IBC) 2012, Section 1705.16 states that firestop inspections shall be included as part of the mandatory special inspections for high-risk facilities. Enforcement began in earnest when the local building code was adopted as 2012 IBC or newer, and now building owners, contractors, and designers are bumping into this requirement on more and more projects. So, what is fire stopping and why is it so special? Firestopping is a passive containment approach to resist the spread of smoke and fire in a building, it is defined by the International Firestop Council (IFC) as “a process where certain materials are used to resist or stop the
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Permit Required Confined Space Program Misconceptions

 Last month, we discussed common misconceptions about the Lockout/Tagout program. Many similar misconceptions exist about Permit-required Confined Space Programs and affect their implementation. The most common misconceptions are: My employees do not enter permit-required confined spaces; we use contractors, so I do not need a program. For permit-required confined spaces, the host employer performs the following items: Inform the contractor that the workplace contains permit spaces and that permit space entry is allowed only through compliance with a permit space program meeting the requirements of 1910.146. Apprise the contractor of the elements, identified hazards and any experience which makes the space a permit space. Apprise the contractor of any precautions or procedures that have been implemented for the protection of employees in or near permit spaces where contractor personnel will be working. Coordinate entry operations with the contractor. Debrief the contractor at the conclusion of the entry operations regarding
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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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