Improperly managing regulated medical waste (RMW) can lead to environmental damage and threaten human health. It can also result in significant financial penalties.
In a recent announcement, a hospital in Washington, DC, said it would pay $108,304 in penalties to settle alleged violations of hazardous waste regulations. As part of the settlement, they did not admit liability for the alleged violations. The medical facility fully cooperated with the EPA in its investigation and has reconfirmed its commitment to compliance with all EPA regulations.
What went wrong, and was there anything the hospital could have done to prevent the fines? Is there a lesson other medical facilities can take away to help them mitigate the risk of being hit with similar, staggering fines?
Many RMW generators don’t fully understand what it means to be responsible from “cradle-to-grave” for the waste they generate. Or that, even if the country is going through a once-in-a-lifetime pandemic, it doesn’t relieve them of their responsibility to properly dispose of RMW.
There’s no doubt the pandemic has caused sudden, extreme changes in the flow of RMW. Medical facilities and RMW disposal companies have had to make significant changes to how they operate to accommodate the medical crisis. For instance, TriHaz established a second shift of employees, delivered more containers to customers, and added additional pickups to customers' schedules – among other proactive responses – so they can continue to comply with applicable regulatory requirements.
Understanding your facility’s RMW disposal responsibilities can help you avoid the risk of hefty fines and protect your facility from tens, if not hundreds, of thousands of dollars in penalties.
Violations Can Result in Steep Fines
In the hospital case, the EPA cited them for violating the federal Resource Conservation and Recovery Act (RCRA). The RCRA governs the treatment, storage, and disposal of hazardous waste and is designed to:
- Protect public health.
- Safeguard the environment.
- Avoid extensive cleanups through safe and environmentally sound storage and disposal of hazardous waste.
The hospital's alleged violations included failure to:
- Label and date hazardous waste containers.
- Conduct weekly inspections of the hazardous waste accumulation area.
- Maintain aisle space necessary for emergency response.
- Minimize the risk of release of hazardous waste.
- Obtain a storage permit for storage of hazardous waste for more than 90 days.
The hospital case is a reminder that you can’t ignore the risks that come with not properly planning for RMW disposal, even in times of high demand. Careful attention to the collection, transportation, and disposal processes required by the EPA, DOT, and local and state regulations can go a long way in reducing your risk of heavy fines and protecting your facility from exorbitant penalties.
Remember, there’s no expiration date on your responsibility for the proper disposal of RMW, and no facility gets a pass because the country is in the midst of a pandemic. Your facility must ensure its RMW is being collected, treated, and disposed of properly. If improperly handled, you can and will be prosecuted. Fortunately, TriHaz Solutions has processes and procedures in place that make us flexible regarding sudden changes in RMW demand flow. Our flexibility helps ensure our customers' compliance.
To learn more about what you can do to keep your facility compliant and safe, now and in the future, get in touch with TriHaz today.