Resource Conservation and Recovery Act (RCRA) Resource Conservation and Recovery Act (RCRA)
Lisa PapettiU.S. Environmental Protection Agency (EPA)Region 1 New England
Lisa PapettiU.S. Environmental Protection Agency (EPA)Region 1 New England
MOST COMMON RCRA VIOLATIONS IN HEALTHCAREMOST COMMON RCRA VIOLATIONS MOST COMMON RCRA VIOLATIONS IN HEALTHCAREIN HEALTHCARE
Hazardous waste determinationsImproper disposalOpen containersUnmarked/unlabeled containersSatellite accumulationHazardous waste trainingContingency planUniversal Waste
Note: Don’t forget contractors and consultants
Hazardous waste determinationsHazardous waste determinationsImproper disposalImproper disposalOpen containersOpen containersUnmarked/unlabeled containersUnmarked/unlabeled containersSatellite accumulationSatellite accumulationHazardous waste trainingHazardous waste trainingContingency planContingency planUniversal WasteUniversal Waste
Note: Don’t forget contractors and consultantsNote: Don’t forget contractors and consultants
RCRABASICSRCRA
BASICS
RCRA Basics IRCRA Basics I
HAZARDOUS WASTE DETERMINATIONSGenerator’s responsibilityannually or when process changesProcess knowledgeAnalysisMSDSExpiration dates
HAZARDOUS WASTE DETERMINATIONSGenerator’s responsibilityannually or when process changesProcess knowledgeAnalysisMSDSExpiration dates
RCRA Basics IRCRA Basics I
HAZARDOUS WASTE DETERMINATIONS
Process knowledgeAnalysisMSDSExpiration dates
HAZARDOUS WASTE DETERMINATIONS
Process knowledgeAnalysisMSDSExpiration dates
RCRA Basics IIRCRA Basics II
Waste Activity NotificationWaste Activity Notification
RCRA Basics IIIRCRA Basics III
GENERATOR CLASSIFICATION - VOLUMELarge Quantity
> 1000 kg
Small Quantity 100kg –1000kg, < 1kg acute and no more
than 1000kg at any time
Conditionally Exempt < 100 kg, < 1kg acute and no more than
1000 kg at any time
GENERATOR CLASSIFICATION - VOLUMELarge Quantity
> 1000 kg
Small Quantity 100kg –1000kg, < 1kg acute and no more
than 1000kg at any time
Conditionally Exempt < 100 kg, < 1kg acute and no more than
1000 kg at any time
RCRA Basics IIIRCRA Basics III
GENERATOR CLASSIFICATION - TIMELarge Quantity - 90 Days
Small Quantity – 180 Days
Conditionally Exempt - no time limit
GENERATOR CLASSIFICATION - TIMELarge Quantity - 90 Days
Small Quantity – 180 Days
Conditionally Exempt - no time limit
RCRCA Basics IVRCRCA Basics IV
Container ManagementContainer Management
RCRA Basics VRCRA Basics V
Satellite vs. Non-Satellite Storage
Satellite vs. Non-Satellite Storage
RCRA Basics VIRCRA Basics VI
SATELLITE STORAGEAt or near point of generationUnder the control of the operator of the processLess than 55-gallons of wastes -total
SATELLITE STORAGEAt or near point of generationUnder the control of the operator of the processLess than 55-gallons of wastes -total
RCRA Basics VIIRCRA Basics VII
SATELLITE STORAGELabeled “Hazardous Waste” and other words that describe contentsKeep container closed
SATELLITE STORAGELabeled “Hazardous Waste” and other words that describe contentsKeep container closed
RCRA Basics VIIIRCRA Basics VIII
CONTAINER MANAGEMENTLabeling (“hazardous waste” and other words that describe contents)DatingCompatibilityAisle space
CONTAINER MANAGEMENTLabeling (“hazardous waste” and other words that describe contents)DatingCompatibilityAisle space
RCRA Basics IXRCRA Basics IX
CONTAINER MANAGEMENTCondition of containersclosedIgnitable waste special requirementsAir emission standards
CONTAINER MANAGEMENTCondition of containersclosedIgnitable waste special requirementsAir emission standards
RCRA Basics XIIRCRA Basics XII
Manifesting WastesManifesting WastesManifesting Wastes
RCRA Basics XIIIRCRA Basics XIII
CONTAINER STORAGE AREA INSPECTIONS
The owner or operator must inspect areas where containers are stored, at least weekly, looking for leaks and for deterioration caused by corrosion or other factors.
CONTAINER STORAGE AREA INSPECTIONS
The owner or operator must inspect areas where containers are stored, at least weekly, looking for leaks and for deterioration caused by corrosion or other factors.
RCRA Basics XVRCRA Basics XV
HAZARDOUS WASTE TRAININGInitial trainingAnnual refresher trainingDocumentationRelevant to job duties performedTraining program led by qualified staff
HAZARDOUS WASTE TRAININGInitial trainingAnnual refresher trainingDocumentationRelevant to job duties performedTraining program led by qualified staff
RCRA Basics XVIRCRA Basics XVI
HAZARDOUS WASTE TRAININGJob titlesJob descriptionsRCRA vs OSHA
HAZARDOUS WASTE TRAININGJob titlesJob descriptionsRCRA vs OSHA
RCRA Basics XVIIRCRA Basics XVII
CONTINGENCY PLAN Plan must be designed to minimize hazards to human health and the environment from fires, explosions, or release of hazardous waste or hazardous waste constituents.Plan must be carried out immediately.
CONTINGENCY PLAN Plan must be designed to minimize hazards to human health and the environment from fires, explosions, or release of hazardous waste or hazardous waste constituents.Plan must be carried out immediately.
RCRA Basics XVIIIRCRA Basics XVIII
CONTINGENCY PLANDescribe detailed response actionsArrangements with localsEmergency coordinatorsEmergency equipmentEvacuation plans
CONTINGENCY PLANDescribe detailed response actionsArrangements with localsEmergency coordinatorsEmergency equipmentEvacuation plans
RCRA Basics XIXRCRA Basics XIX
PREPAREDNESS AND PREVENTIONAlarm systemCommunication deviceExtinguishersAdequate waterAisle spaceArrangements with locals
PREPAREDNESS AND PREVENTIONAlarm systemCommunication deviceExtinguishersAdequate waterAisle spaceArrangements with locals
RCRA Basics XXRCRA Basics XX
PREPAREDNESS AND PREVENTION
Facilities must be maintained and operated to minimize the possibility of a fire, explosion or release of hazardous waste or hazardous constituents.
PREPAREDNESS AND PREVENTION
Facilities must be maintained and operated to minimize the possibility of a fire, explosion or release of hazardous waste or hazardous constituents.
RCRA Basics XXIRCRA Basics XXI
BIENNIAL REPORT
A large quantity generator is required to submit a biennial report by March 1st of each even numbered year. This report summarizes waste activities during the previous year.
BIENNIAL REPORT
A large quantity generator is required to submit a biennial report by March 1st of each even numbered year. This report summarizes waste activities during the previous year.
RCRA Basics XXIIRCRA Basics XXII
UNIVERSAL WASTE
Universal wastes are widely generated and widely recycled hazardous wastes. Management standards for these wastes are reduced to facilitate their recycling.
Universal Waste need not be counted towards your monthly generation rate
UNIVERSAL WASTE
Universal wastes are widely generated and widely recycled hazardous wastes. Management standards for these wastes are reduced to facilitate their recycling.
Universal Waste need not be counted towards your monthly generation rate
RCRA Basics XXIIIRCRA Basics XXIII
UNIVERSAL WASTEBatteriesPesticidesMercury containing thermostatsHazardous waste lampsUsed electronics
UNIVERSAL WASTEBatteriesPesticidesMercury containing thermostatsHazardous waste lampsUsed electronics
RCRA Basics XXIVRCRA Basics XXIV
UNIVERSAL WASTEContainerizationLabel describing contentDatingTrainingRecord keeping
UNIVERSAL WASTEContainerizationLabel describing contentDatingTrainingRecord keeping
WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTION
AUTHORITY
42 USC Section 6927 (SWDA 3007)
Gives EPA the authority to:Enter at reasonable times any place where
hazardous wastes are or have been generated, stored, treated, disposed of or transported from
Inspect and obtain samplesReview and copy records related to hazardous waste
AUTHORITYAUTHORITY
42 USC Section 6927 (SWDA 3007)42 USC Section 6927 (SWDA 3007)
Gives EPA the authority to:Gives EPA the authority to:Enter at reasonable times any place where Enter at reasonable times any place where
hazardous wastes are or have been generated, hazardous wastes are or have been generated, stored, treated, disposed of or transported fromstored, treated, disposed of or transported from
Inspect and obtain samplesInspect and obtain samplesReview and copy records related to hazardous wasteReview and copy records related to hazardous waste
WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTION
FEDERAL REGULATIONSVS.
STATE REGULATIONS
FEDERAL REGULATIONSFEDERAL REGULATIONSVS.VS.
STATE REGULATIONSSTATE REGULATIONS
WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTION
WHAT WE LOOK AT
Container managementEmergency planningTrainingOther records
WHAT WE LOOK ATWHAT WE LOOK AT
Container managementContainer managementEmergency planningEmergency planningTrainingTrainingOther recordsOther records
WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTION
WHEN WE ARRIVE
It will be a surprisePlan on spending a day to several days with
usThere will be at least two of usMulti-media or notAn opening meeting – you describe your
facility
WHEN WE ARRIVEWHEN WE ARRIVE
It will be a surpriseIt will be a surprisePlan on spending a day to several days with Plan on spending a day to several days with
ususThere will be at least two of usThere will be at least two of usMultiMulti--media or notmedia or notAn opening meeting An opening meeting –– you describe your you describe your
facilityfacility
WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTION
FACILITY TOUR
Photos and lots of notesWill go to any and all areas of the siteWill look at chemical and waste storage
FACILITY TOURFACILITY TOUR
Photos and lots of notesPhotos and lots of notesWill go to any and all areas of the siteWill go to any and all areas of the siteWill look at chemical and waste storageWill look at chemical and waste storage
WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTION
RECORD REVIEW
ManifestsWaste determination documentationTraining recordsContingency planBiennial report
RECORD REVIEWRECORD REVIEW
ManifestsManifestsWaste determination documentationWaste determination documentationTraining recordsTraining recordsContingency planContingency planBiennial reportBiennial report
WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTION
OUTBRIEF
Please have all relevant people at this meeting
Detailed review of areas of concernSummary of time frames and enforcement
follow-upAsk questions and offer information on
compliance determination.
OUTBRIEFOUTBRIEF
Please have all relevant people at this Please have all relevant people at this meetingmeeting
Detailed review of areas of concernDetailed review of areas of concernSummary of time frames and enforcement Summary of time frames and enforcement
followfollow--upupAsk questions and offer information on Ask questions and offer information on
compliance determination.compliance determination.
WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTION
WHEN WE LEAVE
Report and review findings with management
May ask for more information (informally or information request letter)
Prepare enforcement follow-up
WHEN WE LEAVEWHEN WE LEAVE
Report and review findings with Report and review findings with managementmanagement
May ask for more information May ask for more information (informally or information request (informally or information request letter)letter)
Prepare enforcement followPrepare enforcement follow--upup
WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTION
TYPES OF ENFORCEMENT
Notice of ViolationAdministrative Order with penalty (up to $ 32,500 per day per
violation)Referral to the Department of Justice7003 Order for imminent/substantial endangermentReferral to State/other EPA program/other agencyCriminal referral
Note: EPA does not issue “compliance letters”
TYPES OF ENFORCEMENTTYPES OF ENFORCEMENT
Notice of ViolationNotice of ViolationAdministrative Order with penalty (up to $ 32,500 per day per Administrative Order with penalty (up to $ 32,500 per day per
violation)violation)Referral to the Department of JusticeReferral to the Department of Justice7003 Order for imminent/substantial endangerment7003 Order for imminent/substantial endangermentReferral to State/other EPA program/other agencyReferral to State/other EPA program/other agencyCriminal referralCriminal referral
Note: EPA does not issue “compliance letters”Note: EPA does not issue “compliance letters”
WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?
WHEN YOU GENERATE IT OR DETERMINE IT TO BE NO LONGER
USABLE
WHEN YOU GENERATE IT OR WHEN YOU GENERATE IT OR DETERMINE IT TO BE NO LONGER DETERMINE IT TO BE NO LONGER
USABLEUSABLE
WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?
A solid waste is any discarded material that is not otherwise excluded. A material is discarded if it is abandoned by being disposed of, burned or incinerated; accumulated, stored or treated before or in lieu of being abandoned by being disposed of, burned or incinerated; or recycled.
A person who generates a solid waste must determine if that waste is a hazardous waste.
A solid waste is any discarded material that is not A solid waste is any discarded material that is not otherwise excluded. A material is discarded if it is otherwise excluded. A material is discarded if it is abandoned by being disposed of, burned or abandoned by being disposed of, burned or incinerated; accumulated, stored or treated incinerated; accumulated, stored or treated before or in lieu of being abandoned by being before or in lieu of being abandoned by being disposed of, burned or incinerated; or recycled.disposed of, burned or incinerated; or recycled.
A person who generates a solid waste must A person who generates a solid waste must determine if that waste is a hazardous determine if that waste is a hazardous waste.waste.
WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?
40 CFR Section 261.2(f)
Documentation of claims that materials are not solid waste or are conditionally exempt from regulation. Respondents in actions to enforce regulations implementing subtitle C of RCRA who raise a claim that a certain materials is not a solid waste, or is conditionally exempt from regulation must demonstrate that there is a known market or disposition for the material and that they meet the terms of the exclusion.
40 CFR Section 261.2(f)40 CFR Section 261.2(f)
Documentation of claims that materials are not solid Documentation of claims that materials are not solid waste or are conditionally exempt from waste or are conditionally exempt from regulation. regulation. Respondents in actions to enforce Respondents in actions to enforce regulations implementing subtitle C of RCRA who regulations implementing subtitle C of RCRA who raise a claim that a certain materials is not a solid raise a claim that a certain materials is not a solid waste, or is conditionally exempt from regulation waste, or is conditionally exempt from regulation must demonstrate that there is a known market must demonstrate that there is a known market or disposition for the material and that they meet or disposition for the material and that they meet the terms of the exclusion.the terms of the exclusion.
WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?
A solid waste is a HAZARDOUS waste if it:
Is not excluded or deferred; and
Is LISTED; or Exhibits a CHARACTERISTIC(S); orIs mixed with a hazardous waste; orIs derived from a hazardous waste; orIs regulated by a State.
A solid waste is a HAZARDOUS waste if it:A solid waste is a HAZARDOUS waste if it:
Is not excluded or deferred; and Is not excluded or deferred; and
Is LISTED; or Is LISTED; or Exhibits a CHARACTERISTIC(S); orExhibits a CHARACTERISTIC(S); orIs mixed with a hazardous waste; orIs mixed with a hazardous waste; orIs derived from a hazardous waste; orIs derived from a hazardous waste; orIs regulated by a State.Is regulated by a State.
WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?
LISTED HAZARDOUS WASTES
F Wastes Non-specific sourcesF001-F039 (solvents, plating
wastes, refineries)
F001-F005 Solvent > 10% before use
LISTED HAZARDOUS WASTESLISTED HAZARDOUS WASTES
F WastesF Wastes NonNon--specific sourcesspecific sourcesF001F001--F039F039 (solvents, plating (solvents, plating
wastes, refineries)wastes, refineries)
F001F001--F005 Solvent > 10% before useF005 Solvent > 10% before use
WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?
LISTED WASTES (CONT.)
P Wastes Acutely hazardousP001-P123 (e.g., nitric oxide,
dichloromethyl ether)
U Wastes Toxic wastesU001-U359 (e.g., acetone,
formaldehyde)
Discarded commercial chemical product, residues and spills AND sole active ingredients
LISTED WASTES (CONT.)LISTED WASTES (CONT.)
P WastesP Wastes Acutely hazardousAcutely hazardousP001P001--P123P123 (e.g., nitric oxide, (e.g., nitric oxide,
dichloromethyl ether)dichloromethyl ether)
U WastesU Wastes Toxic wastesToxic wastesU001U001--U359U359 (e.g., acetone, (e.g., acetone,
formaldehyde)formaldehyde)
Discarded commercial chemical product, residues and spills Discarded commercial chemical product, residues and spills AND sole active ingredientsAND sole active ingredients
WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?
CHARACTERISTIC HAZARDOUS WASTES
D001 Ignitable – liquids with a flash point < 140 degrees F
D002 Corrosive – pH less than or equal to 2 or greater than or equal to 12.5 or corrodes steel .25
inches/year D003 Reactive – unstable,
explosive, water reactiveD004-D043 Toxic - TCLP
CHARACTERISTIC HAZARDOUS WASTESCHARACTERISTIC HAZARDOUS WASTES
D001D001 Ignitable Ignitable –– liquids with a flash liquids with a flash point < 140 degrees Fpoint < 140 degrees F
D002D002 Corrosive Corrosive –– pH less than or equal pH less than or equal to 2 or greater than or equal to 2 or greater than or equal to 12.5 or corrodes steel .25 to 12.5 or corrodes steel .25
inches/year inches/year D003D003 Reactive Reactive –– unstable, unstable,
explosive, water reactiveexplosive, water reactiveD004D004--D043D043 Toxic Toxic -- TCLPTCLP
WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?
HAZARDOUS WASTE MIXTURES
Hazardous waste mixtures that are still hazardous waste
Mix anything with a listed waste and it’s all listedMix something with a characteristic waste and it
retains characteristicSpill residues, soil, water, debris mixed with listed
waste
HAZARDOUS WASTE MIXTURESHAZARDOUS WASTE MIXTURES
Hazardous waste mixtures that are still hazardous Hazardous waste mixtures that are still hazardous wastewaste
Mix anything with a listed waste and it’s all listedMix anything with a listed waste and it’s all listedMix something with a characteristic waste and it Mix something with a characteristic waste and it
retains characteristicretains characteristicSpill residues, soil, water, debris mixed with listed Spill residues, soil, water, debris mixed with listed
wastewaste
WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?
EMPTY CONTAINERS DO NOT HAVE TO BE MANAGED AS HAZARDOUS WASTE
Compressed Gas – no pressureP-listed Waste – triple rinse and manage rinsate as
HW
All else - all waste removed AND < 1” of residue OR < 3% of the containers capacity (if container less than 110 gallons)
EMPTY CONTAINERS DO NOT HAVE TO BE EMPTY CONTAINERS DO NOT HAVE TO BE MANAGED AS HAZARDOUS WASTEMANAGED AS HAZARDOUS WASTE
Compressed Gas Compressed Gas –– no pressureno pressurePP--listed Waste listed Waste –– triple rinse and manage rinsate as triple rinse and manage rinsate as
HWHW
All else All else -- all waste removed AND < 1” of residue OR all waste removed AND < 1” of residue OR < 3% of the containers capacity (if container less < 3% of the containers capacity (if container less than 110 gallons)than 110 gallons)
WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?WHEN IS A WASTE A WASTE?
DON’T FORGET
Expired chemicals and unused chemicals/pharmaceuticals (both active use and inactive use)
Facilities wastesDental wastesPhotographic wastes
DON’T FORGET DON’T FORGET
Expired chemicals and unused Expired chemicals and unused chemicals/pharmaceuticals (both chemicals/pharmaceuticals (both active use and inactive use)active use and inactive use)
Facilities wastesFacilities wastesDental wastesDental wastesPhotographic wastesPhotographic wastes
REGION II HOSPITAL INITIATIVE –INSPECTIONS AND ENFORCEMENTREGION II HOSPITAL INITIATIVE REGION II HOSPITAL INITIATIVE ––INSPECTIONS AND ENFORCEMENTINSPECTIONS AND ENFORCEMENT
Region II includes New Jersey, New York, Puerto Rico, and U.S. Virgin Islands
Region II conducted at least 12 inspections and initiated four penalty actions
Region II includes New Jersey, New Region II includes New Jersey, New York, Puerto Rico, and U.S. Virgin York, Puerto Rico, and U.S. Virgin IslandsIslands
Region II conducted at least 12 Region II conducted at least 12 inspections and initiated four penalty inspections and initiated four penalty actionsactions
REGION II HOSPITAL INITIATIVE –INSPECTIONS AND ENFORCEMENTREGION II HOSPITAL INITIATIVE REGION II HOSPITAL INITIATIVE ––INSPECTIONS AND ENFORCEMENTINSPECTIONS AND ENFORCEMENT
North Shore University Hospital
Total Penalty - $ 57,749
Waste determination – chemo waste for incineration, lamps in trash
Failure to minimize the threat of release –abandoned chemicals not segregated
North Shore University HospitalNorth Shore University Hospital
Total Penalty Total Penalty -- $ 57,749$ 57,749
Waste determination Waste determination –– chemo waste for chemo waste for incineration, lamps in trashincineration, lamps in trash
Failure to minimize the threat of release Failure to minimize the threat of release ––abandoned chemicals not segregatedabandoned chemicals not segregated
REGION II HOSPITAL INITIATIVE –INSPECTIONS AND ENFORCEMENTREGION II HOSPITAL INITIATIVE REGION II HOSPITAL INITIATIVE ––INSPECTIONS AND ENFORCEMENTINSPECTIONS AND ENFORCEMENT
Atlantic Health Systems/Mountainside Hospital
Total Penalty - $ 64,349
Waste determination – chemo waste, scrap amalgam, lamps, lab wastes, dental clinic wastes in trash or down sink or disposed of as medical waste
Atlantic Health Systems/Mountainside Atlantic Health Systems/Mountainside HospitalHospital
Total Penalty Total Penalty -- $ 64,349$ 64,349
Waste determination Waste determination –– chemo waste, chemo waste, scrap amalgam, lamps, lab wastes, scrap amalgam, lamps, lab wastes, dental clinic wastes in trash or down dental clinic wastes in trash or down sink or disposed of as medical wastesink or disposed of as medical waste
REGION II HOSPITAL INITIATIVE –INSPECTIONS AND ENFORCEMENTREGION II HOSPITAL INITIATIVE REGION II HOSPITAL INITIATIVE ––INSPECTIONS AND ENFORCEMENTINSPECTIONS AND ENFORCEMENT
Memorial Sloan Kittering
Total Penalty - $ 214,423
Storage of hazardous waste without a permit
Waste determination
Memorial Sloan KitteringMemorial Sloan Kittering
Total Penalty Total Penalty -- $ 214,423$ 214,423
Storage of hazardous waste without a Storage of hazardous waste without a permitpermit
Waste determinationWaste determination
REGION II HOSPITAL INITIATIVE –INSPECTIONS AND ENFORCEMENTREGION II HOSPITAL INITIATIVE REGION II HOSPITAL INITIATIVE ––INSPECTIONS AND ENFORCEMENTINSPECTIONS AND ENFORCEMENT
Nassau Health Care Corporation/Nassau University Hospital
Total Penalty - $ 279,900
Storage of hazardous waste without a permit – old, unused chemicals stored for greater than one year
Failure to minimize the threat of release – abandoned chemicals not segregated, wastes stored in alphabetical order
Nassau Health Care Corporation/Nassau University HospitalNassau Health Care Corporation/Nassau University Hospital
Total Penalty Total Penalty -- $ 279,900$ 279,900
Storage of hazardous waste without a permit Storage of hazardous waste without a permit –– old, unused old, unused chemicals stored for greater than one yearchemicals stored for greater than one year
Failure to minimize the threat of release Failure to minimize the threat of release –– abandoned abandoned chemicals not segregated, wastes stored in alphabetical chemicals not segregated, wastes stored in alphabetical orderorder
RCRA REGULATED CHEMOTHERAPY DRUGSRCRA REGULATED RCRA REGULATED CHEMOTHERAPY DRUGSCHEMOTHERAPY DRUGSSome drugs that are LISTED hazardous wastes:
Chlorambucil (U035)Cyclophosphamide (U058)Daunamycin (U059)Melphalin (U150)Mitomycin C (U010)Streptozocin (U206)Uracil Mustard (U237)Arsenic Trioxide (P012!!!)
Some drugs that are LISTED hazardous wastes:Some drugs that are LISTED hazardous wastes:
Chlorambucil (U035)Chlorambucil (U035)Cyclophosphamide (U058)Cyclophosphamide (U058)Daunamycin (U059)Daunamycin (U059)Melphalin (U150)Melphalin (U150)Mitomycin C (U010)Mitomycin C (U010)Streptozocin (U206)Streptozocin (U206)Uracil Mustard (U237)Uracil Mustard (U237)Arsenic Trioxide (P012!!!)Arsenic Trioxide (P012!!!)
RCRA REGULATED CHEMOTHERAPY DRUGSRCRA REGULATED RCRA REGULATED CHEMOTHERAPY DRUGSCHEMOTHERAPY DRUGSIV BAGS AND ASSOCIATED
EQUIPMENT
Empty bags and equipment that are not acutely hazardous may be disposed as empty containers
Bags and equipment with material remaining must be managed as hazardous waste
IV BAGS AND ASSOCIATED IV BAGS AND ASSOCIATED EQUIPMENTEQUIPMENT
Empty bags and equipment that are Empty bags and equipment that are not acutely hazardous may be not acutely hazardous may be disposed as empty containersdisposed as empty containers
Bags and equipment with material Bags and equipment with material remaining must be managed as remaining must be managed as hazardous waste hazardous waste
