How medical waste is disposed of has been a hot issue for the Environmental Protection Agency (EPA) during the last five years. In 2002, the EPA introduced a health care compliance initiative in response to the growing number of environmental violations within the health care sector.

The goal of the initiative is to ensure that health care facilities comply with all federal environmental laws and regulations, though the EPA is focusing most of its efforts on facilities that deal with hazardous wastes, wastewater discharges, air emissions and storage tanks.

How bad is it?
According to the EPA, most hospitals and health care providers are not aware of their responsibility under federal environmental guidelines and have failed to implement effective compliance strategies. Through its initiative, the EPA is taking a closer look at affected facilities, and stepping up its inspection and enforcement activities.

Since the initiative began, the EPA has inspected 44 facilities, resulting in 22 enforcement actions and $911,018 in penalties. In 2003, the EPA aggressively sought fines against Nassau University Medical Center in East Meadow, N.Y., for $279,900 and Mountainside Hospital in Montclair, N.J., for $64,349 for violations of the Resource Conservation and Recovery Act relating to the improper designation, storage and labeling of hazardous wastes. The EPA also noted that neither hospital had a permit to store hazardous wastes.

Since then, the EPA has continued to focus its enforcement efforts toward hospitals and health care facilities by issuing more fines for noncompliance.

What should you do?
In light of the EPA’s initiative, hospitals and health care providers should review their policies and procedures now to be prepared for an unscheduled inspection by the EPA or state regulators. For example, within each category emphasized by the EPA, review the appropriate criteria.

For clean air compliance, make sure that:

• Incinerators have all permits,
• Labs have any necessary permits,
• Asbestos is properly removed, and
• Paint booths have all permits.

For hazardous waste (HW) compliance, check that:

• HW is properly labeled,
• HW storage sites are inspected to ensure they don’t exceed storage requirements,
• Employees are trained on and follow HW segregation and disposal policies, and
• Underground storage tanks are in compliance and properly maintained.

For clean water compliance, see that:

• Permits have been obtained for wastewater discharges, and
• HW is not disposed of through floor drains.

Moreover, spill prevention control measures should be in place.

What does the future hold?
It’s likely that the EPA will continue to monitor the health care industry’s handling of medical waste. Hospitals and health care providers should review their applicable state and federal laws and regulations to make sure they are in compliance.

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