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 regulations, hospital and hospital system departmental and administration leaders often struggle with meeting regulatory compliance requirements related to RCRA. Unfortunately, systemic issues may only be uncovered during a government agency compliance inspection or a waste/chemical management incident. When an incident occurs, or an inspection is performed by an environmental agency inspector, it’s often found that no single department or person is responsible for the campus or system waste program. Therefore, it takes some organizational work to evaluate how best to address and manage these environmental compliance risks for the entire campus.
In our experience gained from working with other industries and many healthcare systems, it’s critical that hospital risk management, quality/compliance, facility management, safety, laboratory, environmental services, and pharmacy leaders collaborate on and strive for a campus-wide hazardous waste management approach that connects the disparate functions of these departments. Doing this will undoubtedly take knowledge, patience, time, and leadership; however, this approach will give you the best shot at campus compliance with RCRA hazardous waste regulations.
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