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Environmental requirements related to patient care and the team working to ensure compliance.

The US Environmental Protection Agency (EPA) was established in 1970 to protect the environment, which has the attendant effect of protecting people's health. This correlates with one goal of the US Army Public Health Command (USAPHC):

   To protect Soldiers and Army communities, worldwide, from
   environmental conditions that could adversely affect human
   health. (1)


One example of an environmentally regulated process frequently used in patient care is cervical cancer screening. Historically, samples of cervical cells were manually smeared directly on a glass slide which was then sent to a lab for processing and review. This screening procedure was not reliable. Sometimes the cells were smeared too thick or too thin, commonly resulting in false positive or false negative results. In 1996, the Food and Drug Administration approved the ThinPrep Pap System (Hologic Inc, Bedford, MA) (2) which suspends the cervical cells in a methanol-based solution, then uses an automated process that places the cells uniformly on a slide. The new process has improved accuracy for cervical cancer screening, but generates a hazardous waste (HW) in the process. Personnel ordering and using this equipment and its reagents were not initially aware this process generated a HW. Since chemical and pharmaceutical manufacturing companies are not required to communicate disposal requirements for their products, the person generating the waste must make the determination. In this as in most cases, the process is simple and personnel are available to assist. Each medical activity (MEDDAC) has personnel within the logistics and preventive medicine divisions who can assist in determining which wastes are hazardous and which are not. Logistics and preventive medicine personnel can seek assistance, if needed, from their USAPHC regions.

Determining which regulations apply can be tricky, and collaboration is often required to ensure the facilities are in compliance.

There are 22 regulatory acts and 3 executive orders under the jurisdiction of the EPA. Although all of the acts and executive orders can be applied to healthcare facilities, the most significantly relevant are the Resource Conservation and Recovery Act (RCRA) (3) and the Clean Water Act. (4)

THE RESOURCE CONSERVATION AND RECOVERY ACT

The RCRA was first enacted in 1976 and amended in 1984. (5) According to the US Department of Agriculture, the objectives of the RCRA are:

   ... to protect human health and the environment from
   the potential hazards of waste disposal, to conserve
   energy and natural resources, to reduce the amount of
   waste generated, and to ensure that wastes are managed
   in an environmentally sound manner. RCRA regulates
   the management of solid waste (eg, garbage), hazardous
   waste, and underground storage tanks holding petroleum
   products or certain chemicals. (6)


The RCRA requirements are not industry-specific. Any industry generating HW or storing petroleum, oils, and lubricants is regulated. Patient care, including dental and veterinary care, generates HW. Hospitals store petroleum to power emergency generators, dining facilities generate used oil from cooking, and facilities maintenance generates used oil during regular maintenance activities. The RCRA relates to patient care, both directly and indirectly.

The RCRA divides HW into 2 broad categories, Characteristic and Listed. The Characteristic subcategories are Ignitable, Corrosive, Reactive, and Toxic. The Listed categories are F, K, P and U. All HWs are given a 4 digit EPA HW Identification Number.

Ignitable HW includes, but is not limited to, liquids containing at least 24% alcohol with a flashpoint of 60[degrees]C/140[degrees]F or higher. With a flashpoint of 60[degrees]C, the methanol-based waste generated from cervical cancer screening becomes an ignitable HW upon disposal. The EPA HW number for ignitable HW is D001. The characteristic of corrosive HW (D002) include liquids having a pH of 2 or lower, or 12.5 or higher. These pH ranges apply to many acids and bases used in clinical laboratories. Reactive (D003) HW includes wastes reactive with water, capable of detonation if heated or under confinement, or items that can undergo violent change without detonation. Lithium batteries and non-empty aerosol cans are waste that can fall into this category upon disposal.

The toxicity characteristic is based on the type and concentration of specific chemical constituents such as silver or mercury that may be present in waste. These constituents are harmful or fatal when ingested or absorbed; can enter the environment as leachate from improperly discarded waste; and pollute ground water. Toxicity is defined through a laboratory procedure called the toxicity characteristic leaching procedure (TCLP). The TCLP helps identify constituents in items such as silver nitrate sticks (see illustration) that are likely to leach into the environment. Table 1 provides a list of constituents commonly found in patient care settings, with the associated EPA HW Number and the regulatory level that, when reached or exceeded, makes the item a HW.

The Kdist consists of specific industrial processes. Examples include pressure treating wood or developing explosives, such as trinitrotoluene or TNT. The wastes generated from these processes are HWs. This category is not applicable to patient care.

The F-list consists of waste generated from processes common to multiple types of industrial processes. Acetone, xylene, and methylene chloride are used as solvents in paint, leather, and pesticide manufacturing, as well as by the auto industry for degreasing. In cases when these are used for their solvent properties, they are F-listed HW. The hospital may not seem "industrial," but xylene is used in a histology laboratory during tissue processing to dissolve paraffin and tissue-based fats. Because xylene is used in this process as a solvent, RCRA characterizes it as an F-listed HW upon disposal. Various chemicals with solvent properties are often used in facilities maintenance, which would be the only other activity that may regularly generate this waste.

The P-list and U-list consist of commercial chemical products such as formaldehyde, methanol, xylene, and warfarin (Coumadin). If such products require disposal, they will be a P or U-listed HW only when unused and if the product has only one active ingredient which is on the P or U-list. For example, an unused, expired bottle of phenol used in physical therapy would be a U188 RCRA HW because the item is an unused commercial chemical product and phenol is its sole active ingredient. In contrast, yellow fever vaccine preserved with phenol is not a U188 HW because phenol is not the sole active ingredient in the vaccine. Similarly, xylene used in a histology laboratory for its solvent properties would not be a U-listed waste for disposal. However, if the xylene is expired and cannot be used, it would be managed as a U239 HW upon disposal. Table 2 lists additional items used in patient care that would be P or U-listed HW upon disposal.

The difference between the P and U-lists is that P-listed chemical products are acutely toxic. Acutely toxic refers to HW that could pose a threat to human health and the environment even when properly managed. Toxic HW is considered capable of posing a threat to human health and the environment in the absence of special handling and storage procedures. Because P-listed wastes are acutely toxic, the containers that hold them are also considered acutely toxic. A container that held Coumadin would therefore be a P-listed HW. The same categorization applies to wrappers that contained nicotine patches and blister packs that contained nicotine gum.

THE CLEAN WATER ACT, RCRA, AND PETROLEUM, OILS AND LUBRICANTS

The majority of petroleum, oils, and lubricants (POL) associated with hospitals are stored in above ground storage tanks (ASTs), underground storage tanks, or 55-gallon drums. Fuel for emergency generators is stored in ASTs with capacities ranging from 500 to 12,000 gallons. Used cooking oil generated in a dining facility is commonly stored in 55-gallon drums or in 400-gallon leak proof ASTs that look like dumpsters.

Sites with POL storage in containers with a capacity of 55 gallons or more are regulated by EPA under 40 CFR [section]112-Oil Pollution Prevention which mandates a spill prevention, control, and countermeasures plan (SPCCP). The SPCCP must be updated by DPW every 5 years. Additionally, anything stored in underground storage tanks is also regulated by the RCRA. Each regulated containment system must be documented in the installation's SPCCP. The SPCCP prescribes inspections, spill response, and spill reporting requirements. Facilities Maintenance and dining facility personnel are required to comply with the SPCCP as this document is effectively the regulation to which the facility must comply, or be cited. In 2014, one Army installation paid $158,700 for RCRA violations related to improper management of underground storage tanks. (7) The site had 20 tanks storing gasoline, diesel, used oil, jet fuel, and anti-freeze for use in vehicles, aircraft, emergency generators, and maintenance carts. The EPA found 19 tanks out of compliance.

CHARACTERIZING HAZARDOUS WASTES

By regulation, any person or entity generating waste is required to determine if their waste is hazardous. The process commonly begins with a review of the materials safety data sheets, which provide information such as pH or flashpoint, or package inserts which are commonly provided with pharmaceuticals. When a process mixes various chemicals, such as in a laboratory, a waste may require chemical analysis. This is accomplished by taking a sample of the waste and contracting with an EPA or state certified laboratory for analysis. If the analysis indicates the waste fits within one of the Characteristic subcategories, it must be managed and discarded as a HW. The Army Institute of Public Health (AIPH) and the USAPHC Regions are available to assist with this process.

MANAGING HAZARDOUS WASTE

The EPA requirements for management of HW are straightforward. At a minimum, the person generating the waste must store the waste at or near points of generation, and the storage site must be under the control of the waste generator. These storage sites are commonly called satellite accumulation points or areas. Containers at the accumulation point must be closed and marked "Hazardous Waste," or with words indicating the contents. Containers must be in good condition, compatible with contents, closed when not adding or removing waste, vapor tight, and spill proof. The quantity of HW permitted at satellite accumulation points or areas is 55 gallons of nonacute HW, or 1 quart acute HW (ie, P-listed). If either limit is reached, the generator must remove the waste in excess of 55 gallons or 1 quart within 3 days. The waste is normally removed by the installation's Directorate of Public Works (DPW) and stored at a DPW maintained facility before being sent to a HW disposal contractor. In some cases, patient care facility personnel will transfer waste to the DPW storage facilities. This is allowed only when the DPW storage facility and the patient care facility are on the same installation. Medical personnel may not transport HW off the installation or bring HW onto the installation unless specific conditions are met. This is relevant for personnel who generate HW at off-post clinics. Under most conditions, transport off the installation is allowed only by personnel who have formal permits and required certifications to transport HW on public roadways. The regional USAPHC must be contacted to confirm legality if HW generated at off-post clinics is to be transported by medical facility personnel to a HW storage or disposal facility. Transport (off post), treatment, and disposal of HW are contracted through the Defense Logistics Agency--Disposition Services (DLA-DS), formerly the Defense Reutilization and Marketing Office.

As a tenant on an installation, the hospital will reimburse the DLA-DS, via DPW, for HW disposal. The conditions and costs will be outlined in an inter-service support agreement between the hospital and DPW. The hospital reimburses DPW using environmental program requirement funds disbursed by the US Army Medical Command, and managed by the MEDDAC Environmental Science and Engineering Officer (ESEO). The ESEO is normally the Chief of Environmental Health within the Preventive Medicine Division. Although the ESEO manages the funding for disposal, Army Regulation 40-3 (8) designates Medical Logistics as responsible for the hospital waste program. Waste management programs are successful when the ESEO and Medical Logistics have a close working relationship. Each role has the support of the installation DPW, with higher level support available from the regional USAPHC.

STATE AND HOST COUNTRY REQUIREMENTS

Because our uniformed personnel move from state to state, it is important to understand that with the exception of Iowa, Alaska, and Hawaii, individual states have the jurisdiction to enact more stringent environmental regulations. For example, the state of Washington defines Sodasorb, a corrosive salt used to absorb carbon dioxide from anesthetized patients, as a corrosive D002 HW. The Washington regulations require any caustic solid that causes a liquid to have a pH of 2 or lower or higher than 12.5 (when exposed to an equal volume of liquid) to be disposed of as a corrosive HW. In contrast, the EPA only regulates liquids.

Pharmaceutical waste is another area where states have applied more stringent requirements or regulatory interpretations. The DLA-DS has contracted with a pharmaceutical reverse distributor that picks up unusable/unwanted pharmaceuticals directly from MEDDAC pharmacies. The process provides credit for the pharmacy to use for future purchases, so this system is utilized Army wide. The contractor will take opened, unopened, expired, unexpired, uncontrolled, and controlled pharmaceuticals from animal and patient care. The dilemma, as indicated earlier, is that some pharmaceuticals are a HW upon disposal. Colorado, Connecticut, California, Kansas, Kentucky (except for Ireland Army Community Hospital), Missouri, New Mexico, New York, Oklahoma, South Carolina, and West Virginia will not allow a pharmacy to return expired or unusable (such as opened containers) HW pharmaceuticals through the reverse distributor. These states require HW pharmaceuticals to be managed and disposed of from the site they were deemed nonusable.

We cannot forget that we have installations and bases overseas. Although host nation environmental agencies do not have the jurisdiction to impose penalties like the EPA, requirements exist overseas., In those locations where the US military is well-established, requirements are published in Final Governing Standards. These exist for Germany, Korea, and Kuwait, for example. Final Governing Standards are a consolidation of status of forces agreements, host nation laws, and DoD Publication 4715.05-G (9) These differ from US requirements, but not significantly. In the absence of Final Governing Standards, personnel follow DoD Regulation DoD Publication 4715.05-G.

THE JOINT COMMISSION

The 2014 Joint Commission EC Standard EC.01.01.01 EP1 (10) requires a hospital to have "a written plan for managing the following: Hazardous Materials and Wastes." The Standard EC.02.02.0110 requires the hospital to:

   maintain a written, current inventory of hazardous materials
   and waste that it uses, stores, or generates. The only
   materials that need to be included on the inventory are
   those for which handling, use and storage are addressed
   by law and regulation.


Compliance with environmental laws is required for conformance with The Joint Commission. Most hospitals have an Environment of Care Committee, a team of personnel that performs internal audits for conformance with the Environment of Care Standard. Personnel conducting a review of a waste management program will be successful only if they have adequate training. On many occasions, the knowledge of personnel assessing the hazardous material and waste programs is limited to hazardous material requirements of the Occupational Safety and Health Act (Pub L 91-596, 84 Stat (1970)). There are several ways to remedy this. The AIPH provides an online waste management course that includes training on the EPA waste management requirements as they relate to patient care. The USAPHC Regions provide training to hospital personnel during assistance visits provided for the ESEO. Local classes are often mandated by the installation. Although those classes normally do not cover hospital wastes and commonly focus on maintenance activities of field units, they are useful to understand local procedures for waste management.

RELEVANT ARMY REGULATIONS

Army Regulation 200-1 (11) directs compliance with environmental legal mandates. Installation tenants are required to comply with federal, state, and local laws as well as installation policies.

Army Regulation 40-61 (12) assigns operational responsibility for waste collection and disposal to the MEDDAC's chief of logistics. The ESEO acts as the principal advisor for the waste management program per Army Regulation 40-11. (13) In most cases, the ESEO is not trained for this responsibility. Therefore, MEDCOM has tasked AIPH, through the USAPHC Regions, to provide on-site assistance to ESEOs. Each region provides such assistance to each MEDDAC ESEO within 6 months of the ESEO's arrival. This process is part of the framework established to help the facility avoid potential liabilities from noncompliance.

INTERNAL AND EXTERNAL INSPECTIONS

A variety of inspection programs internal to the Army, installation, or MEDDAC exists to ensure that hospitals maintain compliance. The inspections, led by MEDCOM assets, include the Organizational Inspection Program conducted by regional medical commands, and the Command Logistics Review Program conducted by MEDCOM Logistics and augmented by AIPH, which reviews the waste management program. The installation's DPW Environmental Division normally has personnel who inspect units and tenants. Some installation DPW programs inspect weekly, others annually. Another type of internal inspection is the Army Environmental Command Environmental Performance Assessment System (EPAS) which audits the entire installation, including tenant organizations. An installation undergoes an EPAS audit every 2 to 3 years.

Inspections external to the Army include EPA and state inspections. These agencies can impose notices of violations upon the installation that can result in civil or criminal penalties. A listing of violations resulting in civil penalties is provided in Table 3. The funds to pay these penalties do not come from the environmental funds managed by the ESEO. The penalties are paid for by the hospital's operating costs, and payment means less money for patient care.

Thankfully, Army MEDDACs have not received a fine since 1998. This is comforting because in the past 3 years, Walgreen's, Target, Walmart, and CVS Pharmacy, paid fines ranging from $800,000 to $22.5 million due to failure to implement successful compliance programs, such as those in the Army. (23)

THE WASTE MANAGEMENT ASSISTANCE VISIT

Within 6 months of an ESEO's arrival, USAPHC Region personnel provide a Waste Management Assistance Visit (WMAV). The visit introduces the ESEO to key personnel of the MEDDAC and installation environmental programs (MEDDAC logistics, DPW HW manager, The Joint Commission team, resource management), provides formal training, assists with a facility walk-through with the ESEO, reviews EPR funding, coordinates waste analysis if necessary, etc. The walk-through identifies instances of noncompliance, but rather than reporting them to a higher echelon, they are used as training aids to teach the ESEO to implement corrective actions based on root causes. If the root cause is systemic, AIPH will engage MEDCOM for a solution. The entire process works to help the hospital attain and maintain compliance.

The USAPHC Region personnel coordinate formal training opportunities, based on the patient care area/ activity prior to the site visit which include state and local regulations, and are catered to personnel. Examples of classes USAPHC Regions provide: Waste Characterization and Management in the Laboratory, Pharmaceutical Waste Management, Environmental Requirements of Joint Commission, and Environmental Liabilities for Commanders and Chiefs.

The assistance team also ensures required waste analysis is completed. All of this provides an effective assistance visit that equips the ESEO to oversee the program and ensures they are introduced to the key players so they may work as a team. The program allows the ESEOs to have direct contact with the respective USAPHC Region, which provide support during their tenure as a MEDDAC ESEO. Compliance is not always simple or straightforward. All parties involved fully support MEDCOM's efforts in the area of environmental stewardship.

CONCLUSION

Patient care encompasses a wide variety of processes and procedures regulated by a variety of federal, state, local, and host nation requirements. Although these requirements are in place to ensure the health of people and their environment, they can be challenging to understand. The ESEO, with the help of the WMAV, is trained to assist MTF personnel to comply with these requirements. In turn, the ESEO can, at any time, contact the USAPHCR Region for support.

REFERENCES

(1.) US Army Public Health Command. Environmental Health Portfolio [internet]. 2014. Command Information Sheet CIS-011. Available at: http:// phc.amedd.army.mil/Documents/USAPHC_CIS011_EHE.pdf. Accessed November 19, 2014.

(2.) US Food and Drug Administration, Office of In Vitro Diagnostics and Radiological Health. ThinPrep 2000 System PMA P950039. Decision Date October 8, 1997. Retrieved from http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpma/pma. cfm?id=6530.

(3.) Resource Conservation and Recovery Act, 42 USC [section]6901 et seq (1976).

(4.) Clean Water Act, 33 USC [section]1251 et seq (1972)

(5.) Hazardous and Solid Wastes Amendments of 1984, Pub L 98-616, 98 Stat 3224 (1984).

(6.) US Environmental Protection Agency. Resource Conservation and Recovery Act. US EPA Website. Available at: http://www.epa.gov/agriculture/lrca. html. Accessed November 20, 2014.

(7.) Fort Wainwright Reduces water contamination risk from fuel tanks in EPA settlement [press release]. Washington, DC: US Environmental Protection Agency; July 2, 2014. Available at: http://www2. epa.gov/newsroom/news-releases. Accessed November 26, 2014.

(8.) Army Regulation 40-3: Medical, Dental, and Veterinary Care. Washington, DC: US Dept of the Army; 2013.

(9.) US Department of Defense. Overseas Environmental Baseline Guidance Document: DoD 4715.05-G. Washington, DC; US Dept of Defense: 2013.

(10.) The Joint Commission. 2014 Comprehensive Accreditation Manual for Hospitals. Oak Brook, IL: The Joint Commission; 2014.

(11.) Army Regulation 200-1: Environmental Protection and Enhancement. Washington, DC: US Dept of the Army; 2007.

(12.) Army Regulation 40-61: Medical Logistics Policies. Washington, DC: US Dept of the Army; 2005.

(13.) Army Regulation 40-5: Preventive Medicine. Washington, DC: US Dept of the Army; 2007.

(14.) Joint Base Elmendorf-Richardson settles with EPA for hazardous waste law violations [press release]. Washington, DC: US Environmental Protection Agency; September 18, 2013. Available at: http:// www2.epa.gov/newsroom/news-releases. Accessed November 26, 2014.

(15.) Eielson Air Force Base near Fairbanks mismanaged hazardous waste and failed to maintain adequate training plan for personnel handling waste [press release]. Washington, DC: US Environmental Protection Agency; March 13, 2012. Available at: http://www2.epa.gov/newsroom/news-releases. Accessed November 26, 2014.

(16.) Fort Belvoir to pay civil penalty for environmental violations [press release]. Washington, DC: US Environmental Protection Agency; September 14, 2011. Available at: http://www2.epa.gov/news room/news-releases. Accessed November 26, 2014.

(17.) Veterans Administration Medical Center in Wichita, Kan., to pay $17,979 civil penalty to settle hazardous waste issues [press release]. Washington, DC: US Environmental Protection Agency; July 26, 2011. Available at: http://www2.epa.gov/news room/news-releases. Accessed November 26, 2014.

(18.) VA hospitals in Leavenworth and Topeka, Kan., agree to pay civil penalty and implement plan to manage hazardous wastes [press release]. Washington, DC: US Environmental Protection Agency; August 18, 2009. Available at: http://www2.epa. gov/newsroom/news-releases. Accessed November 26, 2014.

(19.) Army research facility agrees to pay penalty for hazardous waste violations [press release]. Washington, DC: US Environmental Protection Agency; May 28, 2009. Available at: http://www2.epa.gov/ newsroom/news-releases. Accessed November 26, 2014.

(20.) EPA and the Coast Guard settle hazardous waste violations at Portsmouth, Va. facility [press release]. Washington, DC: US Environmental Protection Agency; October 8, 2008. Available at: http://www2.epa.gov/newsroom/news-releases. Accessed November 26, 2014.

(21.) US EPA enforcement prompts VA medical center to make changes Palo Alto Veterans Affairs Medical Center corrects federal environmental violations [press release]. Washington, DC: US Environmental Protection Agency; September 9, 2008. Available at: http://www2.epa.gov/newsroom/ news-releases. Accessed November 26, 2014.

(22.) Army settles EPA complaints over waste storage at Walter Reed Hospital and Fort Belvoir [press release]. Washington, DC: US Environmental Protection Agency; August 30, 1999. Available at: http:// yosemite.epa.gov/r3/press.nsf/7f3f954af9cce39b88 2563fd0063a09c/f55cfd374f93b31085256a07006b7 35b!OpenDocument.

(23.) Berlin SR. EPA is hitting retail stores for hazardous waste violations. Kilpatrick Townsend Legal Alert [online serial]. June 11, 2013. Available at: http://www.kilpatricktownsend.com/en/ Knowledge_Center/Alerts_and_Podcasts/Legal_ Alerts/2013/06/EPA_is_Hitting_Retail_Stores_ for_Hazardous_Waste_Violations.aspx. Accessed November 20, 2014.

Diane Roberts

AUTHOR

Ms Roberts is an Environmental Scientist in the Environmental Health Engineering Division, US Army Public Health Command Region-West, Joint Base LewisMcChord, Washington.

Table 1. Toxic Hazardous Waste Generated in Patient Care

Constituent   EPA HW Number   Regulatory    Sources of the Waste
                              Level         Stream in Healthcare
                              (mg/L)

m-Cresol      D024            200.0         Insulin (m-Cresol is a
                                              preservative)
Lindane       D013            0.4           Lice and scabies
                                              treatment
Mercury       D002            0.2           Thimerosal preserved
                                              vaccines
                                            Ophthalmic solutions

                                            Amalgam

Selenium      D010            1.0           Topical or shampoo

Silver        D011            5.0           Silver nitrate
                                              cauterizing sticks

Constituent   Concentration
              Range

m-Cresol      1800mg/L and up

Lindane       10,000 mg/L

Mercury       200 mg/L

              200 mg/L

              Up to 400 mg/L

Selenium      250 mg/L and up '

Silver        200 mg/L

Table 2. Listed Category P and U Hazardous Waste Generated from
Patient Care.

P or U Listed     EPA HW   Trade Name          Areas Where
Chemical          Number                       Commonly Generated

Cyclophoshamide   U058     Cytoxan             Inpatient, outpatient,
                           Neosar                and oncological
                                                 pharmacies
Lindane           U129     Gamen               Inpatient and
                           Kwell                 outpatient pharmacies
                           Scabene
Methanol          U154     N/A                 Laboratories
Mitomycin-C       U010     Mutamycin           Oncology, ophthalmol-
                           Mitosol               ogy, and dermatology
Nicotine and      P075     Nicorette Gum       Obstetrics and
salts                      Thrive Gum            inpatient
                           Nicoderm CQ Patch     behavioral health
                           Nicotrol Patch
Phenol            U188                         Physical therapy

Table 3. Civil Penalties Incurred by Federal Facilities for
Violations of EPA Rules and Regulations.

Agency/Installation    Year   Description
Type

Joint Army/Air Force   2013   Failure to:
Installation (14)             * conduct weekly inspections
                              of HW facilities and
                              containers for leakage or
                              deterioration

                              * ensure staff participation
                              in annual HW management
                              training

                              * submit HW tracking reports

Air Force              2012   Improper labeling to clearly
Base (15)                     identify HW, improper
                              management of fluorescent
                              lamps containing mercury, and
                              failure to:

                              * determine if a waste was
                              hazardous

                              * have adequate training plan
                              in place for facility workers
                              handling HW

                              * conduct regular inspections
                              of HW containers

Army                   2011   Failure to:
Installation (16)             * have adequate release
                              detection with respect to
                              piping associated with
                              underground storage tanks

                              * operate an incinerator at
                              adequate temperatures

                              * maintain adequate service
                              records regarding appliances
                              containing 50 or more pounds
                              of ozone depleting
                              refrigerants

VA Medical             2011   Improper disposal of hazardous
Center (17)                   waste through the biological
                              waste system and failure to:

                              * make HW determinations

                              * inspect, label, date, and
                              close HW containers

                              * make arrangements with
                              emergency responders for spill
                              response support

                              * label used oil containers

VA Medical             2009   Unlawful shipping of HW,
Center (18)                   unpermitted on-site
                              incineration of HW, and
                              failure to:

                              * perform proper HW
                              determinations

                              * properly manage HW satellite
                              accumulation containers

                              * keep proper emergency
                              information posted near
                              telephones

                              * conduct weekly inspections
                              of HW storage areas

                              * make proper advance
                              arrangements with local fire
                              and police departments and
                              other emergency responders for
                              responding to emergencies

                              * develop a proper emergency
                              contingency plan

                              * document a personnel
                              training plan

                              * store incompatible wastes
                              without proper segregation

Army                   2009   Accumulated hazardous waste in
Installation (19)             an area with a floor drain
                              without taking measures to
                              prevent a leak or spill, and
                              failure to:

                              * determine whether numerous
                              containers held HW

                              * properly label HW containers

Coast Guard (20)       2008   For operating a hazardous
                              waste storage facility without
                              a permit or interim status and

VA Hospital (21)       2008   failure to label universal
                              waste batteries. For: *
                              storage of HW without a permit

                              * open containers

                              * inadequate facility
                              maintenance

                              * ignitable waste within 50 ft
                              of property line

                              * failure to make a HW
                              determination

Army Medical           1999   For improperly storing
Center (22)                   laboratory chemicals without a
                              permit, and failure to notify
                              the EPA prior to receiving a
                              shipment of hazardous waste
                              from a US Army facility in
                              Thailand

Agency/Installation    Actual Penalty:
Type                   Settlement Agreement

Joint Army/Air Force   $21,000
Installation (14)

Air Force              $45,700: Make improvements to
Base (15)              standard operating procedures

                       and management controls to

                       comply with federal hazardous
                       waste laws.

Army                   $33,000: Agreement to purchase
Installation (16)      environmental friendly
                       refrigerants for $310,000.

VA Medical             $18,000: Agreement to spend
Center (17)            $62,000 to erect an HW accumu-
                       lation building.

VA Medical             $52,000: $482,000 to develop
Center (18)            and implement a program to
                       properly manager
                       pharmaceutical and chemical
                       wastes.

Army                   $89,500
Installation (19)

Coast Guard (20)       $9,280: $89,290 to purchase a
                       new digital x-ray machine for
                       its dental clinic.

VA Hospital (21)       $32,500

Army Medical           $50,400: Agreement to complete
Center (22)            a $1.6 million project to
                       purchase and implement a
                       hazardous material management
                       system.
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Author:Roberts, Diane
Publication:U.S. Army Medical Department Journal
Geographic Code:1USA
Date:Jan 1, 2015
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