Hazardous Waste Management at Healthcare Facilities

Common CUPA violations from improper hazardous waste management at healthcare facilities.

Healthcare facilities, such as hospitals, pharmacies, dentist/orthodontist offices, and veterinary clinics, store and handle a wide variety of hazardous chemicals and materials. Certified Unified Program Agency (CUPA) inspectors have recently shifted focus on how these facilities manage hazardous waste accumulation during their annual inspections.

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Provided below are a few common violations:

• Point of Generation
  • With multiple departments on-site, a facility may elect to have all hazardous waste transported to a central area for inventory control and disposal. However, this results in a violation as hazardous waste must be segregated, containerized, and labeled at the point of generation.

• Incorrect Generator Status
  • For facilities with no central handling, departments managing their own hazardous waste separately may consider themselves as a Small Quantity Generator (SQG). However, the accumulation of each department’s hazardous waste may result in the entire facility being categorized as a Large Quantity Generator (LQG). A violation can be assessed for incorrect generator status.

• Illegal Disposal
  • Employees may unknowingly dispose hazardous waste into the medical waste container or down the sanitary sewer.

• Unauthorized/Illegal Treatment
  • Some chemicals may require authorization to be treated. Furthermore, chemicals must be properly neutralized and/or correctly disposed of as hazardous waste.

• Improper Manifesting
  • Because of unauthorized/illegal treatment, a hazardous waste manifest may have the incorrect waste description or list the incorrect waste code.

• Improper Hazardous Waste Identification
  • Without proper labeling on-site, some hazardous waste may be commingled with other hazardous waste streams. This also results in incorrect manifest descriptions and codes.

Violations generally occur from facilities being unaware of CUPA regulations. These hazardous waste management violations are just one of the many components during the overall CUPA inspection. Facilities should be acquainted with each aspect of the inspection to avoid a Notice of Violation.

Alta’s Environmental Health and Safety and Air Quality experts can provide a thorough review of your facility’s hazardous materials program. This includes waste characterization, waste disposal, and reporting requirements. In addition, we offer random site evaluations to prepare your facility for your next annual CUPA inspection. For more information, contact us at info@altaenviron.com or (562) 495-5777.