Healthcare: Compliance

Use this site to find information to help you understand and comply with environmental requirements. Keep in mind that this site and its associated links may not list all regulatory requirements that might apply to your healthcare facility. State and local governments may also have additional or stricter regulations than the federal government. For more information contact your state/local agencies.

In addition, many of the links below (e.g., Colleges & Universities, Other/General Information) take you to non-healthcare sites. While the information on these sites may not be specific to healthcare facilities, it may provide useful background and general compliance information.

Information Specific to Healthcare

Profile of the Healthcare Industry, February 2005
Designed to give readers an understanding of the major environmental issues associated with the industry. Includes industry background and trends, pollutant releases, pollution prevention, compliance history, voluntary initiatives, and other information.

Healthcare Environmental Resource Center (HERC)
Find pollution prevention and compliance assistance information for the healthcare sector.

Regulatory Interpretations – Healthcare
These links provide information to help hospitals comply with some basic environmental regulatory requirements, but do not include all regulatory interpretations that might be applicable to a facility.

Scope of Hazardous Waste Listing PO42 (Epinephrine), October 15, 2007, See RCRA Online #14778 (PDF) (8 pp., 1.2 MB, about PDF)
Epinephrine fact sheet, Healthcare Environmental Resource Center (PDF) (3 pp., 55 KB, about PDF)
This fact sheet provides developed by HERC contains information to assist healthcare facilities with hazardous waste determinations regarding epinephrine wastes (PO42).
RCRA Online #14788, 4/14/08 (PDF) (1 p., 470 KB, about PDF)
The 1994 epinephrine syringe interpretation states that the residual epinephrine contained in a used discarded syringe is no longer classified as a listed hazardous waste. This interpretation does extend to other P- and U-listed pharmaceuticals administered by syringe. If residue remaining within a needle and syringe exhibits a characteristic, the needle and syringe would need to be managed as a RCRA hazardous waste. This interpretation only applies to syringes. The Agency has recently clarified that epinephrine salts are not included in the epinephrine PO42 listing. Therefore, epinephrine salts and all delivery devices which contact them would be hazardous only if they exhibited one or more of the hazardous wastes' characteristics
Regulation of Nitroglycerine under Revised Mixture and Derived-From Rules, March 18, 2003, See RCRA Online #14654 (PDF) (2 pp., 19 KB, about PDF)
Under the revised mixture and derived-from rules, wastes listed solely for exhibiting the characteristic of ignitability, corrosivity, or reactivity are not hazardous wastes if they do not exhibit a characteristic. Medicinal nitroglycerine is not listed as P081 if it is not reactive because P081 is listed solely for reactivity. If a waste does not exhibit a characteristic at the point of generation, then land disposal restrictions (LDR) are not applicable (SEE ALSO: 66 FR 27286; 5/16/01). The revised mixture and derived-from rules are less stringent, so authorized states may choose not to adopt them. Nitroglycerine will remain regulated as P081 in states that do not adopt the new rules.
Mixed Waste Rule
Region 1 Regulatory Interpretation, December 20, 2005 (PDF) (4 pp., 236 KB, about PDF)

Joint Commission on Accreditation of Healthcare Organizations (JCAHO) Environmental Compliance and Improvement Guide
Guide relates each JCAHO Element of Performance to specific federal regulations, to help facilities achieve compliance with both. The Guide also suggests steps that facilities can take to encourage environmental performance improvements.

EPA Region 2 - Healthcare

Common Violations and Problems Found at Hospitals
EPA Region II has conducted inspections resulting in enforcement actions with penalties.

EPA New England Hospital Environmental Assessment Template - An Environmental Compliance & Pollution Prevention Tool (PDF) (8 pp., 281 KB, about PDF)

University of New Hampshire Data Collection & Compilation of Hospital Assessment Tool (MS Word Doc., 77 pp. 3.2 MB)

EPA Medical Waste home page

Managing Pharmaceutical Waste: A 10-Step Blueprint for Health Care Facilities In the United States, Revised August 2008 (PDF) (93 pp., 489 KB, about PDF)
Updated in August 2008, this Guide will help you develop and implement a comprehensive pharmaceutical hazardous waste management program that combines regulatory compliance and best management practices with waste minimization.

Colleges & Universities

Common Violations

Lead - Based Paint Hazards (PDF) (4 pp., 141 KB, about PDF)

Virtual Campus

Other/General Information

Audits - Discover, Disclose and Correct Violations

Compliance Assistance & Pollution Prevention in New England

EPCRA Tier II Reporting

Enforcement Alert: Mismanagement of Lab Waste Creates Risk of Serious Injury, November 2004 (PDF) (4 pp., 192 KB, about PDF)

Enforcement in New England

Laws and Regulations

Spill Prevention, Control and Countermeasure (SPCC) Rule