Maintaining a Safe Environment of Care – conformance to Joint Commission Standards and avoiding accreditation citations Reply

Joint Commission accreditation is intended to ensure that hospitals provide the highest level of performance and service to their patients. The Joint Commission’s accreditation process seeks to help organizations identify and resolve problems and to inspire them to improve the safety and quality of care and services provided. The process focuses on systems critical to the safety and the quality of care, treatment, and services.

Joint Commission publishes a list of the top deficiency citations about every 6 months. The top ten citations for the first half of 2014 were recently highlighted in the December 2014 issue of the New England Healthcare Engineers’ Society (NEHES) newsletter. One of the top ten citations is specifically related to management of hazardous materials and waste. The Joint Commission Standards include Environment of Care Standard EC.02.02.01, the management of hazardous materials and waste. This standard includes several elements of performance to ensure that hospitals are maintaining a safe environment for their patients, health care professionals, and support staff. Hospitals must be able to demonstrate that they do the following:

– Maintain a written, current inventory of hazardous materials and waste that it uses, stores, or
generates
– Have written procedures, including the use of precautions and personal protective equipment, to
follow in response to hazardous material and waste spills or exposures
– Implement its procedures in response to hazardous material and waste spills or exposures
– Minimize risks associated with selecting, handling, storing, transporting, using, and disposing
of hazardous chemicals, radioactive materials (radiation, x-rays), hazardous energy sources
(lasers, MRIs), and hazardous gases and vapors
– Minimize risk associated with disposing of hazardous medications
– Monitor levels of hazardous gases and vapors to determine that they are in safe range
– Have the permits, licenses, manifests, and MSDSs required for managing hazardous materials and
waste
– Label hazardous materials and waste, identifying the contents and hazard warnings

Demonstrating conformance to this standard includes compliance with several regulations, covering a diverse range of hazardous materials and hazardous waste sources, or “streams.” In addition, there is overlap among the many applicable regulations: OSHA, EPA, DOT, NRC, DOE, state regulations, and local bylaws.

In order to reduce risk, hospitals should consider getting a third party inspection, or audit, to assist on both compliance with applicable hazardous materials and hazardous waste regulations, and conformance to the Joint Commission Environment of Care standard. If you would like to find out more, please contact CAPACCIO’s William Potochniak, PE, at wpotochniak@capaccio.com or Jill Vernes, CHMM, TURP, at jvernes@capaccio.com.

EPA Reduces the Regulatory Burden for Industrial Facilities Using Solvent Wipes Reply

The U.S. Environmental Protection Agency (EPA) recently modified the hazardous waste management regulations under the Resource Conservation and Recovery Act (RCRA) to conditionally exclude solvent-contaminated wipes from hazardous waste regulations provided that the businesses clean or dispose of them properly. Based on EPA’s final risk analysis, the rule, peer reviewed in 2008 and published for public comment in 2009, concluded wipes contaminated with certain hazardous solvents do not pose significant risk to human health and the environment when managed properly. This common-sense exclusion will save industry up to $27.8 million per year.

Wipes are used in conjunction with solvents for cleaning and other purposes by tens of thousands of facilities in a variety of industrial sectors including printers, electronics, furniture, chemicals, automobile repair shops and manufacturers of automobiles.

The final rule excludes wipes that are contaminated with solvents listed as hazardous wastes under RCRA that are cleaned or disposed of properly. To be excluded, solvent-contaminated wipes must be managed in closed, labeled containers and cannot contain free liquids when sent for cleaning or disposal. Also, facilities that generate solvent-contaminated wipes must comply with certain recordkeeping requirements and may not accumulate wipes for longer than 180 days.

Please note, there is already a MassDEP policy on wipes located at this link:

http://www.mass.gov/eea/agencies/massdep/recycle/regulations/waste-and-recycling-policies-and-guidance.html

For more information about the EPA’s rulemaking visit:

http://www.epa.gov/epawaste/hazard/wastetypes/wasteid/solvents/wipes.htm

For more information or assistance, please contact Linda Swift at 508.970.0033 ext. 119 or lswift@capaccio.com.

When to Notify the MassDEP Bureau of Waste Prevention of a Spill or Release Reply

Did you know that you may be required to notify more than one section of the Massachusetts Department of Environmental Protection (MassDEP) when you have a spill that requires implementation of your hazardous waste contingency plan?

Spills or releases of hazardous waste – whether inside the facility or outside to the environment – are reportable to the MassDEP Bureau of Waste Prevention at the appropriate MassDEP Regional Office when there is an imminent or actual emergency involving hazardous waste that requires the facility to activate its hazardous waste contingency plan.  This requirement is in addition to notification (if required) to the MassDEP Emergency Response Section per the Massachusetts Contingency Plan (310 CMR 30.400).

The MassDEP hazardous waste regulations require that Large Quantity Generators (LQGs) have a written hazardous waste contingency plan (310 CMR 30.341(1)(b)) that outlines what to do in the event of an emergency involving hazardous waste.  Even if a facility has to activate the hazardous waste contingency plan for something as simple as calling the Emergency Coordinator for a spill of hazardous waste inside the facility, the facility must notify the MassDEP Bureau of Waste Prevention.  The same applies if you have a bulging or leaking drum of hazardous waste that is overpacked by your emergency response team and then shipped off-site for proper disposal.

These reporting requirements are outlined in 310 CMR 30.341(b) and 310 CMR 30.521(e)(7) and apply to LQGs when there is an imminent or actual emergency involving hazardous waste which triggers the need to implement the hazardous waste contingency plan. This applies even if it does not result in a reportable release pursuant to 310 CMR 40.000 (The Massachusetts Contingency Plan requirements).

We recommend developing a methodology of who to report to and when, and including it in your hazardous waste contingency plan so that it is readily available to personnel responsible for reporting.

What to report, when, and to whom, can be confusing.  Please contact Linda Swift at 508.970.0033 extension 119 or lswift@capaccio.com with any questions you may have regarding reporting spills.

Lucille Servidio to be a Keynote Speaker at the Cancer Council of Australia’s ‘Cancer in the Workplace’ forum Reply

Capaccio Environmental Engineering, Inc.’s Senior Vice President, Lucy Servidio, CHMM, TURP, will be among the keynote speakers at the Cancer Council of Australia’s ‘Cancer in the Workplace’ forum in Carlton, Victoria, Australia. The national forum is set to take place on May 3, 2012.  The forum will provide practical solutions for prevention and is open to occupational health and safety professionals, industry representatives, unions, researchers, public health professionals, and anyone with an interest in occupational cancers.

Ms. Servidio will present information on how and why Massachusetts adopted the Toxics Use Reduction Act (TURA) more than 20 years ago.  She will highlight the law’s importance of reducing the amount of toxics in industry and its role in keeping workers and communities safe.  Ms. Servidio will outline how TURA has evolved and changed over the years and provide information on how TURA has helped to reduce carcinogens in the workplace.  Attendees will receive information on how to create and implement a TUR Plan, and Ms. Servidio will present case studies showing how some Massachusetts companies developed TUR Plans and made their processes more effective while reducing their use of toxic materials.

More information on the program content and the international, national, and local speakers can be found at: http://www.cancer.org.au/File/Aboutcancer/CancerintheWorkplace2012/speakers-cancer-in-the-workplace-forum-flyer-final.pdf

Lucy will be posting blogs pertaining to the conference as well as interesting stories about her travels in Australia. Stay tuned to Capaccio’s regulatory news site for her upcoming blogs.