Guide to JCAHO Environment of Care Standard 3.10.3
© 2005
Joint Commission on Accreditation of Healthcare Organizations.
Any use of any or all of the Joint Commission standards
and elements of performance beyond this particular tool
is strictly forbidden without the written permission
of the Joint Commission. Citations from JCAHO standards are ©2005 Joint Commission on Accreditation of Healthcare Organizations. Any use of any or all of the Joint Commission standards and elements of performance beyond this particular tool is strictly forbidden without the written permission of the Joint Commission. These pages do not reflect any changes in the standards made after 2005. |
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Introduction Table of Contents Checklist for 3.10.3
Environment of Care Standard 3.10: The organization manages hazardous materials and waste risks Element of Performance 3. Implementation of Hazardous Material and Hazardous Waste Program The organization establishes and implements processes for selecting, handling, storing, transporting, using and disposing of hazardous materials and wastes from receipt or generation through use and/or final disposal, including managing the following: chemicals, chemotherapeutic materials, pharmaceuticals, radioactive materials and infectious and regulated medical waste including sharps. |
This page provides a set of criteria for evaluating how well a facility has implemented its procedures for managing hazardous materials and waste. The criteria have been grouped into categories covering:
Categories: |
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Hazardous Materials Management
Purchasing | ||||
Newly
purchased hazardous materials are added to the inventory.
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Purchasing policy promotes selection
of less hazardous, environmentally preferable products.
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TRACER Staff can describe environmentally preferable products that are in use, e.g. non-toxic or less-toxic cleaners, mercury-free medical devices (thermometers, blood pressure cuffs), or other hazardous chemical alternatives. | ||||
Purchase non-PVC equipment to eliminate patient risks associated with DEHP and environmental risks associated with dioxin formation from the incineration of PVC. | ||||
TRACER Staff are trained to use less hazardous chemicals to reduce exposures, and generate less waste. | ||||
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Handling, labeling, and storage | ||||
Facility
maintains a hazardous materials inventory that lists
all hazardous chemicals used, and their locations.
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Facility
maintains an MSDS management program.
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Hazardous
materials are labeled (with name, hazard warnings, hazard
symbols, etc.), and are stored, handled, and used appropriately.
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Personal
protective equipment is available, appropriate to hazards
and maintained.
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TRACER Staff can describe appropriate handling procedures and personal protective equipment to be used with hazardous material in question | ||||
Storage
cabinets and/or storage rooms are available for the storage
of flammable liquids and other
hazardous chemicals as appropriate.
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Personal protective equipment is reused whenever possible (e.g. gowns). | ||||
Spills | ||||
Spill
clean up procedures are in place in all areas where
hazardous materials are used and/or stored.
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Spill
clean up residues are managed as hazardous waste.
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Spills
are reported to local authorities and National Response
Center, if necessary.
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Spill
control and decontamination
equipment is readily available
in areas where hazardous materials are used.
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Spill
control equipment is maintained in usable condition.
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Eyewashes and showers (ANSI approved) are available in all areas where hazardous materials are routinely used and/or stored, and are checked regularly.
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All
employees who may be involved in spills are appropriately
trained. Spill response team members are HAZWOPER trained.
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TRACER Staff respond appropriately to spills
of hazardous material used in patient care (e.g. mercury, formalin,
glutaraldehyde, etc.).
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Hazardous Material Spill Policy is established and implemented.. | ||||
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Training | ||||
Staff are trained on hazards of materials used and appropriate handling and use of protective equipment. | ||||
Staff are trained and competency tested in appropriate spill response for hazardous materials and waste. | ||||
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Documentation for all training, including staff trained, content covered, competency levels attained, and dates of training, is kept for a minimum of 3 years. | ||||
TRACER Staff respond appropriately regarding use of hazardous material used in patient care, e.g. solvents for specimen analysis, cleaning agents for rooms, sterilants for surgical procedures. | ||||
TRACER Staff respond appropriately regarding clean up of a hazardous material spill used in patient care, e.g. formalin, disinfectant, glutaraldehyde. | ||||
TRACER Staff respond appropriately regarding disposal of hazardous material used in patient care, e.g. solvents for specimen analysis, aerosols, cleaning agents for rooms, sterilants for surgical procedures, drug disposal. | ||||
TRACER Staff can describe elimination and/or
substitution of less hazardous materials as part of
the facility’s environmental improvement, e.g.
use of biodiesel, rechargeable batteries, energy-efficient
equipment and vehicles, mercury-free devices, ethylene
oxide elimination. |
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Mandatory Hazard Communication Training during new employee orientation sessions includes environmental improvement elements such as waste prevention, using less materials, commitment to environmental performance, etc. | ||||
Waste prevention and proper waste handling requirements are included in all employee job descriptions, according to a progressive facility-wide policy. (This is important, particularly where safety issues are concerned. It will also emphasize the importance of participation in pollution prevention commitments.) | ||||
More resources | ||||
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Recordkeeping and reporting | ||||
The
facility has obtained an EPA Identification Number.
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Generator
status is determined and reviewed monthly.
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Facility is working toward moving to smaller quantity
generator status by minimizing hazardous
materials present on site. |
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The
basis for hazardous waste determinations is documented.
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Facility submits
Biennial Reports on EPA Form 8700-13A each even-numbered
year.
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Manifest
copies are managed properly (e.g. appropriate copies
are received from the treatment facility and are routed
to the regulatory authority).
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Manifests, Biennial Reports, and records
of test results and analyses are kept on site
for a minimum of three years.
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Land
Disposal Restriction notices are kept for a minimum of
three years.
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Weekly
inspections of the hazardous waste storage areas are
performed and documented according to written procedures Inspections
include checking for leaks, corroded containers, and
other potential problems.
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Hazardous waste determination | ||||
A RCRA hazardous
waste determination has been made for all solid
waste that is generated. Examples
of potential sources of hazardous waste include:
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Containers with hazardous materials, (e.g. aerosol cans,
chemotherapy agents) are completely emptied or managed
as hazardous waste.
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Containers that
held P-listed wastes are managed as hazardous waste.
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Mixed
wastes (e.g., radioactive and hazardous wastes, infectious
and hazardous wastes) are properly evaluated and disposed
of.
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Facility is minimizing hazardous waste generation to avoid making and documenting determinations. | ||||
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Storage | ||||
Hazardous waste
storage areas are secure, and are operated to prevent
releases to the environment (e.g. facility has provided
for secondary containment of containers).
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Hazardous
waste is stored in non-leaking, sturdy, compatible containers
that are kept closed unless adding or removing waste.
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Storage areas are clean and organized. | ||||
Containers are protected from weather, fire, physical damage, and vandals. | ||||
Adequate
aisle space is maintained in the hazardous waste storage
area to ensure access to containers in event of spills
or leaks.
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Weekly
inspections of the hazardous waste storage areas are
performed, and are documented according to written procedures,
to check for leaks, corroded containers, or other problems.
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Containers of hazardous waste are marked with the words ¿Hazardous
Wasteî, and a descriptive name of the waste.
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Incompatible wastes are segregated.
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Precautions are taken to prevent accidental ignition
of ignitable waste, or reaction of reactive waste, by
(among other measures) separating the waste from sources
of ignition or reaction (e.g. open flames, smoking, sparks,
welding, hot surfaces).
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Satellite accumulation | ||||
Containers are located within the immediate operator
control and are inspected daily.
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Containers are labeled with a descriptive name of the
waste and the
words “Hazardous
Waste”.
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When
satellite accumulation containers are full they are moved
to the hazardous waste storage area within three days
and marked with the accumulation start date.
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Spills | ||||
Spill
clean up procedures are in place in all areas where
hazardous waste is handled and/or stored
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Spill
clean up residues are managed as hazardous waste.
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Spills
are reported to local authorities and National Response
Center, if necessary.
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Spill
control and decontamination
equipment is readily available
in areas where hazardous waste is handled or stored.
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Spill
control equipment is maintained in usable condition.
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Eyewashes
and showers (ANSI
approved) are available in
all areas where hazardous waste is routinely handled
and/or stored,
and are checked regularly.
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All
employees who may be involved in spills are appropriately
trained. Spill response team members are HAZWOPER trained.
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Disposal and Transportation | ||||
Hazardous
waste is shipped offsite for treatment or disposal within
appropriate timeframes based on generator status (90
days Large Quantity Generator or 180 days Small Quantity
Generator).
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Determination of treatment requirements for land disposal
of hazardous waste have been performed.
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Hazardous
waste must be shipped to a facility permitted to handle
the waste.
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Hazardous
waste must be shipped using a hazardous waste manifest.
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Waste
is properly marked and packaged for transportation.
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Hazardous
waste transport vehicle is properly placarded if necessary.
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Contingency Planning | ||||
A Contingency
plan is in place if the facility is a Large Quantity
Generator.
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An emergency
coordinator is designated and has authority to commit
resources if necessary.
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The
provisions of the hazardous waste contingency plan are
carried out immediately whenever there is a fire, explosion,
or release of hazardous waste or hazardous waste constituents
which could threaten human health or the environment.
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Emergency
information is posted near the telephone in the hazardous
waste storage area.
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Arrangements are made with local authorities to respond
to a hazardous waste emergency.
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Training | ||||
TRACER Staff can describe appropriate response
for hazardous waste spill.
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Staff
are trained in, are thoroughly familiar with, and competency
has been tested in, proper waste identification, handling and emergency
procedures relevant to their jobs.
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Personnel
are trained regarding satellite accumulation.
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Staff is periodically reminded that hazardous waste should never be improperly disposed of down the drain or as solid or infectious waste. |
Facility promotes recycling
all potential recyclable materials (e.g., paper, cardboard,
aluminum, steel, solvents, construction wastes, grease
or food scraps, etc.). Bins are clearly
labeled, and are conveniently located throughout the
facility. |
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Facility promotes reduction of solid waste by choosing products with less packaging, using less materials (source reduction). | |
Materials and equipment are reused and/or reprocessed to the greatest possible extent. | |
Food and organic waste is composted. |
Regulated Medical (Infectious) Waste
A
comprehensive medical waste management plan, "Bloodborne
Pathogens (BBP) Exposure Control Plan", is in place that
includes identification, proper
segregation, and management of waste from generation
to disposal.
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Facility has done a risk assessment to identify employee risks to BBP exposures and other related BBP risks | ||||
Infectious waste
is properly segregated according to state-specific definitions.
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The facility's RMW segregation plan ensures that
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Infectious waste
containers are sturdy and labeled with the universal
biohazard symbol.
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Signs to assist with proper
segregation of infectious waste are placed above containers.
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Staff is trained and competency tested on proper
segregation and disposal of infectious waste.
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Infectious
waste containers are stored onsite in secured area away
from public areas, and are kept on site for no longer
than period of time permitted by applicable state regulation.
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Infectious waste
containers intended for transport are properly packaged
and marked.
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Waste is placarded
for transport, if necessary.
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Facility is registered as
generator of RMW with state and
local authorities if required.
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Regulated
medical waste is tracked and documentation kept in accordance with state rules.
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Facility performs a waste assessment and documents the amount of RMW generated per month to identify opportunities for reduction. | ||||
Using non-polyvinyl chloride IV bags, tubing and other
equipment to diminish dioxin emissions and reduce when
waste is incinerated |
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Facility has developed and implemented a comprehensive RMW minimization plan that provides for:
and includes measures such as:
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If RMW is incinerated or otherwise treated on site: | ||||
Incinerator is operated within permit parameters and records are kept (40 CFR 70).[not specific to incinerators] | ||||
Design capacity of the incinerator is not exceeded (40 CFR 70). | ||||
Hazardous waste is not burned in the incinerator unless allowed by permit (40 CFR 70). | ||||
Facility renders RMW non-infectious through autoclaving
or other non-incineration technologies to
reduce the dioxin,
heavy metal, and particulate emissions associated with incineration. |
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Waste fluorescent
lamps, batteries, mercury thermostats and certain pesticides are
either managed as Universal Waste or
are evaluated for hazardous waste management.
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Containers holding
Universal Waste are structurally sound and kept closed
except when adding or removing waste.
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Containers are properly
labeled with the name of the universal waste and the
accumulation start date. (e.g., “Universal Waste
Batteries”).
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Storage space for
universal waste is maintained.
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All hospital staff
who handle Universal Wastes e.g., (batteries) are trained
in proper handling and emergency response procedures.
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Records, documents,
and procedures indicate that universal waste is recycled
within one year of initial accumulation.
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Crushed fluorescent
lamp residue is evaluated for
hazardous waste characteristics.
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Compact fluorescent bulbs are in use, and purchasing policy and practices indicate preference for compact fluorescent bulbs. | ||||
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Purchasing policy and practices
indicate preference for rechargeable batteries and
equipment. |
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Procedures for recharging batteries and equipment are
in place and are actually being carried
out. |
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Asbestos | ||||
An asbestos assessment
has been done to confirm any asbestos containing building
materials (ACBM) present in the facility, including sampling
results if appropriate.
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Employees who may
potentially disturb or come into contact with asbestos
been trained at least to the "awareness level" with the
required OSHA 2hr Asbestos Awareness training.
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Areas accessible
to the public having asbestos-containing building materials
with the potential for being disturbed have been properly
labeled.
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Manifests are complete
(e.g. no information missing) and appropriately routed.
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Abated asbestos
is disposed of at an approved (either EPA or state) facility.
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Ten day prior notification
is given to local authorities prior to large asbestos
projects and records of the notice are retained.
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When conducting asbestos abatement, proper separation from occupied areas is maintained and appropriate clearance monitoring conducted prior to opening the area for occupancy. | ||||
Air monitoring is
conducted during and post abatement, records are kept
and clearance obtained.
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CFCs | ||||
Air conditioning
systems having over 50 pounds of CFC (chlorofluorocarbons)
refrigerant charge are maintained free from leaks of
CFC and records of leaks and maintenance are kept.
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All technicians
conducting repair and maintenance activities on CFC air
conditioning and refrigerant systems are EPA-certified.
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Refrigerant recovery
devices meet EPA standards.
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Efficient systems are used for air conditioning to minimize
pollution from chlorofluorocarbon use and air emissions. |
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Ethylene Oxide | ||||
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The facility properly maintains ethylene oxide abaters and refreshes scrubber catalysts on schedule. | |||
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Facility has a valid
air quality permit for any EtO sterilizer or aerator.
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Areas utilizing EtO are provided with a continuous alarm monitor. | |||
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An up-to-date, written EtO emergency plan is in place, with annual training implemented and records kept. | |||
Ethylene oxide is eliminated from the facility. |
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Glutaraldehyde | ||||
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Glutaraldehyde-based high level disinfectants are properly monitored, effectively contained, and safely handled. | |||
To reduce exposures and the amount of glutaraldehyde used, operating procedures are reviewed and improved with use of overhead hoods, employee training and monitoring | ||||
Glutaraldehyde is replaced with less hazardous material. | ||||
Mercury | ||||
Sanitary sewer drainpipes
suspected to contain mercury are cleaned or replaced.
Old pipes, biofilm and/or water used to clean pipes
are recovered, tested for mercury content, and disposed
of properly. |
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Facility has conducted a mercury inventory, and has
established a mercury elimination plan that includes
a schedule for the removal and replacement of known
mercury-containing items. |
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Facility participates in the Practice Greenhealth Making
Medicine Mercury Free Award program. |
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Pesticides | ||||
Pesticides classified
for restricted use are applied only by licensed applicators.
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Restricted pesticides
are not used.
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Pesticide containers
are triple rinsed.
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The rinsate is managed
as hazardous waste if it is not used.
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A hazardous waste
determination is made and documented for pesticides that have not been used up
and are being discarded.
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Warning signs are posted and staff notified when pesticides are applied. | ||||
Facility has instituted
an Integrated Pest Management program with the following
elements:
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Petroleum Products (see also Used Oil and Tanks below) | ||||
Energy is conserved, thereby reducing the use of oil
and petroleum products. |
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Purchasing policy and other evidence indicates a preference
for energy efficient equipment, that does not burn
oil or diesel fuel. |
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Bio-diesel is used in place of diesel in generators
and other equipment. |
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Pharmaceuticals and chemotherapeutic agents | ||||
Chemotherapeutic and
pharmaceutical wastes are evaluated
for hazardous waste classification. Process for evaluation
is documented.
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Waste containers
holding U-listed chemotherapeutic and pharmaceutical materials are completely empty
or managed as hazardous waste.
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Waste containers holding the P-listed chemotherapeutic drug arsenic trioxide and P-listed pharmaceuticals are managed as a hazardous waste, and in many situations also as RMW. | ||||
Used syringes containing RCRA-regulated hazardous waste are managed as RMW. | ||||
TRACER Pharmacy,
oncology and nursing staff are proficient in identifying
and managing hazardous chemotherapeutic and
pharmaceutical waste.
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TRACER Staff can describe process used for chemotherapeutic and pharmaceutical waste evaluation and basis for choice of disposal. | ||||
Overt amounts of chemotherapeutic drugs are managed as hazardous waste | ||||
Trace amounts of chemotherapeutic drugs are incinerated at a permitted RMW incinerator. | ||||
A waiver for federal exclusion for nitroglycerin in finished dosage forms has been submitted and is on file. | ||||
Pharmacy and oncology staff are trained regarding waste reduction and pollution prevention opportunities and practices. | ||||
Non-regulated chemotherapeutic wastes are managed in the same way as regulated chemotherapeutic wastes. | ||||
IV bags and related
equipment that are polyvinyl chloride (PVC)- and DEHP-free
are used. Reasons include:
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Polychlorinated Biphenyls (PCB) | ||||
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PCB equipment is properly labeled, and inspected. need citations | |||
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Disposal of PCB containing items are handled as appropriate. | |||
PCB-containing equipment and oil is eliminated. |
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Radioactive Materials and Waste | ||||
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Inventory and management
plans for hazardous energy sources; ionizing and non-ionizing
radiation, lasers, microwaves and ultrasound devices
are available.
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Staff is trained and competency tested in appropriate spill response for radioactive materials and waste. | |||
The
facility is eliminating or reducing the use radioactive
material, to the extent that it is possible to substitute
non-radioactive or less radioactive isotopes (e.g.
using isotopes with lower level radiation or shorter
half-lives for non-therapeutic laboratory applications). |
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The
facility is eliminating the use of radioactive materials
with longer half-lives to the greatest possible extent
for all applications. |
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Used Oil | ||||
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The
organization properly collects used oil from vehicles,
and physical plant equipment (emergency generators, compressors,
etc.)
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Used
oil is stored in sturdy compatible containers labeled “used
oil” that are kept closed.
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Oil-containing equipment is not leaking.
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Spill
control equipment is available and used when necessary.
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Spills
are reported to local and federal authorities.
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Used
oil is recycled and receipts are kept indicating such.
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Staff
is trained and competency tested in appropriate spill
response for used oil.
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A hazardous waste determination is made and documentation is kept for used oil that is destined for disposal. | |||
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Used oil filters
are drained for a minimum of twelve hours to ensure all
residual oil is collected before disposing of the filters
as scrap metal.
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Recordkeeping and reporting | ||||
Air permits are
modified when fuel usage changes.
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Certificates to
Operate and Permits are not permitted to expire.
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Calculations are
done and kept on site verifying air permit requirements
for boilers, incinerators, generators or other releases
to the air( e.g. ethylene oxide). (40 CFR 70).
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Boilers, generators | ||||
Bio diesel is considered and possibly used with emergency
generators. |
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Oil burning equipment is well maintained. Logs and documentation evident. | ||||
Energy efficient boilers and generators are used to
minimize air pollution (Documentation: EC3.10.7).
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Policies indicate preference for energy efficient equipment
and practices throughout the facility to minimize
fuel use. |
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Incinerator | ||||
Incinerator is operated within permit parameters and records are kept (40 CFR 70) [not specific to incinerators]. | ||||
Design capacity of the incinerator is not exceeded (40 CFR 70). | ||||
Hazardous waste is not burned in the incinerator unless allowed by permit (40 CFR 70). | ||||
Incineration is eliminated or reduced as a waste treatment
or disposal method. (Incineration creates air
pollution such as dioxins, acid gases (such as hydrogen
chloride), carbon monoxide, and heavy metals. Air
pollution from incinerators is deleterious to community
health.) |
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All waste is minimized to eliminate emissions to air. |
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Tanks | ||||
Spill Containment
and Countermeasures plan is in place for aggregate
aboveground storage greater than 1320 gallons.
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Tanks are permitted or registered with either EPA or local authorities. | ||||
Underground storage
tanks must have been upgraded or replaced by 12/22/98
to meet integrity, cathodic protection, leak and overfill
protection requirements.
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Maintenance and calibrating procedures are enacted to ensure tank monitors are working appropriately. | ||||
Tanks are inspected on weekly/monthly basis as per EPA or local regulations. | ||||
Tank alarm system can be heard or otherwise adequately communicated to operators. | ||||
Procedures are written and available for steps to be taken when tank alarm sounds. | ||||
Tank overfill protection
equipment is monitored.
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Corrosion protection
for tanks is adequate. If cathodic protection
is used it is inspected and replaced as required.
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Release detection
equipment for tanks and piping is adequate and up to
date. Monitor and record condition.
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Suspect releases
or spills are reported to EPA or appropriate local
authority.
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TRACER Staff respond appropriately regarding steps to be taken in the event of tank alarm, spill, or leak. | ||||
Tank parts are appropriately labeled with appropriate American Petroleum Institute (API) code. E.g. Hexagon for #2 Fuel Oil (40 CFR 280) | ||||
Equipment on tank to shut down when tank reaches 95% of capacity during fueling. | ||||
Tanks are located
a safe distance from other areas of the facility.
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Use of underground storage tanks is eliminated, minimizing risk of leaks and spills. | ||||
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Wastewater | ||||
Review of local rules and codes to ensure all discharges to sewer (laboratories, pharmacy, surgery, dialysis, central processing, nutrition services, etc.) are permitted and/or if pretreatment is required (40 CFR 403). [can't find 403] | ||||
All discharges to sewer are reported to local wastewater authority (local permits, 40 CFR 403). | ||||
Spill
Prevention Control and Countermeasure Plans are in
place, including adequate secondary containment of
storage tanks.
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All discharges to the sewer are evaluated assure conformance with local, state and federal restrictions, e.g. formalin, glutaraldehyde, pharmaceuticals, alcohols, laboratory discharges, x-ray chemicals (40 CFR 403). | ||||
All discharges to the sewer are evaluated for hazardous waste and reported to local sewer are evaluated for hazardous waste and reported to local sewer and hazardous waste authorities. (40 CFR 403) | ||||
Direct, point source discharges are required to obtain National Pollution Discharge Elimination System (NPDES) permits under 402 of the Clean Water Act (CWA) | ||||
If the facility has any septic tanks, drain fields, lagoons, or other on-site wastewater disposal areas, they are properly permitted | ||||
Hazardous materials or waste storage or process areas DO NOT have floor drains that might allow a release of a hazardous chemical to the environment | ||||
Wastewater is monitored, tested and reported as per local, state and/or federal permit requirements, and exceedances are managed appropriately. | ||||
Wash water from
kitchen cleaning or other cleaning operations is not
discharged to the storm sewer without a National Pollutant
Discharge Elimination Permit.
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Discharges
to sewer are reduced or eliminated. |
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