Guide to JCAHO Environment of Care Standard 3.10.7

© 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 3.10.7

Environment of Care Standard 3.10: The organization manages hazardous materials and waste risks

Element of Performance 7. Hazardous Material and Hazardous Waste Documentation

The organization maintains documentation, including permits, licenses,
and adherence to other regulations.
 

This page provides a set of criteria for evaluating a facility's system for determining what documentation is required, and ensuring that required documentation is on-hand and accessible.

The criteria are divided into several topic areas.

= Compliance
= Environmental Improvement
= Tools and Resources

Hazardous Materials

  Copies of the following reports are on site and available for review:

-- inspection reports (e.g. tours, insurance, OSHA, College of American Pathologists (CAP), fire marshal, US EPA, state environmental and/or health departments, etc.)

   

Tours: EC1.20.1,4,5  

-- facility response and mitigation of deficiencies on inspection

-- results of employee monitoring for exposure to hazardous materials such as:
  • asbestos

   

  Occupational exposure, asbestos: 29 CFR 1910.1001
  • ethylene oxide

   

  Occupational exposure, ethylene oxide: 29 CFR 1910.1047
  • formaldehyde

   

  Occupational exposure, formaldehyde: 29 CFR 1910.1048
  • mercury

   

   
  • radiation

   

  Occupational exposure, ionizing radiation: 29 CFR 1910.1096

-- records of industrial hygiene monitoring of noise, dust and mold [need OSHA cite]

-- records for clean up for hazardous materials spills (e.g.  mercury)  including air monitoring, proper clean up, reporting to authorities [need OSHA cite]

The  number of exposure monitoring reports required is reduced due to the reduction or elimination of hazardous materials (such as pesticides, disinfectants, cold sterilants, blood borne pathogens, etc.).

Records indicate that staff are trained on hazards of materials used, including training on:
  • asbestos
  • blood and body fluids
  • chemicals
  • disinfectants
  • pesticides
  • petroleum products

and on appropriate handling and use of protective equipment.

   

Competence: HR2.10.9

Roles (Risks): HR2.20.1

Personal protective equipment selection: 29 CFR 1910.120 (g)(3)

Personal Protective Equipment (general): 29 CFR 1910.132

Personal Protective Equipment (eye, face): 29 CFR 1910.133

Personal Protective Equipment (respiratory): 29 CFR 1910.134

Personal Protective Equipment (head): 29 CFR 1910.135

Personal Protective Equipment (foot): 29 CFR 1910.136

 (HR 2.10, 29 CFR 1910.132-139, 1910.1030, 1910.1200).

Records indicate that staff preparing hazardous materials for shipment are trained on Dept of Transportation rules for marking, packaging, shipping papers, placarding and transport.

   

Shipping papers: 49 CFR 172.201

Shipping papers (HazMat descriptions): 49 CFR 172.202

Hazardous waste manifest (DOT): 49 CFR 172.205

Labeling (DOT): 49 CFR 172.400

Placarding: 49 CFR 172.500

HazMat employee training (DOT): 49 CFR 172.704

Records indicate that staff are trained in, and are thoroughly familiar with, proper waste handling and emergency procedures relevant to their jobs.

   

Implementation: EC3.10.3

Competence: HR2.10.9

Roles (Incident): HR2.20.3

HERC: Managing Hazardous (RCRA) Wastes

Hazardous waste operations (HAZWOPER) training: 29 CFR 1910.120 (e)

Employees familiar with HazWaste handling: 40 CFR 262.34 (d)(5)(C)(iii)

HazMat employee training (DOT): 49 CFR 172.704


Hazardous Waste

A RCRA hazardous waste determination has been made for all solid waste that is generated.  Examples of potential sources of hazardous waste include:
  • waste pharmaceuticals  HERC:  Pharmaceutical Wastes
  • laboratory chemicals and reagents
  • formalin
  • chemicals/anesthetics used in surgery
  • waste rags with solvent
  • aerosols
  • disinfectants
  • sterilants
  • x-ray contrast media
  • waste electronics

   

=Implementation: EC3.10.3

HERC: Hazardous Waste Determination

Hazardous waste definition: 40 CFR 261.3

Hazardous waste determination: 40 CFR 262.11

The basis for hazardous waste determinations is documented.

   

 

Hazardous waste recordkeeping: 40 CFR 262.40

Copies of reports sent regularly (either annually or biennially) to state or federal authorities regarding hazardous waste generation are kept on site for a minimum of three years.

   

<Implementation: EC3.10.3

HERC: State Hazardous Waste Locator

Hazardous waste recordkeeping: 40 CFR 262.40

The facility maintains documentation verifying that hazardous waste storage inspections have been performed.

   

Inventory  EC 3.10.2

Hazardous waste storage inspections (LQG): 40 CFR 265.17

Hazardous waste manifests and other documents from waste hauler and disposal facility are kept on site and maintained appropriately for a minimum of three years.

   

 

Manifests 40 CFR 262.20

Hazardous waste recordkeeping: 40 CFR 262.40

Quantities of hazardous wastes shipped on manifests, and number of hazardous waste shipments, are reduced.

Records are kept indicating recycling of universal waste and used oil.

   

Manifests (universal waste): EC3.10.8

Manifests (used oil) EC3.10.8

Universal waste accum. time (SQG): 40 CFR 273.15

Universal waste accum. time (LQG): 40 CFR 273.35

Used oil definition: 40 CFR 279.10

Used oil specifications: 40 CFR 279.11

Used oil practices: 40 CFR 279.20

Used oil storage: 40 CFR 279.22

Used oil off-site shipments: 40 CFR 279.24

Land Disposal Restriction notices are kept for a minimum of three years.

   

=Implementation: EC3.10.3

Land disposal restrictions (index page): 40 CFR 268

Land disposal restrictions, recordkeeping: 40 CFR 268.7

  Chemotherapeutic Waste

Chemotherapeutic wastes are evaluated for hazardous waste classification.  Process for evaluation is documented.

   

  Hazardous waste determination: 40 CFR 262.11

Chemotherapy hazardous wastes are reported biennially to the EPA, and reports are kept on site for at least three years.

   

  Hazardous waste determination: 40 CFR 262.11

Chemotherapy hazardous wastes are reported as required by state and local authorities.

   

  HERC: State Hazardous Waste Locator
 

Regulated Medical (Infectious) Waste

Facility is registered with state and local authorities if required, and has obtained all required permits.

   

 

HERC: State RMW Locator

Regulated medical waste is tracked and documentation kept per state rules, to ensure the material arrives at an appropriate destination for treatment and final disposal.

   

 

HERC: State RMW Locator

Facility maintains documentation of annual reviews carried out to identify safer medical devices designed to eliminate or minimize occupational exposure to bloodborne pathogens.  Frontline workers should be solicited for input.

   

Safety plan EC1.10.1

Bloodborne pathogens: 29 CFR 1910.1030

Facility maintains employee medical and training records.

   

 

Bloodborne pathogens: 29 CFR 1910.1030

Facility tracks and documents the amount of RMW generated monthly to identify opportunities for reduction.
Sources and quantities of regulated medical waste are measured and documented to facilitate RMW reduction.

Employee exposure reports for blood borne pathogen splashes due to pouring of suction canisters is reduced through the use of fluid management systems that eliminate or reduce use of suction canisters.
 

Materials of Concern

  Asbestos [need basic compliance info]

Abated asbestos is disposed of at an approved (either EPA or state) facility.

   

=Implementation: EC3.10.3

NESHAP, asbestos, waste disposal: 40 CFR 61.150

Ten day prior notification is given to local authorities for large asbestos projects and records of the notice are retained.

   

=Implementation: EC3.10.3

NESHAP, asbestos, demolition and renovation: 40 CFR 61.145

Air monitoring is conducted during and post abatement, records are kept and clearance obtained.

   

Implementation: EC3.10.3

NESHAP, asbestos, demolition and renovation: 40 CFR 61.145

Manifests are complete (e.g. no information missing) and are appropriately routed.

   

Implementation: EC3.10.3

Manifests: EC3.10.8

Manifests (EPA): 40 CFR 262.20

  Pesticides

Records indicate staff using disinfectants, cold sterilants and pesticides have been trained on their hazards and appropriate use.

   

Plan: EC3.10.1

Hazard communication (OSHA): 29 CFR 1910.1200

Pesticide applicator licenses are maintained or are part of pest management contract.

   

Plan: EC3.10.1

Implementation: EC3.10.3

Pesticides, criteria for restriction: 40 CFR 152.170

Pesticides classified for restricted use: 40 CFR 152.175

Pesticide applicator categories: 40 CFR 171.3

Documentation of pesticides applied maintained to ensure appropriate exposure monitoring and to ensure restricted pesticides are not used.

   

Plan: EC3.10.1

Implementation: EC3.10.3

Pesticides classified for restricted use: 40 CFR 152.175

 

An Integrated Pest Management (IPM) program is in place.

If the organization is a federal facility, documentation that an integrated pest management program is in place.  CHECK THIS REQUIREMENT

Pesticide applicator licenses are no longer needed due to no pesticides being applied at facility.
   Petroleum Products

Tanks are permitted or registered with either EPA or local authorities.

Number of tank permits required is reduced due to minimized use of petroleum products (or hazardous waste/material storage).
 

Facilities and equipment

  Air (general) [need basic compliance info]

Up to date air permits are available on site for review.  Permits may be required for:
  • boilers
  • incinerators
  • fume hoods
  • ethylene oxide sterilizers

   

Implementation: EC3.10.3

 

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).
  Boilers
bullet Air permits are modified when fuel usage changes.

   

=Implementation: EC3.10.3

State air permit programs (index page): 40 CFR 70

bullet Certificates to Operate and Permits are not permitted to expire.

   

=Implementation: EC3.10.3

State air permit issuance and revisions:  40 CFR 70.7

Air permits are modified when fuel usage changes (40 CFR 70).Certificates to Operate and Permits are not permitted to expire (40 CFR 70).
bullet
Permits for boilers are not needed due to energy efficient boilers.
  Incinerators

Incinerator is operated within permit parameters and records are kept (40 CFR 70).

Hazardous waste is not burned in the incinerator unless allowed by permit (40 CFR 70).
bullet
No on-site incineration is carried out at the facility.
  Ethylene oxide sterilizers
bullet
Ethylene oxide has been eliminated as a sterilant.
  Wastewater

Facility has wastewater discharge permit indicating all discharges to sewer have been reported and are permitted.  (local permits, 40 CFR 403).[not a CFR citation]

Facility maintains copies of wastewater monitoring results (local permits, 40 CFR 403).

Wastewater monitoring requirements are diminished due to minimized discharges to sewer.