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"EPA Region 4 Kickstarts Hospital Enforcement Initiative," Waller Environmental Alert

12.01.08

The U.S. Environmental Protection Agency's regional office in Atlanta (which covers Tennessee, Kentucky, Alabama, Georgia, Mississippi, and Florida) has started conducting unannounced "compliance assistance visits" to hospitals in the region, as part of a sector-specific environmental enforcement initiative. In other EPA regions, even prestigious hospitals have been assessed six-figure fines for violations of hazardous waste management or air emissions permitting requirements. The EPA also has required corrective actions to bring operations into compliance, including extensive self-audits, compliance certifications, and obtaining operational permits.

EPA has identified hospitals as an industry sector with environmentally significant operations. Historically the sector has not been a focus of agency compliance efforts. Hospitals often generate hazardous waste through lab work, chemotherapy or pharmacy operations, and many do not realize that the same rules that regulate hazardous waste generation at manufacturing facilities apply to them. In addition, hospitals generally have air emissions point sources that require permits and may have wastewater discharges that are subject to permit limits as well. While EPA has to date focused on hospitals, with their varied operations, the same standards apply to other healthcare facilities with similar operations, including dialysis clinics or ambulatory surgery centers, among others.

Over the last year, EPA has presented seminars and offered compliance assistance focused on hospitals in an effort to raise awareness of environmental issues at the facilities. Now, EPA is conducting multi-media inspections at hospitals across the Southeast in coordination with state environmental agencies. In September, for instance, EPA and Tennessee Department of Environment and Conservation personnel jointly inspected several hospitals in the Chattanooga market to assess environmental compliance. We understand that EPA has developed a schedule that will result in all major markets in the region being subject to similar "compliance assistance visits" in the coming months.

Hospitals would be well served to review their operations carefully to ensure compliance with all applicable environmental regulations. EPA and many states have policies to mitigate enforcement penalties against facilities that conduct self-audits, then promptly disclose and correct discovered violations.

For more information, please contact Bob Martineau, Ed Callaway or Lena Babaeva of Waller Lansden's Environmental practice at 800-487-6380.

The opinions expressed in this bulletin are intended for general guidance only. They are not intended as recommendations for specific situations. As always, readers should consult a qualified attorney for specific legal guidance.

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