Last month, wediscussed在资源保护和恢复法案（RCRA）下，过去几年的联邦危险废物法规如何为医院，医疗保健有关的药房和实验室，零售设施和学术机构等行业创造了挑战。从历史上看，在执行RCRA的合规性时，这些行业被忽视了，但最近必须加强由于联邦RCRA的变化和随后的监管审查增加的挑战。在这篇博客中，我电竞app竞猜们将讨论一些实际步骤，即这些发生器现在可以达到满足合规性。
After a facility, operation or business has completed an accurate, up-to-date and documentable waste inventory (which allows one to determine the actual hazardous waste compliance requirements that apply to their locations), it must develop and implement practices and procedures for hazardous waste notification; segregation; collection; storage; training; spill response; manifesting; disposal; and reporting (if required). Some of the practices and procedures for these “non-industrial” sectors will be similar but each has unique challenges. From a facility or business-wide perspective here are some practical steps to consider for each of these sectors based on their unique industries:
Hospitals, Hospital Systems and Healthcare-Related Businesses
Since this industry – encompassing urban hospitals, small clinics, medical laboratories, specialized pharmacies and more – is so diverse, one of the primary challenges is distinguishing the rules surrounding regulated medical wastes (RMW), such as infectious waste and sharps, from those relevant to chemical, pharmaceutical and other regulated wastes. In general, it works best to address the compliance requirements specific to RMW separately and independently from the compliance requirements for chemical and pharmaceutical wastes since this is the side that RCRA hazardous wasteregulations适用于。这是一个教育挑战，传统上，这些行业的许多员工和专业人士都没有收到足够的培训或有关为什么RMW与化学/制药废物有关的培训或信息。在我们的咨询工作中，我们发现这个商业部门的许多人定期与其他重要的监管定义术语相混淆，如EPA / RCRA危险废物;点危险材料;Osha危险化学品;最后，但并非最不重要的是Niosh危险药物。
Educational Institutions
Facilities, locations or campuses under the educational umbrella have their own diverse wastes and waste streams which trigger management challenges. To complicate things further, consider the diversity within medical center campuses operated by educational institutions. One practical suggestion is for compliance leaders to engage the leader(s) of each department at least annually to help them accurately re-assess their wastes and waste streams, and look for opportunities to reduce or eliminate the use of products that trigger the highest risks and costs related to RCRA hazardous wastes. Concurrently, environmental compliance leaders should provide education to department leaders on the environmental and employee health and safety risks these products and chemicals trigger for the institution. Furthermore, this knowledge may motivate department leaders to collaborate more in improving overall program management and reducing risks.
零售商
Given the complexity and evolution of hazardous waste regulations across the country and the nature of the retail sector, the challenge to comply is evident. Often, RCRA hazardous waste management programs are structured as “one-size-fits-all” by the corporation with their selected national waste services vendor. This approach may match the type of products sold and/or wastes generated in all locations, but doesn’t fully address the state-by-state or local (i.e. county or other) regulatory jurisdictions that often apply. Since there is typically little chance to develop and maintain local environmental compliance expertise at each location, we advise retail compliance and risk management leaders to consider industry-specific environmental compliance data management tools to help track and manage compliance requirements. Additionally, we suggest enlisting internal or external expertise at the corporate level while simultaneously enhancing internal or external compliance support in those states or jurisdictions that pose greater environmental risks and liabilities.
对这些额外信息ics, please reach out to environmental consultantDarrell阿曼.