The Bullet:
The Palmetto Health Richland has been fined $28,000 by the South Carolina Department of Health and Environmental Control (DHEC) for mismanagement of hazardous waste. Read the full article in The State.
Who:
- Palmetto Health Richland located in Columbia, SC
- Reference is also made to Palmetto Health Baptist – also located in Columbia, SC – though no mention is made of violations at that location.
- South Carolina Department of Health and Environmental Control (DHEC)
What:
DHEC ordered the hospital to complete the following:
- Correct the conditions subject to the violations.
- Keep proper records.
- Institute a training program. Learn more about Hazardous Waste Personnel Training (aka RCRA Training)
- Pay the fine of $28,000.
Palmetto Health Richland’s response:
A spokeswoman for the hospital said that the violation arose when the waste disposal company that handled the medical waste at Palmetto Health Baptist and Palmetto Health Richland went out of business and was purchased by a competitor.
The new company mislabeled and handled nonhazardous medical waste as though it were hazardous, spokeswoman Tammie Epps said, resulting in a fine because of the greater amount of waste that was erroneously processed as hazardous.
Palmetto Health has since hired a new company to handle its waste.
Where:
Palmetto Health Richland is one of several locations of Palmetto Health. It is located in Columbia, SC.
When:
The article was published 08.15.17. No reference is made to the date of the violations or the DHEC action.
Why:
Violations of the hazardous waste regulations documented by DHEC include:
- Hazardous waste containers not kept closed except when actively adding or removing waste. Read: USEPA Regulations for Closed Container
- Hazardous waste containers not marked or labeled to identify it as hazardous waste and to indicate date of initial accumulation.
- Failure to maintain adequate aisle space to all areas of the facility to allow for unobstructed movement of personnel and equipment in an emergency. Read: Required Aisle Space for Emergency Preparedness
- Failure to maintain copies of Uniform Hazardous Waste Manifest for off-site shipments of hazardous waste. Read: Maintenance of Manifest Records by Hazardous Waste Generator
How:
DHEC is the authorized regulatory and enforcement agency for the Federal regulations of the Resource Conservation and Recovery Act (RCRA) within the state of South Carolina. It has the authority to enforce its state-specific regulations and those of the USEPA it has adopted within the state of South Carolina. There is no mention of the involvement of the US Environmental Protection Agency in this enforcement action. Read: State Authorization Under RCRA
Conclusion:
“No hazardous medical waste was placed in the environment as a result of this processing error.”
-Tammie Epps
I see two fundamental errors made by Palmetto Health that led to these violations.
The first is the over-reliance of a hazardous waste generator on a contractor for their regulatory compliance. All hazardous waste generators should note that the company Palmetto Health Richland held responsible for the errors paid no fine. It was not even mentioned in the publication! They are likely working for some other hazardous waste generator right now and possibly making the same – or worse – mistakes. Remember: as the generator of a waste – any waste – you have a “cradle-to-grave” responsibility for its management that continues through off-site transportation and beyond its final treatment, storage, or disposal. Read: Hazardous Waste Generator Cradle-to-Grave Responsibility
The second error is a failure to provide hazardous waste personnel training for employees responsible for the management of waste. A large quantity generator of hazardous waste must provide initial training to its personnel followed by an annual review. A small quantity generator need only ensure its personnel are “thoroughly familiar” with how to manage hazardous waste and how to respond to a hazardous waste emergency (more…). A very small quantity generator has no training requirement at all. However, no matter a company’s hazardous waste generator status, high-quality training like mine (either Onsite or Web-Based) provides the knowledge to ensure that violations such as this don’t occur.
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