BOSTON – VHS Acquisition Subsidiary Number 7, Inc., the parent corporation that operates St. Vincent Hospital in Worcester has been assessed a $2,860 penalty by the Massachusetts Department of Environmental Protection (MassDEP) for violating Hazardous Waste Management and Air Pollution Control requirements. (Link to the news release on the MADEP website).
During a routine inspection of the hospital conducted by MassDEP personnel in December 2012, it was determined that the facility generated hazardous waste in excess of its registered status, failed to ensure all required information on hazardous waste manifests was correct and failed to submit an annual Source Registration form. In a negotiated consent order, the parent company, VHS Acquisition Subsidiary Number 7, Inc. of Tennessee, agreed to maintain facility compliance with applicable regulations and pay the $2,860 penalty.
“During the inspection when the violations were identified, the facility immediately took steps to ensure compliance with applicable regulations, including its handling of hazardous wastes,” said Lee Dillard Adams, director of MassDEP’s Central Regional Office in Worcester. “MassDEP appreciates these measures and anticipates this level of attention will lead to on-going compliance.”
An assessed penalty of this amount is not a significant burden to a company of this size. However, I am certain the that the hospital managers, not to mention the officers of the parent corporation, were not happy with the black eye it gives their facility. And yet, it all could have been avoided by some relatively simple actions. For example, a point I emphasize in my Training Seminars is to keep a close eye on your hazardous waste generation, I even provide a sample form to use when tracking your hazardous waste from cradle to grave.
Ensuring all the information is correct on the RCRA Manifest is important since a mistake here could lead to violations of USEPA regulations – in this case the regulations of the Massachusetts Department of Environment since MA has an authorized hazardous waste program – and those of the US Department of Transportation.
Both the USEPA – or an authorized state – and the USDOT require training of applicable personnel. It is your responsibility to identify those employees and ensure they are trained properly. Please contact me for a free consultation of your RCRA/Hazardous Waste and HazMat Employee training requirements.