Guide to JCAHO Environment of
Care Standard 3.10.3
Please note: this page is under development.
Contact
(603) 795-9966,
if you have questions or
suggestions.
Introduction
Table of
Contents Checklist
for 3.10.3
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Environment of Care Standard 3.10: The
organization manages hazardous materials and waste
risks
Element of Performance 3.
Implementation of Hazardous Material and Hazardous
Waste Program
The
organization establishes and implements processes for
selecting, handling, storing, transporting, using and
disposing of hazardous materials and wastes from receipt or
generation through use and/or final disposal, including
managing the following: chemicals, chemotherapeutic materials,
pharmaceuticals, radioactive materials and infectious and
regulated medical waste including sharps.
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This page
provides a set of criteria for evaluating how well
a facility has implemented its procedures
for managing hazardous materials and waste. The criteria have been grouped into categories
covering:
- general management topics (procuring, handling,
and disposing of various classes of waste)
- specific materials and wastes of concern
- facilities and
equipment
Categories:
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=
Compliance |
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=
Environmental Improvement
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=
Tools
and
Resources | |
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Hazardous Materials
Management
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Purchasing |
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Newly
purchased hazardous materials are added to the inventory.
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Purchasing policy promotes selection
of less hazardous, environmentally preferable
products.
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TRACER Staff can describe environmentally
preferable products that are in use, e.g. non-toxic or
less-toxic cleaners, mercury-free medical devices
(thermometers, blood pressure cuffs), or other hazardous
chemical alternatives. |
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Purchase
non-PVC equipment to eliminate patient risks associated with
DEHP and environmental risks associated with dioxin formation
from the incineration of PVC. |
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TRACER Staff
are trained to use less hazardous chemicals to reduce
exposures, and generate less waste. |
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- Having
fewer hazardous materials on-hand means having fewer to
manage. Purchase and track products that are are
non-toxic or less toxic, use less energy, have less waste
associated with them and are made with recycled content
materials.
- H2E:
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Handling,
labeling, and storage |
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Facility
maintains a hazardous materials inventory that lists all
hazardous chemicals used, and their locations.
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Facility
maintains an MSDS management program.
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Hazardous
materials are labeled (with name, hazard warnings, hazard
symbols, etc.), and are stored, handled, and used appropriately.
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Personal
protective equipment is available, appropriate to hazards and
maintained.
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TRACER
Staff can describe appropriate handling procedures and
personal protective equipment to be used with hazardous
material in question |
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Storage
cabinets and/or storage rooms are available for the storage of
flammable liquids and other
hazardous chemicals as appropriate.
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Personal
protective equipment is reused whenever possible (e.g.
gowns). |
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Spills |
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Spill
clean up procedures are in place in all areas
where hazardous materials are used and/or stored.
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Spill
clean up residues are managed as hazardous waste.
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Spills
are reported to local authorities and National Response
Center, if necessary.
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Spill
control and
decontamination equipment is readily
available in areas where hazardous materials are used.
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Spill
control equipment is maintained in usable condition.
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Eyewashes
and showers
(ANSI approved) are
available in
all areas where hazardous materials are routinely used and/or
stored,
and are checked regularly.
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All
employees who may be involved in spills are appropriately
trained. Spill response team members are HAZWOPER
trained.
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TRACER Staff respond appropriately to spills
of hazardous material used in patient care (e.g. mercury,
formalin,
glutaraldehyde, etc.).
(Staff competence: HR2.10.9,
Safety roles: HR2.20.2). |
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Hazardous
material elimination or minimization programs reduce the
potential for spills. Where the risk of spills is high,
consider an alternative less hazardous material, and ensure
proper training and education in that area to reduce the
overall risk of spills. |
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Hazardous
Material Spill Policy is established and
implemented.. |
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Training |
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Staff are
trained on hazards of materials used and appropriate handling
and use of protective equipment.
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Staff are
trained and competency tested in appropriate spill response
for hazardous materials and waste.
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Documentation for all training, including staff
trained, content covered, competency levels attained, and
dates of training, is kept for a minimum of 3
years. |
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TRACER Staff respond appropriately regarding
use of hazardous material used in patient care, e.g. solvents
for specimen analysis, cleaning agents for rooms, sterilants
for surgical procedures. |
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TRACER Staff respond appropriately regarding
clean up of a hazardous material spill used in patient care,
e.g. formalin, disinfectant, glutaraldehyde. |
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TRACER Staff respond appropriately regarding
disposal of hazardous material used in patient care, e.g.
solvents for specimen analysis, aerosols, cleaning agents for
rooms, sterilants for surgical procedures, drug
disposal. |
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TRACER Staff can describe elimination
and/or substitution of less hazardous materials as part of the
facility’s environmental improvement, e.g. use of biodiesel,
rechargeable batteries, energy-efficient equipment and
vehicles, mercury-free devices, ethylene oxide
elimination. |
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Mandatory
Hazard Communication Training during new employee orientation
sessions includes environmental improvement elements such as
waste prevention, using less materials, commitment to
environmental performance, etc. |
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Waste prevention
and proper waste handling requirements are included in all
employee job descriptions, according to a progressive
facility-wide policy. (This is important, particularly where
safety issues are concerned. It will also emphasize the
importance of participation in pollution prevention
commitments.) |
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More
resources |
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- Hazardous
materials are most often found in Dialysis,
Environmental Services/Housekeeping, Facilities Management,
Laboratories, Nursing Care, Nutrition Services, Oncology,
Pharmacy, Radiology, Surgery, Emergency Services and Vehicle
Maintenance.
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- New
York State Department of Environmental Conservation,
Pollution Prevention Unit:
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- Virginia Department of Environmental Quality, ISO
14001 Environmental Management System,
home
page
- US
Environmental Protection Agency
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Hazardous Waste
Management
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Recordkeeping and
reporting |
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The
facility has obtained an EPA Identification Number.
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Generator
status is determined and reviewed
monthly.
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Facility is working toward moving to smaller quantity
generator status by minimizing hazardous
materials present on site. |
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The basis
for hazardous waste determinations is documented.
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Facility
submits Biennial Reports on EPA Form 8700-13A
each even-numbered year.
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Manifest
copies are managed properly (e.g. appropriate copies are
received from the treatment facility and are routed to the regulatory
authority).
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Manifests, Biennial Reports, and
records of test results and analyses are kept on site
for a minimum of three years.
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Land
Disposal Restriction notices are kept for a minimum of three
years.
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Weekly
inspections of the hazardous waste storage areas are performed
and
documented according to written procedures Inspections
include checking for leaks,
corroded containers, and other potential problems.
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Hazardous waste
determination |
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A RCRA hazardous
waste determination has been made for all solid waste
that is generated. Examples of
potential sources of hazardous waste include:
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waste pharmaceuticals
HERC: Pharmaceutical Wastes
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laboratory
chemicals and reagents
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formalin
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chemicals/anesthetics used
in surgery
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waste rags with solvent
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aerosols
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disinfectants
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sterilants
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x-ray contrast media
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waste electronics
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Containers with hazardous materials, (e.g. aerosol
cans, chemotherapy agents) are completely emptied or managed
as hazardous waste.
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Containers that
held P-listed wastes are managed as hazardous waste.
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Mixed
wastes (e.g.,
radioactive and hazardous wastes, infectious and hazardous
wastes) are properly evaluated and disposed of.
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Facility
is minimizing hazardous waste generation to avoid making and
documenting determinations. |
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National Cancer Institute:
Information page on Mixed Waste. (The waste
management procedures in the table at the bottom of the page
should be considered to apply only to the facility that
produced the page.)
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Storage |
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Hazardous waste
storage areas are secure, and are operated to prevent releases
to the environment (e.g. facility has provided for secondary containment of containers).
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Hazardous waste is stored in non-leaking, sturdy, compatible
containers that are kept closed unless adding or removing waste.
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Storage
areas are clean and organized. |
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Containers
are protected from weather, fire, physical damage, and
vandals. |
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Adequate
aisle space is maintained in the hazardous waste storage area to
ensure access to containers in event of spills or leaks.
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Weekly
inspections of the hazardous waste storage areas are performed,
and are documented according to written procedures, to check for
leaks, corroded containers, or other problems.
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Containers of hazardous waste are marked with the words
“Hazardous Waste”, and a descriptive name of the waste.
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Incompatible wastes are segregated.
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Precautions are taken to prevent accidental ignition of
ignitable waste, or
reaction of reactive waste, by (among other measures) separating
the waste
from sources of ignition or reaction (e.g. open flames,
smoking, sparks, welding, hot surfaces).
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Satellite accumulation |
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Containers are located within the immediate operator
control and are inspected daily.
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Containers are labeled with a descriptive name of the
waste and the
words
“Hazardous Waste”.
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When
satellite accumulation containers are full they are moved to
the hazardous waste storage area within three days and marked
with the accumulation start date.
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Spills |
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Spill
clean up procedures are in place in all areas
where hazardous waste is handled and/or stored
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Spill
clean up residues are managed as hazardous waste.
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Spills
are reported to local authorities and National Response
Center, if necessary.
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Spill
control and
decontamination equipment is readily
available in areas where hazardous waste is handled or stored.
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Spill
control equipment is maintained in usable condition.
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Eyewashes
and showers
(ANSI approved) are
available in
all areas where hazardous waste is routinely handled and/or
stored, and are checked regularly.
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All
employees who may be involved in spills are appropriately
trained. Spill response team members are HAZWOPER
trained.
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Disposal and
Transportation |
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Hazardous
waste is shipped offsite for treatment or disposal within
appropriate timeframes based on generator status (90 days
Large Quantity Generator or 180 days Small Quantity
Generator).
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Determination of treatment requirements for land
disposal of hazardous waste have been performed.
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Hazardous
waste must be shipped to a facility permitted to handle the
waste.
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Hazardous
waste must be shipped using a hazardous waste manifest.
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Waste is
properly marked and packaged for transportation.
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Hazardous
waste transport vehicle is properly placarded if necessary.
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Contingency Planning |
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A
Contingency plan is in place if the facility is a Large
Quantity Generator.
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An
emergency coordinator is designated and has authority to
commit resources if necessary.
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The
provisions of the hazardous waste contingency plan are carried
out immediately whenever there is a fire, explosion, or
release of hazardous waste or hazardous waste constituents
which could threaten human health or the environment.
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Emergency
information is posted near the telephone in the hazardous
waste storage area.
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Arrangements are made with local authorities to respond
to a hazardous waste emergency.
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Training |
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TRACER Staff can describe appropriate
response for hazardous waste spill.
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Staff are
trained in, are thoroughly familiar with, and
competency has been tested in, proper waste
identification, handling and
emergency procedures relevant to their jobs.
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Personnel
are trained regarding satellite accumulation.
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Staff
is periodically reminded that hazardous waste should never be
improperly disposed of down the drain or as solid or
infectious waste. |
Top
Nonhazardous solid waste
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Facility promotes
recycling
all potential recyclable materials (e.g., paper, cardboard,
aluminum, steel, solvents, construction wastes, grease or food
scraps, etc.). Bins are clearly
labeled, and are conveniently located throughout the
facility. |
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Facility promotes
reduction
of solid waste by choosing products with less packaging, using
less materials (source reduction). |
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Materials
and equipment are reused and/or reprocessed to the greatest
possible extent. |
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Food
and organic waste is composted. |
Top
Regulated Medical (Infectious)
Waste
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A
comprehensive medical waste management plan, "Bloodborne
Pathogens (BBP) Exposure Control Plan", is in place that
includes identification, proper
segregation, and management of waste from generation to
disposal.
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Facility
has done a risk assessment to identify employee risks to BBP
exposures and other related BBP risks |
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Infectious waste is
properly segregated according to state-specific definitions.
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The facility's RMW
segregation
plan ensures that
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Infectious waste
containers are sturdy and labeled with the universal biohazard
symbol.
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Signs to assist with proper
segregation of infectious waste are placed above
containers.
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- Examples of suitable signage are available from
[link]
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Staff is trained and competency tested on proper
segregation and disposal of infectious waste.
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Infectious
waste containers are stored onsite in secured area away from
public areas, and are kept on site for no longer than period
of time permitted by applicable
state regulation.
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Infectious waste
containers intended for transport are properly packaged and
marked.
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Waste is placarded
for transport, if necessary.
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Facility is
registered as
generator of RMW with state and
local authorities if required.
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Regulated
medical waste is tracked and documentation kept in accordance with state
rules.
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Facility performs a waste assessment and documents
the amount of RMW generated per
month to identify opportunities for
reduction. |
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Using non-polyvinyl chloride IV bags, tubing and other
equipment to diminish dioxin emissions and reduce when waste
is incinerated |
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Facility has developed and implemented a
comprehensive RMW minimization plan that provides for:
- comprehensive staff training that
includes
- clear
definitions of RMW
- plain
language explanations of RMW disposal procedures
- guidance to identify hazardous chemicals or other
inappropriate wastes and to ensure that they not included
in the RMW waste stream
- comprehensive data collection and reporting
and
includes measures such as:
- replacing disposal equipment with reusable
equipment
- using equipment
designed to eliminate suction canisters
- using reusable
sharps containers
- using waste
reduction as a method to reduce exposure (e.g.,
formaldehyde, xylene)
- reducing blood
sample volumes to minimize quantities of infectious waste
and reduce risk of nosocomial anemia
- using automated
technology for disposal of contents of suction canisters
into sanitary sewer
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- Other
elements of a comprehensive program that may result in
performance improvement outcomes include:
- using
non-PVC equipment will minimize
DEHP exposure and dioxin formation
- ensuring
hazardous chemicals or other inappropriate wastes are not
included in this waste stream
- using
waste reduction as a method to reduce occupational
exposure
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If RMW
is incinerated or otherwise treated on site: |
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Incinerator is
operated within permit parameters and records are kept (40 CFR
70).[not specific to incinerators] |
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Design capacity of
the incinerator is not exceeded (40 CFR 70). |
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Hazardous
waste is not burned in the incinerator unless allowed by
permit (40 CFR 70). |
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Facility renders RMW non-infectious through
autoclaving or other non-incineration technologies to
reduce the dioxin,
heavy metal, and particulate emissions associated with
incineration. |
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Top
Universal Waste
Top
Materials of
Concern
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Asbestos |
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An asbestos
assessment has been done to confirm any asbestos containing
building materials (ACBM) present in the facility, including
sampling results if appropriate.
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Employees who may
potentially disturb or come into contact with asbestos been
trained at least to the "awareness level" with the required
OSHA 2hr Asbestos Awareness training.
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Areas accessible to
the public having asbestos-containing building materials with
the potential for being disturbed have been properly
labeled.
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Manifests are
complete (e.g. no information missing) and appropriately
routed.
(=EC3.10.7,
=EC3.10.8, 40 CFR 150 (d)). |
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Abated asbestos is
disposed of at an approved (either EPA or state) facility.
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Ten day prior
notification is given to local authorities prior to large
asbestos projects and records of the notice are retained.
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When conducting
asbestos abatement, proper separation from occupied areas is
maintained and appropriate clearance monitoring conducted
prior to opening the area for occupancy. |
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Air monitoring is
conducted during and post abatement, records are kept and
clearance obtained.
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- EPA:
- OSHA:
-
Asbestos - 1910.1001 -- a web page provided by OSHA that
presents 29 CFR 1910.1001 in a convenient format
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CFCs |
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Air conditioning
systems having over 50 pounds of CFC (chlorofluorocarbons)
refrigerant charge are maintained free from leaks of CFC and
records of leaks and maintenance are kept.
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All technicians
conducting repair and maintenance activities on CFC air
conditioning and refrigerant systems are EPA-certified.
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Refrigerant
recovery devices meet EPA standards.
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Efficient systems are used for air conditioning to
minimize pollution from chlorofluorocarbon use and air
emissions. |
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Ethylene Oxide |
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The facility
properly maintains ethylene oxide abaters and refreshes
scrubber catalysts on schedule. |
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Facility has a
valid air quality permit for any EtO sterilizer or aerator.
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Areas utilizing EtO
are provided with a continuous alarm monitor. |
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An up-to-date,
written EtO emergency plan is in place, with annual training
implemented and records kept. |
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Ethylene oxide is eliminated from the facility.
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Glutaraldehyde |
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Glutaraldehyde-based
high level disinfectants are properly monitored, effectively
contained, and safely handled. |
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To
reduce exposures and the amount of glutaraldehyde used,
operating procedures are reviewed and improved with use of
overhead hoods, employee training and monitoring |
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Glutaraldehyde
is replaced with less hazardous material. |
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Mercury |
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Facility has conducted a mercury inventory, and has
established a mercury elimination plan that includes a
schedule for the removal and replacement of known
mercury-containing items. |
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Pesticides |
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Pesticides
classified for restricted use are applied only by licensed
applicators.
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Restricted
pesticides are not used.
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Pesticide
containers are triple rinsed.
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The rinsate is
managed as hazardous waste if it is not used.
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A hazardous waste
determination is made and documented for pesticides that have not been used up and
are being discarded.
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Warning signs are
posted and staff notified when pesticides are
applied. |
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Facility has
instituted an Integrated Pest Management program with the
following elements:
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Pesticide
application is used only as a last resort
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Only the least
toxic pesticides are used
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The primary focus of
the program is pest identification and monitoring
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Non-chemical
methods are used for pest control (e.g. traps,
barriers)
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The program has a
staff training
component (e.g. actions that help prevent pests on the
premises)
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Pesticide
applicators are licensed and trained by appropriate
authorities
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Staff, patients, and visitors
are informed whenever pesticide is
applied |
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Top
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Petroleum Products (see also Used
Oil and Tanks
below) |
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Energy is conserved, thereby reducing the use of oil
and petroleum products. |
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Purchasing policy and other evidence indicates a
preference for energy efficient equipment, that does not burn
oil or diesel fuel. |
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Bio-diesel is used in place of diesel in generators and
other equipment. |
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Top
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Pharmaceuticals and chemotherapeutic
agents |
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Chemotherapeutic
and
pharmaceutical wastes are
evaluated for hazardous waste classification. Process for
evaluation is documented.
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Waste containers
holding U-listed chemotherapeutic and pharmaceutical
materials are completely empty
or managed as hazardous waste.
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Waste containers
holding the P-listed chemotherapeutic drug arsenic trioxide
and P-listed pharmaceuticals are managed as a hazardous waste,
and in many situations also as RMW. |
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Used syringes
containing RCRA-regulated hazardous waste are managed as
RMW. |
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TRACER
Pharmacy, oncology and nursing staff are proficient in
identifying and managing hazardous chemotherapeutic
and
pharmaceutical waste.
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TRACER
Staff can describe process used for chemotherapeutic
and
pharmaceutical waste evaluation
and basis for choice of disposal. |
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Overt amounts of
chemotherapeutic drugs are managed as hazardous
waste |
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Trace amounts of
chemotherapeutic drugs are incinerated at a permitted RMW
incinerator. |
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A waiver for
federal exclusion for nitroglycerin in finished dosage forms
has been submitted and is on file. |
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Pharmacy and
oncology staff are trained regarding waste reduction and
pollution prevention opportunities and practices. |
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Non-regulated
chemotherapeutic wastes are managed in the same way as
regulated chemotherapeutic wastes. |
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IV bags and related
equipment that are polyvinyl chloride (PVC)- and DEHP-free are
used. Reasons include:
- PVC
weighs more than polyolefin or other plastic. Using
lighter plastic reduces waste weight.
- PVC
contributes to dioxin formation when manufactured and
incinerated.
- DEHP is
a reproductive toxin and endocrine disruptor.
Minimizing its use improves patient safety.
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Top
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Polychlorinated Biphenyls (PCB) |
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PCB
equipment is properly labeled, and inspected. need citations |
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Disposal
of PCB containing items are handled as
appropriate. |
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PCB-containing equipment and oil is
eliminated. |
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Top
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Radioactive Materials and Waste |
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Inventory and
management plans for hazardous energy sources; ionizing and non-ionizing radiation, lasers,
microwaves and ultrasound devices are available.
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Staff is trained
and competency tested in appropriate spill response for
radioactive materials and waste. |
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The
facility is eliminating or reducing the use radioactive material, to the
extent that it is possible to substitute non-radioactive or
less radioactive isotopes (e.g. using isotopes with lower
level radiation or shorter half-lives for non-therapeutic
laboratory applications). |
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The
facility is eliminating the use of radioactive materials with longer
half-lives to the greatest possible extent for all
applications. |
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Top
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Used Oil |
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The
organization properly collects used oil from vehicles, and
physical plant equipment (emergency generators, compressors,
etc.)
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Used oil
is stored in sturdy compatible containers labeled “used oil”
that are kept closed.
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Oil-containing equipment is not leaking.
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Spill
control equipment is available and used when necessary.
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Spills are reported to local and federal authorities.
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Used oil
is recycled and receipts are kept indicating such.
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Staff is
trained and competency tested in appropriate spill response
for used oil.
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A
hazardous waste determination is made and documentation is
kept for used oil that is destined for disposal. |
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Used oil filters
are drained for a minimum of twelve hours to ensure all
residual oil is collected before disposing of the filters as
scrap metal.
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Facilities and
equipment
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Recordkeeping and reporting |
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Air permits are
modified when fuel usage changes.
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Certificates to
Operate and Permits are not permitted to expire.
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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).
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Top
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Boilers,
generators |
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Bio diesel is considered and possibly used with
emergency generators. |
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Oil burning
equipment is well maintained. Logs and documentation
evident. |
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Energy efficient boilers and generators are used to
minimize air pollution (Documentation:
EC3.10.7). |
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Policies indicate preference for energy efficient
equipment and practices throughout the facility to minimize
fuel use. |
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Incinerator |
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Incinerator is
operated within permit parameters and records are kept (40 CFR
70) [not specific to incinerators]. |
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Design capacity of
the incinerator is not exceeded (40 CFR 70). |
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Hazardous waste is
not burned in the incinerator unless allowed by permit (40 CFR
70). |
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Incineration is eliminated or reduced as a waste
treatment or disposal method. (Incineration creates air
pollution such as dioxins, acid gases (such as hydrogen
chloride), carbon monoxide, and heavy metals. Air
pollution from incinerators is deleterious to community
health.) |
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All waste is minimized to eliminate emissions to air.
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Tanks |
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Spill Containment
and Countermeasures plan is in place for aggregate aboveground
storage greater than 1320 gallons.
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Tanks are permitted
or registered with either EPA or local authorities.
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Underground storage
tanks must have been upgraded or replaced by 12/22/98 to meet
integrity, cathodic protection, leak and overfill protection
requirements.
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Maintenance and
calibrating procedures are enacted to ensure tank monitors are
working appropriately. |
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Tanks are inspected
on weekly/monthly basis as per EPA or local regulations.
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Tank alarm system
can be heard or otherwise adequately communicated to
operators. |
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Procedures
are written and available for steps to be taken when tank
alarm sounds. |
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Tank overfill
protection equipment is monitored.
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Corrosion
protection for tanks is adequate. If cathodic protection
is used it is inspected and replaced as required.
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Release detection
equipment for tanks and piping is adequate and up to
date. Monitor and record condition.
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Suspect releases
or spills are reported to EPA or appropriate local authority.
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TRACER
Staff respond appropriately regarding steps to be taken
in the event of tank alarm, spill, or leak. |
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Tank parts are
appropriately labeled with appropriate American Petroleum
Institute (API) code. E.g. Hexagon for #2 Fuel Oil (40 CFR 280) |
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Equipment on tank
to shut down when tank reaches 95% of capacity during fueling.
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Tanks are located a
safe distance from other areas of the facility.
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Use of underground
storage tanks is eliminated, minimizing risk of leaks and
spills. |
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- US
Environmental Protection Agency:
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Wastewater |
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Review of local
rules and codes to ensure all discharges to sewer
(laboratories, pharmacy, surgery, dialysis, central
processing, nutrition services, etc.) are permitted and/or if
pretreatment is required (40 CFR 403).
[can't find 403] |
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All discharges to
sewer are reported to local wastewater authority (local
permits, 40 CFR 403). |
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Spill
Prevention Control and Countermeasure Plans are in place,
including adequate secondary containment of storage
tanks.
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All discharges to
the sewer are evaluated assure conformance with local, state
and federal restrictions, e.g. formalin, glutaraldehyde,
pharmaceuticals, alcohols, laboratory discharges, x-ray
chemicals (40 CFR 403). |
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All discharges to
the sewer are evaluated for hazardous waste and reported to
local sewer are evaluated for hazardous waste and reported to
local sewer and hazardous waste authorities. (40 CFR 403)
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Direct, point
source discharges are required to obtain National Pollution
Discharge Elimination System (NPDES) permits under 402 of the
Clean Water Act (CWA) |
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If the facility has
any septic tanks, drain fields, lagoons, or other on-site
wastewater disposal areas, they are properly
permitted |
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Hazardous materials
or waste storage or process areas DO NOT have floor drains
that might allow a release of a hazardous chemical to the
environment |
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Wastewater is
monitored, tested and reported as per local, state and/or
federal permit requirements,
and exceedances are managed appropriately. |
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Wash water from
kitchen cleaning or other cleaning operations is not
discharged to the storm sewer without a National Pollutant
Discharge Elimination Permit.
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Discharges
to sewer are reduced or eliminated.
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Click the
icon to see the overall Tools & Resources
for 3.10.3
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