If you are responsible for safety and/or environmental
programs at your facility, you may have been contacted in the last few months
by your Hospital Administrator regarding a recent announcement by the Colorado
Department of Public Health and Environment (CDPHE). In a March 17, 2009
letter to Hospital Administrators, CDPHE announced that it will begin
conducting hazardous waste compliance inspections at Colorado Hospitals.
What Does that Mean to You?
- Well
it means that CDPHE likely will be coming your way in the next 12 to 24
months to audit your hospital’s hazardous waste program.
Are you Ready?
- Do you
have all your hazardous wastes identified throughout the hospital
(laboratories, pharmacy, facilities/maintenance, and nursing
floors)?
- Have
you established procedures to ensure all hazardous wastes are
appropriately managed, stored and disposed of, including pharmaceutical
wastes?
- Does
your pharmaceutical waste distributor have an EPA Identification Number
and are they managing your unused drugs in accordance with regulations?
- Have
you trained all your personnel that handle hazardous wastes (this not only
includes your facilities and maintenance personnel, but also your
laboratory personnel, pharmacy personnel and your nursing staff.)
Yes your nursing staff must be included in this training as they handle
pharmaceuticals such as Coumadin, or Warfarin, that is a P-Listed
hazardous waste upon disposal. As a P-listed waste, anything that
touches the Coumadin is also a hazardous waste such as gloves, packaging
and pill cups. Are you handling these items appropriately?
With the new focus that CDPHE now places upon hospital
hazardous waste compliance, you must have a well designed plan and positive
steps in place to evaluate, work toward, and ensure compliance. CDPHE has
been hosting periodic round-table meetings on the subject for the past year
plus and was offering free on-site technical assistance through its Generator
Assistance Program (GAP). However, CDPHE has now taken very real steps
towards pushing compliance the “old fashioned way” - through site visits and
inspection. Currently, CDPHE is inspecting about two hospitals per month,
and compliance advisories have been issued for at least one hospital to
date. CDPHE has stated that they are giving hospitals a one-week notice
prior to inspection.
References that CDPHE has shared on this topic include the
following from their website:
If you would like help in evaluating your existing hazardous
waste program, identifying potential gaps, and/or assistance with procedure or
training implementation, Hellman & Associates is available to support
you. We have several consultants who work actively in the hospital
environment and who have experience assisting clients with preparation for
CDPHE hazardous waste compliance inspections. Contact Hellman &
Associates and you will have a partner in this new compliance environment.
303.384.9828 or gborchert@ehscompliance.com
