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EPA Signs "Self-audit" Agreements With Three Hospitals

Client Alert | 1 min read | 03.26.04

The New England Region of the Environmental Protection Agency has signed "self-audit" agreements with three hospitals requiring them to conduct comprehensive environmental audits of their facilities. These agreements were reached using EPA's Healthcare Compliance Initiative, under which health facilities can assess their facilities for compliance under all major environmental programs, report and correct violations, and receive relief from penalties.

The agreements are with Columbia University Medical Center, Riverside Health Care System in Westchester, New York, and Alice Hyde Medical Center, in upstate New York. If the institutions correct all violations and abide by the other terms of their individual agreements, EPA will waive "gravity-based penalties," which are normally based on the seriousness of violations.

Environmental compliance by health care institutions is an increasingly important focus of EPA enforcement. Hospitals generate a wide variety of hazardous waste, such as chemotherapy and antineoplastic chemicals, solvents, formaldehyde, photographic chemicals, radionuclides, and waste anesthetic gases, as well as solid waste. Many hospitals have been penalized for air, toxic substances and water violations. The EPA is especially interested in hospital compliance actions regarding persistent bioaccumulative toxins ("PBTs").

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Client Alert | 3 min read | 04.25.24

JUST RELEASED: EPA’s Bold New Strategic Civil-Criminal Enforcement Collaboration Policy

The Environmental Protection Agency’s (EPA’s) Office of Enforcement and Compliance Assurance (OECA) just issued its new Strategic Civil-Criminal Enforcement Policy, setting the stage for the new manner in which the agency manages its pollution investigations. David M. Uhlmann, the head of OECA, signed the Policy memorandum on April 17, 2024, in order to ensure that EPA’s civil and criminal enforcement offices collaborate efficiently and consistently in cases across the nation. The Policy states, “EPA must exercise enforcement discretion reasonably when deciding whether a particular matter warrants criminal, civil, or administrative enforcement. Criminal enforcement should be reserved for the most egregious violations.” ...