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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 | 12.13.24

New FTC Telemarketing Sales Rule Amendments

The Federal Trade Commission (“FTC”)  recently announced that it approved final amendments to its Telemarketing Sales Rule (“TSR”), broadening the rule’s coverage to inbound calls for technical support (“Tech Support”) services. For example, if a Tech Support company presents a pop-up alert (such as one that claims consumers’ computers or other devices are infected with malware or other problems) or uses a direct mail solicitation to induce consumers to call about Tech Support services, that conduct would violate the amended TSR. ...