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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 | 4 min read | 09.15.26

GAO Indicates Reasonable Conflict of Interest Investigation Must Include Inquiry of Involved Firm

The U.S. Government Accountability Office’s (GAO) recent decision in Viderity Inc.—Costs, B-424422.5, Sept. 1, 2026, offers useful insight into what constitutes a legally sufficient conflict of interest investigation. The decision arose in an unusual procedural posture: Viderity initially protested, alleging that an agency evaluator had a personal conflict of interest. After the agency took corrective action, Viderity filed a cost entitlement claim requesting that GAO direct the agency to reimburse Viderity’s protest costs. In evaluating that claim, GAO assessed whether Viderity’s underlying protest ground was “clearly meritorious.”...