1. Home
  2. |Insights
  3. |EPA Signs "Self-audit" Agreements With Three Hospitals

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").

Insights

Client Alert | 5 min read | 04.13.26

EU Pharma Package: Global (Orphan) Marketing Authorization Compromise Proposal

In our fifth alert in this EU Pharma Package Series, we provided an analysis of the background and ongoing legal debates regarding the concept of the global marketing authorization (GMA). We discussed in particular the missed opportunities in the Pharma Package to further codify and clarify the GMA, in view of its central role in determining the regulatory data protection (RDP) rights of a medicinal product....