Monday, July 18, 2011

Hazardous Materials and Waste

Health care organizations are responsible for adhering to local, state, and federal regulations for proper handling and disposal of hazardous materials and wastes. How is it possible for Joint Commission surveyors to determine whether an organization is complying with all these codes, standards, and regulations when they often differ from one location or state to another?

The process of conducting surveys at a wide range of geographic locations presents unique challenges to each surveyor. The federal Environmental Protection Agency regulations apply to most organizations, and it is with these regulations that surveyors are most familiar. State and local regulations are generally even more restrictive. Thus, a surveyor must usually determine what additional requirements state or local regulations have imposed.

An organization’s hazardous materials and waste management program is required to be designed and operated in accordance with all applicable laws and regulations. This written program contains the policies and procedures that are necessary for the organization to be in compliance with all applicable laws. Through a thorough review of the hazardous materials and waste program, surveyors are able to determine the extent to which the state and local regulations have been addressed by the program. Each organization is encouraged to maintain a reference library of all applicable federal, state, and local laws and regulations. Maintenance of this library helps demonstrate that all of the various regulatory requirements have been taken into consideration during program design. If an organization is unable to refer to the actual regulations, it is difficult to see what requirements the program is based on and how the organization keeps abreast of change to these regulations.

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