Guide to JCAHO Environment
of Care Standard 3.10.3
Please
note: this page is under development. Contact
(734) 995-7989,
if you have questions or suggestions.
Introduction Table of Contents Checklist
for 3.10.3
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Environment of Care Standard 3.10: The
organization manages hazardous materials and waste risks
Element of Performance 3. Implementation
of Hazardous Material and Hazardous Waste Program
The
organization establishes and implements processes for selecting,
handling, storing, transporting, using and disposing of hazardous
materials and wastes from receipt or generation through use and/or
final disposal, including managing the following: chemicals, chemotherapeutic
materials, pharmaceuticals, radioactive materials and infectious
and regulated medical waste including sharps.
© 2005
Joint Commission on Accreditation of Healthcare Organizations. Any
use of any or all of the Joint Commission standards and elements of
performance beyond this particular tool is strictly forbidden without
the written permission of the Joint Commission. Citations from JCAHO standards are ©2005 Joint Commission on Accreditation of Healthcare Organizations. Any use of any or all of the Joint Commission standards and elements of performance beyond this particular tool is strictly forbidden without the written permission of the Joint Commission. These pages do not reflect any changes in the standards made after 2005.
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This page provides a set
of criteria for evaluating how well a facility has
implemented its procedures for managing hazardous materials and waste. The criteria have been grouped into categories covering:
- general management topics (procuring, handling,
and disposing of various classes of waste)
- specific materials and wastes of concern
- facilities and
equipment
Categories:
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= Compliance |
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= Environmental
Improvement |
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= Tools
and Resources |
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Hazardous Materials Management
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Purchasing |
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Newly purchased hazardous
materials are added to the inventory.
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Purchasing policy promotes selection
of less hazardous, environmentally preferable products.
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TRACER Staff can describe environmentally
preferable products that are in use, e.g. non-toxic or less-toxic cleaners,
mercury-free medical devices (thermometers, blood pressure cuffs),
or other hazardous chemical alternatives. |
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Purchase non-PVC equipment
to eliminate patient risks associated with DEHP and environmental risks
associated with dioxin formation from the incineration of PVC. |
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TRACER Staff
are trained to use less hazardous chemicals to reduce exposures, and
generate less waste. |
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- Having fewer hazardous
materials on-hand means having fewer to manage. Purchase
and track products that are are non-toxic or less toxic, use less
energy, have less waste associated with them and are made with
recycled content materials.
- Practice Greenhealth:
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Handling, labeling,
and storage |
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Facility
maintains a hazardous materials inventory that lists all hazardous
chemicals used, and their locations.
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Facility
maintains an MSDS management program.
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Hazardous materials
are labeled (with name, hazard warnings, hazard symbols, etc.), and
are stored, handled, and used appropriately.
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Personal protective
equipment is available, appropriate to hazards and maintained.
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TRACER Staff
can describe appropriate handling procedures and personal protective
equipment to be used with hazardous material in question |
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Storage cabinets and/or
storage rooms are available for the storage of flammable liquids and other
hazardous chemicals as appropriate.
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Personal protective
equipment is reused whenever possible (e.g. gowns). |
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Spills |
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Spill
clean up procedures are in place in all areas where
hazardous materials are used and/or stored.
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Spill
clean up residues are managed as hazardous waste.
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Spills
are reported to local authorities and National Response Center, if
necessary.
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Spill control and decontamination
equipment is readily available
in areas where hazardous materials are used.
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Spill control equipment
is maintained in usable condition.
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Eyewashes
and showers (ANSI
approved) are available in
all areas where hazardous materials are routinely used and/or stored, and
are checked regularly.
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All
employees who may be involved in spills are appropriately trained. Spill
response team members are HAZWOPER trained.
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TRACER Staff respond appropriately to spills
of hazardous material used in patient care (e.g. mercury, formalin,
glutaraldehyde, etc.).
(Staff
competence: HR2.10.9,
Safety roles: HR2.20.2). |
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Hazardous material
elimination or minimization programs reduce the potential for
spills. Where the risk of spills is high, consider an alternative
less hazardous material, and ensure proper training and education
in that area to reduce the overall risk of spills.
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Hazardous
Material Spill Policy is established and implemented.. |
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Training |
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Staff are trained
on hazards of materials used and appropriate handling and use of protective
equipment.
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Staff are trained
and competency tested in appropriate spill response for hazardous materials
and waste.
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Documentation for all training, including staff trained,
content covered, competency levels attained, and dates of training,
is kept for a minimum of 3 years. |
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TRACER Staff respond appropriately regarding
use of hazardous material used in patient care, e.g. solvents for specimen
analysis, cleaning agents for rooms, sterilants for surgical procedures. |
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TRACER Staff respond appropriately regarding
clean up of a hazardous material spill used in patient care, e.g. formalin,
disinfectant, glutaraldehyde. |
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TRACER Staff respond appropriately regarding
disposal of hazardous material used in patient care, e.g. solvents
for specimen analysis, aerosols, cleaning agents for rooms, sterilants
for surgical procedures, drug disposal. |
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TRACER Staff can describe elimination and/or
substitution of less hazardous materials as part of the facility’s
environmental improvement, e.g. use of biodiesel, rechargeable batteries,
energy-efficient equipment and vehicles, mercury-free devices, ethylene
oxide elimination.
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Mandatory Hazard Communication
Training during new employee orientation sessions includes environmental
improvement elements such as waste prevention, using less materials,
commitment to environmental performance, etc. |
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Waste prevention
and proper waste handling requirements are included in all employee
job descriptions, according to a progressive facility-wide policy.
(This is important, particularly where safety issues are concerned. It
will also emphasize the importance of participation in pollution prevention
commitments.) |
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More resources |
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- Hazardous
materials are most often found in Dialysis, Environmental
Services/Housekeeping, Facilities Management, Laboratories, Nursing
Care, Nutrition Services, Oncology, Pharmacy, Radiology, Surgery,
Emergency Services and Vehicle Maintenance.
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- New York State
Department of Environmental Conservation, Pollution Prevention
Unit:
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- Virginia Department of Environmental Quality, ISO
14001 Environmental Management System, home
page
- US Environmental
Protection Agency
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Hazardous Waste Management
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Recordkeeping and reporting |
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The facility has obtained
an EPA Identification Number.
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Generator status is
determined and reviewed monthly.
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Facility is working toward moving to smaller quantity
generator status by minimizing hazardous materials
present on site.
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The basis for hazardous
waste determinations is documented.
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Facility submits
Biennial Reports on EPA Form 8700-13A each even-numbered year.
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Manifest copies are
managed properly (e.g. appropriate copies are received from the treatment
facility and are routed to the regulatory authority).
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Manifests, Biennial Reports, and records
of test results and analyses are kept on site for a minimum
of three years.
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Land Disposal Restriction
notices are kept for a minimum of three years.
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Weekly inspections
of the hazardous waste storage areas are performed and documented according
to written procedures Inspections include checking for leaks,
corroded containers, and other potential problems.
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Hazardous waste determination |
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A RCRA hazardous
waste determination has been made for all solid waste that is
generated. Examples of potential sources of
hazardous waste include:
- waste pharmaceuticals HERC: Pharmaceutical
Wastes
- laboratory chemicals
and reagents
- formalin
- chemicals/anesthetics
used in surgery
- waste rags with
solvent
- aerosols
- disinfectants
- sterilants
- x-ray contrast media
- waste electronics
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Containers with hazardous materials, (e.g. aerosol cans,
chemotherapy agents) are completely emptied or managed as hazardous
waste.
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Containers that
held P-listed wastes are managed as hazardous waste.
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Mixed wastes (e.g.,
radioactive and hazardous wastes, infectious and hazardous wastes)
are properly evaluated and disposed of.
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Facility is minimizing
hazardous waste generation to avoid making and documenting determinations. |
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- National Cancer
Institute: Information
page on Mixed Waste. (The waste management procedures
in the table at the bottom of the page should be considered to
apply only to the facility that produced the page.)
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Storage |
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Hazardous waste
storage areas are secure, and are operated to prevent releases to the
environment (e.g. facility has provided for secondary containment of
containers).
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Hazardous
waste is stored in non-leaking, sturdy, compatible containers that
are kept closed unless adding or removing waste.
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Storage
areas are clean and organized. |
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Containers
are protected from weather, fire, physical damage, and vandals. |
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Adequate aisle space
is maintained in the hazardous waste storage area to ensure access
to containers in event of spills or leaks.
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Weekly inspections
of the hazardous waste storage areas are performed, and are documented
according to written procedures, to check for leaks, corroded containers,
or other problems.
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Containers of hazardous waste are marked with the words �Hazardous
Waste�, and a descriptive name of the waste.
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Incompatible wastes are segregated.
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Precautions are taken to prevent accidental ignition
of ignitable waste, or reaction of reactive waste, by (among other
measures) separating the waste from sources of ignition or reaction
(e.g. open flames, smoking, sparks, welding, hot surfaces).
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Satellite accumulation |
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Containers are located within the immediate operator
control and are inspected daily.
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Containers are labeled with a descriptive name of the
waste and the
words “Hazardous
Waste”.
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When satellite accumulation
containers are full they are moved to the hazardous waste storage area
within three days and marked with the accumulation start date.
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Spills |
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Spill
clean up procedures are in place in all areas where
hazardous waste is handled and/or stored
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Spill
clean up residues are managed as hazardous waste.
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Spills
are reported to local authorities and National Response Center, if
necessary.
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Spill control and decontamination
equipment is readily available
in areas where hazardous waste is handled or stored.
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Spill control equipment
is maintained in usable condition.
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Eyewashes and showers (ANSI
approved) are available in
all areas where hazardous waste is routinely handled and/or stored,
and are checked regularly.
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All
employees who may be involved in spills are appropriately trained. Spill
response team members are HAZWOPER trained.
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Disposal and Transportation |
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Hazardous waste is
shipped offsite for treatment or disposal within appropriate timeframes
based on generator status (90 days Large Quantity Generator or 180
days Small Quantity Generator).
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Determination of treatment requirements for land disposal
of hazardous waste have been performed.
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Hazardous waste must
be shipped to a facility permitted to handle the waste.
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Hazardous waste must
be shipped using a hazardous waste manifest.
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Waste is properly
marked and packaged for transportation.
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Hazardous waste transport
vehicle is properly placarded if necessary.
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Contingency Planning |
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A Contingency plan
is in place if the facility is a Large Quantity Generator.
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An emergency coordinator
is designated and has authority to commit resources if necessary.
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The provisions of
the hazardous waste contingency plan are carried out immediately whenever
there is a fire, explosion, or release of hazardous waste or hazardous
waste constituents which could threaten human health or the environment.
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Emergency information
is posted near the telephone in the hazardous waste storage area.
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Arrangements are made with local authorities to respond
to a hazardous waste emergency.
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Training |
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TRACER Staff can describe appropriate response
for hazardous waste spill.
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Staff are trained
in, are thoroughly familiar with, and competency
has been tested in, proper waste identification, handling and emergency
procedures relevant to their jobs.
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Personnel are trained
regarding satellite accumulation.
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Staff
is periodically reminded that hazardous waste should never be improperly
disposed of down the drain or as solid or infectious waste. |
Nonhazardous solid waste
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Facility promotes recycling
all potential recyclable materials (e.g., paper, cardboard, aluminum,
steel, solvents, construction wastes, grease or food scraps, etc.). Bins are clearly
labeled, and are conveniently located throughout the facility.
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Facility promotes reduction
of solid waste by choosing products with less packaging, using less
materials (source reduction). |
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Materials
and equipment are reused and/or reprocessed to the greatest possible
extent. |
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Food
and organic waste is composted. |
Regulated Medical (Infectious) Waste
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A
comprehensive medical waste management plan, "Bloodborne Pathogens
(BBP) Exposure Control Plan", is in place that includes identification, proper
segregation, and management of waste from generation to disposal.
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Facility
has done a risk assessment to identify employee risks to BBP exposures
and other related BBP risks |
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Infectious waste
is properly segregated according to state-specific definitions.
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The facility's RMW segregation
plan ensures that
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Infectious waste
containers are sturdy and labeled with the universal biohazard symbol.
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Signs to assist with proper
segregation of infectious waste are placed above containers.
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- Examples of suitable signage are available from [link]
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Staff is trained and competency tested on proper
segregation and disposal of infectious waste.
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Infectious
waste containers are stored onsite in secured area away from public
areas, and are kept on site for no longer than period of time permitted
by applicable state regulation.
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Infectious waste
containers intended for transport are properly packaged and marked.
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Waste is placarded
for transport, if necessary.
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Facility is registered as
generator of RMW with state and
local authorities if required.
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Regulated medical
waste is tracked and documentation kept in accordance with state rules.
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Facility performs a waste assessment and documents the amount of RMW generated per month to identify opportunities for
reduction. |
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Using non-polyvinyl chloride IV bags, tubing and other
equipment to diminish dioxin emissions and reduce when waste is incinerated
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Facility has developed and implemented a comprehensive
RMW minimization plan that provides for:
- comprehensive staff training that
includes
- clear
definitions of RMW
- plain
language explanations of RMW disposal procedures
- guidance to identify hazardous chemicals or other
inappropriate wastes and to ensure that they not included
in the RMW waste stream
- comprehensive data collection and reporting
and includes
measures such as:
- replacing disposal equipment with reusable equipment
- using equipment designed
to eliminate suction canisters
- using reusable
sharps containers
- using waste reduction
as a method to reduce exposure (e.g., formaldehyde, xylene)
- reducing blood
sample volumes to minimize quantities of infectious waste and
reduce risk of nosocomial anemia
- using automated
technology for disposal of contents of suction canisters into
sanitary sewer
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- Other
elements of a comprehensive program that may result in performance
improvement outcomes include:
- using
non-PVC equipment will minimize
DEHP exposure and dioxin formation
- ensuring
hazardous chemicals or other inappropriate wastes are not
included in this waste stream
- using
waste reduction as a method to reduce occupational exposure
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If RMW is incinerated
or otherwise treated on site: |
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Incinerator is operated
within permit parameters and records are kept (40 CFR 70).[not
specific to incinerators] |
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Design capacity
of the incinerator is not exceeded (40 CFR 70). |
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Hazardous waste is
not burned in the incinerator unless allowed by permit (40 CFR 70). |
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Facility renders RMW non-infectious through autoclaving
or other non-incineration technologies to reduce the dioxin,
heavy metal, and particulate emissions associated with incineration.
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Universal Waste
Materials of Concern
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Asbestos |
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An asbestos assessment
has been done to confirm any asbestos containing building materials
(ACBM) present in the facility, including sampling results if appropriate.
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Employees who may
potentially disturb or come into contact with asbestos been trained
at least to the "awareness level" with the required OSHA 2hr Asbestos
Awareness training.
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Areas accessible
to the public having asbestos-containing building materials with the
potential for being disturbed have been properly labeled.
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Manifests are complete
(e.g. no information missing) and appropriately routed.
(=EC3.10.7,
=EC3.10.8, 40 CFR
150 (d)). |
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Abated asbestos
is disposed of at an approved (either EPA or state) facility.
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Ten day prior notification
is given to local authorities prior to large asbestos projects and
records of the notice are retained.
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When conducting
asbestos abatement, proper separation from occupied areas is maintained
and appropriate clearance monitoring conducted prior to opening the
area for occupancy. |
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Air monitoring is
conducted during and post abatement, records are kept and clearance
obtained.
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- EPA:
- OSHA:
- Asbestos
- 1910.1001 -- a web page provided by OSHA that presents
29 CFR 1910.1001 in a convenient format
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CFCs |
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Air conditioning
systems having over 50 pounds of CFC (chlorofluorocarbons) refrigerant
charge are maintained free from leaks of CFC and records of leaks and
maintenance are kept.
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All technicians
conducting repair and maintenance activities on CFC air conditioning
and refrigerant systems are EPA-certified.
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Refrigerant recovery
devices meet EPA standards.
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Efficient systems are used for air conditioning to minimize
pollution from chlorofluorocarbon use and air emissions.
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Ethylene Oxide |
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The facility properly
maintains ethylene oxide abaters and refreshes scrubber catalysts on
schedule. |
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Facility has a valid
air quality permit for any EtO sterilizer or aerator.
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Areas utilizing
EtO are provided with a continuous alarm monitor. |
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An up-to-date, written
EtO emergency plan is in place, with annual training implemented and
records kept. |
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Ethylene oxide is eliminated from the facility.
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Glutaraldehyde |
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Glutaraldehyde-based
high level disinfectants are properly monitored, effectively contained,
and safely handled. |
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To
reduce exposures and the amount of glutaraldehyde used, operating procedures
are reviewed and improved with use of overhead hoods, employee training
and monitoring |
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Glutaraldehyde
is replaced with less hazardous material. |
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Mercury |
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Facility has conducted a mercury inventory, and has
established a mercury elimination plan that includes a schedule for
the removal and replacement of known mercury-containing items.
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Pesticides |
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Pesticides classified
for restricted use are applied only by licensed applicators.
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Restricted pesticides
are not used.
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Pesticide containers
are triple rinsed.
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The rinsate is managed
as hazardous waste if it is not used.
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A hazardous waste
determination is made and documented for pesticides that have not been used up
and are being discarded.
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Warning signs are
posted and staff notified when pesticides are applied. |
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Facility has instituted
an Integrated Pest Management program with the following elements:
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Pesticide application
is used only as a last resort
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Only the least
toxic pesticides are used
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The primary focus
of the program is pest identification and monitoring
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Non-chemical methods
are used for pest control (e.g. traps, barriers)
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The program has
a staff training component (e.g. actions that help prevent
pests on the premises)
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Pesticide applicators
are licensed and trained by appropriate authorities
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Staff,
patients, and visitors are informed whenever pesticide is applied
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Petroleum Products (see also Used Oil and Tanks below) |
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Energy is conserved, thereby reducing the use of oil
and petroleum products.
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Purchasing policy and other evidence indicates a preference
for energy efficient equipment, that does not burn oil or diesel
fuel.
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Bio-diesel is used in place of diesel in generators
and other equipment.
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Pharmaceuticals and chemotherapeutic agents |
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Chemotherapeutic and
pharmaceutical wastes are evaluated
for hazardous waste classification. Process for evaluation is documented.
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Waste containers
holding U-listed chemotherapeutic and pharmaceutical materials are completely empty
or managed as hazardous waste.
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Waste containers
holding the P-listed chemotherapeutic drug arsenic trioxide and P-listed
pharmaceuticals are managed as a hazardous waste, and in many situations
also as RMW. |
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Used syringes containing
RCRA-regulated hazardous waste are managed as RMW. |
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TRACER Pharmacy,
oncology and nursing staff are proficient in identifying and managing
hazardous chemotherapeutic and
pharmaceutical waste.
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TRACER Staff
can describe process used for chemotherapeutic and
pharmaceutical waste evaluation
and basis for choice of disposal. |
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Overt amounts of
chemotherapeutic drugs are managed as hazardous waste |
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Trace amounts of
chemotherapeutic drugs are incinerated at a permitted RMW incinerator. |
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A waiver for federal
exclusion for nitroglycerin in finished dosage forms has been submitted
and is on file. |
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Pharmacy and oncology
staff are trained regarding waste reduction and pollution prevention
opportunities and practices. |
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Non-regulated chemotherapeutic
wastes are managed in the same way as regulated chemotherapeutic wastes. |
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IV bags and related
equipment that are polyvinyl chloride (PVC)- and DEHP-free are used. Reasons
include:
- PVC weighs more
than polyolefin or other plastic. Using lighter plastic
reduces waste weight.
- PVC contributes
to dioxin formation when manufactured and incinerated.
- DEHP is a reproductive
toxin and endocrine disruptor. Minimizing its use improves
patient safety.
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Polychlorinated Biphenyls (PCB) |
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PCB equipment is properly
labeled, and inspected. need citations |
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Disposal of PCB containing
items are handled as appropriate. |
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PCB-containing equipment and oil is eliminated.
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Radioactive Materials and Waste |
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Inventory and management
plans for hazardous energy sources; ionizing and non-ionizing radiation,
lasers, microwaves and ultrasound devices are available.
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Staff is trained
and competency tested in appropriate spill response for radioactive
materials and waste. |
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The
facility is eliminating or reducing the use radioactive material,
to the extent that it is possible to substitute non-radioactive or
less radioactive isotopes (e.g. using isotopes with lower level radiation
or shorter half-lives for non-therapeutic laboratory applications).
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The
facility is eliminating the use of radioactive materials with longer
half-lives to the greatest possible extent for all applications.
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Used Oil |
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The organization properly
collects used oil from vehicles, and physical plant equipment (emergency
generators, compressors, etc.)
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Used oil is stored
in sturdy compatible containers labeled “used oil” that
are kept closed.
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Oil-containing equipment is not leaking.
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Spill control equipment
is available and used when necessary.
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Spills are reported
to local and federal authorities.
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Used oil is recycled
and receipts are kept indicating such.
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Staff is trained
and competency tested in appropriate spill response for used oil.
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A hazardous waste
determination is made and documentation is kept for used oil that is
destined for disposal. |
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Used oil filters
are drained for a minimum of twelve hours to ensure all residual oil
is collected before disposing of the filters as scrap metal.
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Facilities and equipment
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Recordkeeping and reporting |
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Air permits are
modified when fuel usage changes.
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Certificates to
Operate and Permits are not permitted to expire.
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Calculations are
done and kept on site verifying air permit requirements for boilers,
incinerators, generators or other releases to the air( e.g. ethylene
oxide). (40 CFR 70).
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Boilers, generators |
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Bio diesel is considered and possibly used with emergency
generators.
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Oil burning equipment
is well maintained. Logs and documentation evident. |
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Energy efficient boilers and generators are used to
minimize air pollution (Documentation: EC3.10.7).
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Policies indicate preference for energy efficient equipment
and practices throughout the facility to minimize fuel use.
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Incinerator |
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Incinerator is operated
within permit parameters and records are kept (40 CFR 70) [not
specific to incinerators]. |
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Design capacity
of the incinerator is not exceeded (40 CFR 70). |
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Hazardous waste
is not burned in the incinerator unless allowed by permit (40 CFR
70). |
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Incineration is eliminated or reduced as a waste treatment
or disposal method. (Incineration creates air pollution such
as dioxins, acid gases (such as hydrogen chloride), carbon monoxide,
and heavy metals. Air pollution from incinerators is deleterious
to community health.)
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All waste is minimized to eliminate emissions to air.
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Tanks |
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Spill Containment
and Countermeasures plan is in place for aggregate aboveground storage
greater than 1320 gallons.
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Tanks are permitted
or registered with either EPA or local authorities. |
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Underground storage
tanks must have been upgraded or replaced by 12/22/98 to meet integrity,
cathodic protection, leak and overfill protection requirements.
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Maintenance and
calibrating procedures are enacted to ensure tank monitors are working
appropriately. |
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Tanks are inspected
on weekly/monthly basis as per EPA or local regulations. |
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Tank alarm system
can be heard or otherwise adequately communicated to operators. |
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Procedures
are written and available for steps to be taken when tank alarm sounds. |
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Tank overfill protection
equipment is monitored.
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Corrosion protection
for tanks is adequate. If cathodic protection is used it is
inspected and replaced as required.
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Release detection
equipment for tanks and piping is adequate and up to date. Monitor
and record condition.
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Suspect releases
or spills are reported to EPA or appropriate local authority.
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TRACER Staff
respond appropriately regarding steps to be taken in the event of
tank alarm, spill, or leak. |
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Tank parts are appropriately
labeled with appropriate American Petroleum Institute (API) code.
E.g. Hexagon for #2 Fuel Oil (40 CFR 280) |
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Equipment on tank
to shut down when tank reaches 95% of capacity during fueling. |
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Tanks are located
a safe distance from other areas of the facility.
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Use of underground
storage tanks is eliminated, minimizing risk of leaks and spills. |
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- US Environmental
Protection Agency:
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Wastewater |
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Review of local
rules and codes to ensure all discharges to sewer (laboratories,
pharmacy, surgery, dialysis, central processing, nutrition services,
etc.) are permitted and/or if pretreatment is required (40 CFR 403). [can't
find 403] |
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All discharges to
sewer are reported to local wastewater authority (local permits,
40 CFR 403). |
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Spill
Prevention Control and Countermeasure Plans are in place, including
adequate secondary containment of storage tanks.
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All discharges to
the sewer are evaluated assure conformance with local, state and
federal restrictions, e.g. formalin, glutaraldehyde, pharmaceuticals,
alcohols, laboratory discharges, x-ray chemicals (40 CFR 403). |
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All discharges to
the sewer are evaluated for hazardous waste and reported to local
sewer are evaluated for hazardous waste and reported to local sewer
and hazardous waste authorities. (40 CFR 403) |
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Direct, point source
discharges are required to obtain National Pollution Discharge Elimination
System (NPDES) permits under 402 of the Clean Water Act (CWA) |
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If the facility
has any septic tanks, drain fields, lagoons, or other on-site wastewater
disposal areas, they are properly permitted |
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Hazardous materials
or waste storage or process areas DO NOT have floor drains that might
allow a release of a hazardous chemical to the environment |
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Wastewater is monitored,
tested and reported as per local, state and/or federal permit requirements,
and exceedances are managed appropriately. |
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Wash water from
kitchen cleaning or other cleaning operations is not discharged to
the storm sewer without a National Pollutant Discharge Elimination
Permit.
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Discharges
to sewer are reduced or eliminated.
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Click the icon to see the overall Tools & Resources
for 3.10.3
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