Potential RCRA Liability for Health Care Facilities

Hospitals accustomed to a world of acronyms such as PPO, PHO, DRG, HMO, CMS, should make sure they include another to the already lengthy list: RCRA. Facilities that do not learn about and comply with RCRA could find themselves on the wrong end of an EPA inspection, facing the very real prospect of a six-figure fine. The list of hospitals that have already paid such fines is sobering: to name a few, North Shore University Hospital ($57,749), Atlantic Health Systems/Mountainside Hospital ($64,349), Memorial Sloan Kettering ($214,423), and Nassau Health Care Corporation/Nassau University Hospital ($279,900). With well-publicized increases in EPA hiring of enforcement personnel, now is the time for hospitals to take RCRA seriously. 

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