In a letter dated December 27, 2002, Region 2 of the U.S. Environmental Protection Agency (EPA) announced its plans to conduct compliance inspections of hospitals in 2003 and encouraged hospitals to consider remediation through the EPA's voluntary audit policy. This letter to hospital CEOs in Region 2 (New York, New Jersey, Puerto Rico, and the U.S. Virgin Islands) noted that EPA inspections will assess hospital compliance with the Resource Conservation and Recovery Act, the Clean Air Act, and the Clean Water Act. Since 1999, the EPA has been conducting a similar inspection initiative with colleges and universities in EPA Regions 1, 2, and 3. The proposed fines and actual settlement amounts from these inspections were substantial and ranged from $100,000 to $800,000. Primary areas of focus during the college and university inspections were hazardous waste management in both clinical and research laboratories, storage tanks, and water and air emissions. More information about the university compliance initiative is available on the EPA Region 2 Web site at www.epa.gov/region02/p2/college.

The EPA encourages hospitals to consider voluntary self-audits and remediation through participation in the EPA's audit policy. The primary benefit of the self-audit approach is possible elimination or substantial reduction of fines and a determination not to recommend criminal prosecution. A number of major universities in NYS and NJ are among the facilities that are participating in the self-audit program. Detailed information about the audit agreements for these institutions is posted on the EPA Web site at www.epa.gov/region02/capp/cip/agreeex.htm.

To assist hospitals with environmental compliance, EPA Region 2 is hosting a program at Beth Israel Medical Center on February 26, 2003. To register, contact Diane Buxbaum, EPA Region 2, at (212) 637-3919, or Janet Brown, Director of Hospital Waste Management, Beth Israel Medical Center, at (212) 420-2442. In addition, GNYHA is scheduling a briefing on the university experience with EPA compliance inspections, which will feature university environmental services staff, a law firm experienced in negotiating with the EPA, and an environmental consulting firm.

If you have questions about the EPA inspection initiative or the self-audit program, contact Susan Stuard at GNYHA.