1. Lack of or Improper Labeling of Hazardous Waste – This is often overlooked and is so easy to remedy. Label your storage containersappropriately.
2. Improper or Failure to Perform Hazardous Waste Determinations – You need to know what hazardous waste regulations apply as a hazardous waste generator. This is one of the most critical first steps you can take.
3. Throwing Hazardous Waste down the Drain – Seems like a no-brainer. But as we all know, human beings are human. Short cuts can be tempting, especially if you are trying to cut costs. (See the court decision above)
4. Inadequate or No Hazardous Waste Manifests – Unless you are a conditionally exempt small hazardous waste generator, a uniform hazardous waste manifest must be used for all shipments.
5. Improper Management of Expired Hazardous Waste - Even expired waste is subject to the hazardous waste determination process. See #2
6. Lack of a Contingency Plan – If you are a large quantity generator of hazardous waste, then you must have a contingency plan in place.
7. Inadequate or No Training of Employees in Hazardous Waste Management – Without adequate training, employees won’t know the regulations and proper ways to dispose of hazardous waste. Not only is inadequate training a violation in and of itself, but failure to properly train employees is the first step a hospital should take to reduce exposure and liability.
8. Improper Consolidation of Hazardous Wastes from Nearby Facilities – You must use caution when consolidating wastes from other facilities and your own.
9. Improper Management of Mercury – All of these waste containing items could be handled as universal waste at a greatly reduced regulatory burden. They include, but are not limited to: Fluorescent BulbsThermometersMercury Vapor LamSphygmomanometerGastric TubesThermostats
10. Infrequent or No Weekly Inspections of Hazardous Waste Storage Areas – Hazardous waste storage areas should be inspected every 7 days. It does not matter if you are a large or small quantity generator, weekly inspections means weekly.