||In December 2002, Richard Caspe, Director, Division of Enforcement and Compliance Assistance announced the Region 2 Hospital Compliance Initiative in a letter to 480 hospitals in New York, New Jersey, Puerto Rico, and the Virgin Islands. In this letter, the Region invited the hospitals to undertake voluntary self audits under the Audit Policy, or to participate in Audit Agreements. In addition, the letter announced that EPA would be inspecting hospitals in the Region and distributing information on environmental compliance at upcoming conferences to help with any compliance-related issues. The letter also included information on the audit policy (Federal Register), common violations found in hospitals, and environmental regulations that are applicable to hospitals
Prior to the announcement of the Hospital Compliance Initiative, EPA Region 2 had been reaching out to hospitals and healthcare facilities in the form of presentations at or participation in 10 hospital environmental compliance and/or P2 conferences and providing hospital inspection training.
Since the announcement of the Hospital Initiative, Region 2 has held two events: EPA/Long Island Jewish Medical Center Hospital Environmental Compliance /P2 Conference, Glen Oaks, NY; and EPA/Beth Israel Medical Center Hospital Environmental Compliance /P2 Conference, New York, NY in January and February 2003, respectively
Additional one to two-day conferences are planned in New York City, Albany, Rochester, Princeton, and in FY 2004 for Puerto Rico and the Virgin Island. Others may take place as resources become available.
These conferences address federal environmental regulations, including but not limited to RCRA, CAA, CWA, SPCC, UST, and EPCRA. Presentations are also made on the voluntary audit program, environmental management programs, and such voluntary federal P2 programs as environmentally preferable purchasing, EnergyStar, and WasteWise.
EPA Region 2 has sponsored a series of one to two day Hospital Pollution Prevention/Environmental Compliance Conferences starting in 2000. During the 2003 fiscal year there have been five sessions, including two in May (New York City and Albany), and one in June (Rochester). The goal of these recent conferences is to offer training to hospitals as a part of the Region 2 Hospital Compliance Initiative.
These conferences have involved about 40 to 115 attendees and covered a variety of environmental regulations, including RCRA, air, water, underground storage tanks, and a variety of EPA P2 programs, such as WasteWise, EnergyStar, National Performance Track, H2E, and others. EMSs were covered as well as the Voluntary Audit Policy/Corporate Audit Agreements. A final conference remains for the 2003 fiscal year: July in Princeton. These conferences have been cosponsored with trade organizations, hospitals, academies, and government agencies.
Region 2 patterned its Hospital Initiative after the successful College and University Compliance Initiative. As of Summer 2003, a number of hospitals have commenced corporate audit agreements, and one has been finalized. These agreements enable hospitals to self-audit, report, and correct violations found with extensive and possibly full penalty mitigation.