Environmental Compliance

Regulatory inspections can be costly to your business. Atlas Environmental is here to assist with your compliance concerns.

What is RCRA?

RCRA or the Resource Conservation and Recovery Act is a federal environmental regulation implemented by Congress in 1976 that defines and governs the way certain wastes we produce are disposed of. Several pharmaceuticals with hazardous characteristics fall under the umbrella of this regulation; these characteristics are toxicity, flammability, reactivity, and corrosiveness. RCRA regulations can be found in EPA 40 CFR Section 260.

Why does this affect you?

As a medical facility you are monitored by several Regulatory Agencies including the Environmental Protection Agency, Department of Toxic Substance Control, and Occupational Safety and Health Administration. The waste that your facility produces is your responsibility from cradle to grave, this means that from the time it enters your facility to the time it reaches its final disposal destination you are liable for it. Making sure that you have an effective and up to date RCRA program and disposal documentation keeps you in compliance and avoids penalties and fines.

Why Atlas?

The Expertise

This may seem like a complicated and tedious process but with Atlas Environmental Solutions it becomes quite simple. We will be there during every stage of your RCRA Compliance to help guide you through the process, answer any questions you may have, and find solutions to any obstacles you face.

Atlas Environmental Solutions has been on the forefront of RCRA pharmaceutical management and disposal for over a ten years, pioneering and developing several systems for both large hospitals and small clinics. Every medical facility is unique and there isn't a "blanket system" that works for everyone which is why we spend the time to learn the ins and outs of every facility before designing and implementing the most efficient system possible.


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The Plan

  1. Identification

    Deciding what RCRA wastes your facility produces by identifying substances with hazardous characteristics

  2. Collection

    Implementing a collection system to catch the identified RCRA wastes

  3. Storage

    Safely and properly storing your facilities wastes adhering to all applicable regulations

  4. Disposal

    Transporting your waste to a designated hazardous waste disposal facility for final disposal

  5. Documentation

    Properly documenting all wastes to provide proof of proper disposal to regulatory agencies

Common RCRA Pharmaceuticals

Listed below are pharmaceuticals commonly found at medical facilities that fall under the Resource Conservation and Recovery Act (RCRA) as hazardous waste. These wastes cannot be disposed of as Regulated Medical Waste and should be segregated and disposed of separately.

Substance Common Brands Characteristic Waste Code
Alcohol Solutions (>24%) Hand Sanitizer, Green Soap Tincture, Chloraprep, Duraprep, Nitrolingual Spray, Alcohol Prep Pads, Benzoin Tincture Flammable D001
Aldehydes Formalin Specimen Containers, Cidex OPA, Metricide, Gluteraldehyde Toxic U122
Barium Sulfate Readi-Cat, Liquid-E-Z-Paque, Liquid Polibar, Baro-Cat, E-Z-HD Toxic D005
Chemotherapy Medications Mitomycin, Ifosfamide, Cisplatin, Cyclophosphamide, Doxorubicin, Oncovin, Chlorambucil Toxic U010
U015
U150
U059
Inhalant Aerosols (Inhalers) Albuterol, Atrovent, Proventil, Symbicort Aerosol D001
Insulin Humalog, Novolog, Apidra, Novolin, Novolog, Humalog, Humulin Toxic D024
Mercury Thermometers, Thermostats Toxic U151
Nicotine (Gum, Patches, Spray, Inhalers) Nicorette, Nicotinell, Nicabate, Quitex Toxic P075
Nitroglycerin Nitro-Bid Oinment, Nitrostat Injectable, Parke-Davis Tablets Toxic P081
Selenium Sulfide Selenium Sulfide Toxic U205
Silver Sulfadiazine Cream Ascend, Thermazene, SSD, Watson Toxic D011
Silver Nitrate (Applicators) Grafco, TechMed Reactive D001
D011
Warfarin Marevan, Coumadin Toxic P001

Still have questions?

Atlas professionals are ready to answer your questions and assist with any concerns you encounter.

Atlas strives to provide specific solutions to any environmental concern a client may encounter. Our staff maintains the highest quality and consistency servicing both large and small clients across California. Environmental regulations at the local, state, and federal levels have made it difficult for any company to implement compliant environmental programs on their own. Let Atlas be a trusted partner in your environmental compliance program.


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Compliance Programs

The only thing standing between your facility and fines from regulatory agencies are the compliance programs you have in place. We have years of experience working with both Small Quantity Generators and Large Quantity Generators from a variety of different fields including medical, manufacturing, industrial, municipal, government, and agricultural.

Achieving compliance is not a cookie cutter affair and must be approached from several angles to insure nothing falls through the cracks. We take the time to observe and learn your processes before designing the most effective program to consolidate and dispose of your wastes.

Our Strategy

  1. Take the time to understand the client and their facility
  2. Utilize our extensive knowledge of the industry and applicable regulations to advise the client on the most effective compliance program
  3. Implement the compliance program observing all steps to ensure compliance, safety, and cost efficiency
  1. Record keeping of all important documentation including hazardous waste manifests, bill of ladings, medical waste manifests, and all other waste documentation
  2. Maintain regular dialogue and transparency with the client to ensure continued compliance and the resolution of any issues

Compliance is not a onetime task, it is an ongoing battle which is why Atlas believes in always having open lines of communication and availability to meet with clients no matter how small or large.

Still have questions?

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CERS & Regulatory Preparation

No matter the size or function of your facility if you produce waste you are subject to regulatory inspection. There are several regulatory agencies making their rounds throughout the state; the California Environmental Protection Agency (Cal EPA), the Department of Toxic Substance Control (DTSC), California Occupational Safety and Health Administration (Cal OSHA), and local Certified Unified Program Agencies (CUPA).

Who's Regulating What?

Environmental Protection Agency
  • Proper handling and disposal of wastes on and off site
  • Improper disposal of hazardous wastes effect on the environment
  • Designation and classification of hazardous wastes
EPA Site
Department of Toxic Substance Control
  • Act as the enforcement branch for the California EPA
  • Appoint and track EPA I.D Numbers
  • Track all hazardous waste manifests for the State of California
DTSC Site
Occupational Safety and Health Administration
  • Create and enforce policy for the health and safety of employees
  • Perform investigations of work place accidents
  • Enforce standards for proper employee training
OSHA Site
Certified Unified Program Agencies
  • Enforce local, state, and federal environmental regulations
  • Perform site inspections and manage facilities environmental programs (CERS) for local municipalities
CUPA Site

CUPA Program Preparation

Atlas provides regulatory consulting, corrective action, and online form submittal for the following California Environmental Reporting System(CERS) categories:

Hazardous Materials Business Plans
  • Facility Information
  • Hazardous Materials Inventories
  • Emergency Response and Training Plans
Hazardous Waste Generator Programs
  • Facility Information
  • Recyclable Materials Report
  • Remote Waste Consolidation Annual Report
Storage Tank Programs and Closures
  • Facility Information
  • Underground Storage Tank Reporting
  • Hazardous Waste Tank Closure Certifications
  • Aboveground Petroleum Storage Tanks
Tiered Permitting Program
  • Facility Information
  • Tiered Permit Application
  • Process Review
California Accidental Release Prevention Program
  • Facility Information
  • Design and Implementation of Release Prevention and Spill Response Plans
  • Spill Response Training
  Hazardous Materials Plan Hazardous Waste Generator Program Underground Storage Tank Program Tiered Permitting Program Aboveground Petroleum Storage Tank Accidental Release Prevention Program
Facility Information Required Required Required Required Required Required
Hazardous Materials Inventory Required          
Emergency Response & Training Plans Required          
Underground Storage Tanks     Required      
Tiered Permittings       Required    
Recyclable Materials Report   Required        
Remote Waste Consolidation Site Annual Notification   Required        
Hazardous Waste Tank Closure Certification   Required        
Aboveground Petroleum Storage Act         Required  

Regulatory Inspection Preparation

Regulatory inspection at your facility is an eventuality not a possibility which is why Atlas believes in a hands on approach to assisting our clients through any inspection. We will be there step by step through the preparation, inspection, and resolution of any inspection actively advising our clients and immediately remedying any issues that present themselves.

Experts in:

  • Joint Commission Inspections
  • Environment of Care Preparation
  • Phase 1 and 2 Environmental Site Assessments
  • Environmental Incident Investigations and Reporting

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Air Monitoring

At any given time there are thousands of particulates in the air that we breath, most of them are benign and harmless but there are several hazardous materials that when introduced into the air of our environment can cause irreparable harm.

To ensure that the environments we are exposed to at our homes and work are not hazardous Atlas offers the latest and most efficient air monitoring solutions available.

Mold/Bacteria

Mycotoxins and bacteria in the environment can cause a large range of negative affects to the human body and once identified should be limited or eliminated if possible. Unlike most hazards mold and bacteria are living organisms that thrive in everyday environments that people reside and work in.

Utilizing physical investigations, moisture monitoring, air sampling, and spore trap analysis we are able to create a picture of the microbial activity in your environment and recommend appropriate remediatorial action.

Asbestos

For years asbestos was considered a wonder material for its strength and fire resistance and used in everything from insulation to brake pads. While not inherently toxic it causes irreversible damage to your lungs and digestive system when introduced to your body including mesothelioma, asbestosis, and digestive system cancers. Identifying asbestos containing materials, especially airborne particulates, is extremely important in ensuring an environment that is safe to occupy.

We utilize Certified Asbestos Consultants to identifying possible asbestos containing materials and test those materials for the presence of the carcinogen.

Lead

Lead is another material that was used for years for its advantageous properties when augmenting paint or fuels. The toxic effects of lead exposure can take time to develop in adults but far less time for children to develop symptoms and can be irreversible. Before renovating or construction efforts are underway paint and certain building materials should always be tested for the presence of lead before disturbing them.

Medical Gases

The medical field requires several gases and chemicals to perform procedures including nitrogen, carbon dioxide, formaldehyde, and anesthetic gases.

Regularly testing the exposure levels of these gases to employees throughout their tasks is essential to ensuring a safe and healthy work environment which is why Atlas utilizes Industrial Hygienists to design, execute, and interpret testing protocols in accordance with all applicable regulations.

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Mold

Unlike most hazardous materials mold spores are living microorganisms that can easily migrate and multiply when remediated and disposed of incorrectly.

Atlas utilizes years of experience and the highest standards when approaching a mold remediation project in hospitals, homes, and other facilities. We believe in a "Zero Release" policy in which not even a single spore or contaminant is able to escape containment and we do not consider a project finalized until spore levels are at or below outside air levels.

Asbestos/Lead

There is no room for error when handling hazardous materials with as devastating health effects as lead and asbestos.

Maintaining proper containment and remediation practices is essential to ensure the safety of your family and employees. Atlas complies with all guidelines set forth by the Asbestos Hazard Emergency Response Act (AHERA) and Housing and Urban Development (HUD) guidelines when approaching any remediation project involving asbestos or lead.

Soil and Storage Tanks

Remediating contaminated soil and decommissioning above and underground ground storage tanks can be one of the most difficult environmental tasks a facility can face. Tanks often degrade and leak over time and hazardous materials do not often move uniformly or predictable through soil.

Utilizing the expertise of experienced remediation teams and geologists Atlas offers the safest and most compliant solutions to removing tanks and remediating soil while maintaining the lowest costs possible. We are happy to communicate on your behalf with any regulatory agency throughout the process and will ensure all the necessary requirements are met.

Still have questions?

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559.313.8200 | info@atlasenvironmental.net | 24 Hour Emergency Response: 866.547.2857

3443 W. Gettysburg Avenue, Fresno, CA 93722