EPA v. HOWARD UNIVERSITY CORP. (HOWARD UNIVERSITY HOSPITAL)

Case summary

November 20, 2024, EPA Region III filed an Expedited Settlement Agreement and Final Order, simultaneously commencing and concluding an administrative action proceeding against Howard University Hospital Corp. ( HUH ) located at 2041 Georgia Ave., Washington, DC ( Facility ) for violations of the Resource Conservation and Recovery Act ( RCRA ) and the authorized District of Columbia Hazardous Waste Management Regulations, discovered during EPA's compliance evaluation inspection of the Facility on March 26 - 27, 2024. RCRA gives EPA the authority to control hazardous waste from the cradle-to-grave. This includes the generation, transportation, treatment, storage and disposal of hazardous waste. To that end, EPA develops regulations, guidance and policies that ensure the safe management and cleanup of solid and hazardous waste, and programs that encourage source reduction and beneficial reuse. HUH is a teaching hospital that provides both inpatient and outpatient services. Hazardous waste is generated through its pharmaceutical activities. The violations in the settlement include failure to have a satellite accumulation area at the point of generation, having an open container of hazardous waste while waste is neither being added or removed, storage of hazardous waste greater than 90 days, failure to properly label containers with universal waste lamps, failure to provide annual hazardous waste training, and failure to have the required content in the contingency plan. Region 3 notified DOEE, which had no objections to this action. Per the terms of the Expediated Settlement Agreement, HUH will pay a civil penalty in the amount of $7,500.00.

Defendants (1)

• HOWARD UNIVIERSITY HOSPITALNamed in complaintNamed in settlement

Facilities (2)

• HOWARD UNIVERSITY HOSPITAL CORP.

  2041 GEORGIA AVE NW, WASHINGTON, DC, 20060

  Registry ID: 110041980906

• HOWARD UNIVERSITY HOSPITAL

  2041 GEORGIA AVE NW, WASHINGTON, DC, 20060

  Registry ID: 110041980906

Statutes cited

• RCRA 3004 — Hazardous Waste Treatment, Storage, and Disposal Standards
• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Enforcement conclusions (1)

• HOWARD UNIVERSITY CORP. (HOWARD UNIVERSITY HOSPITAL)entered 2024-11-20

  Primary law: RCRA

  Federal penalty: $7,500

Timeline (4 milestones)

• 2024-11-20Complaint Filed/Proposed Order
• 2024-11-20Final Order Issued
• 2024-11-22Enforcement Action Data Entered
• 2024-12-17Enforcement Action Closed