Document X79n55B13ezyBGJmyr148wv0B

KINGSBROOK JEWISH MEDICAL CENTER INSPECTION REPORT Inspection Date(s): 12 February 2024 Inspection Announced: No Facility or Site Name: Facility/Site Physical Location: (city, state, zip code) Mailing address (if different from above): cility/Site Contacts: Website: Kingsbrook Jewish Medical Center 585 Schenectady Ave East Flatbush, Brooklyn, NY 11203-1891 Suite C 585 Schenectady Ave Nayyer Pervez. MS. CHSP. CHEP. Director, Safety and Emergency Management. Safety Officer P. 718-604-5227 Fax. 5852 C. 929-675-1559 nayyer.pervez@obhny.org Joseph Lubrano, Assistant Director Building Services JLubrano@kingsbrook.org 718-604-5000 x5657 | Mobile: 646-285-3498 https://onebrooklynhealth.org/ RCRA ID Number: NYD986954188 Latitude, Longitude: 40.6591439, -73.9333434 Facility/Site Personnel Participating in Inspection: Joseph Lubrano Assistant Director Building Services Nayyer Pervez Director Safety & Emergency Antonio Alas Clinical Engineering Director Nancy Rojas Mark Drukartz, DDS Clinical Engineering Lead Technician Associate Director, Dept of Dental P. 718-604-5227 Fax. 5852 C. 929-675-1559 nayyer.pervez@obhny.org 718-240-5595 718-613-4959 AAlas@interfaithmedical.org AAlas@bhmcny.org Office: (718) 604 - 5732 Cell: (929) 271 - 2746 nrojas@interfaithmedical.org 516-282-5113 Chris@absolutefbs.com Inspector(s): Carl F. Plssl US EPA, Enforcement Officer/Engineer Additional Inspection Report Elements: Photos Inspection Report Author: 1|Page Plossl.Carl@epa.gov (212) 637-4088 Carl F. Plssl RCRA Compliance Branch KINGSBROOK JEWISH MEDICAL CENTER INSPECTION REPORT CARL PLOSSL Digitally signed by CARL PLOSSL Date: 2024.04.01 14:55:50 -04'00' Supervisor Leonard Grossman LEONARD GROSSMAN Digitally signed by LEONARD GROSSMAN Date: 2024.04.11 15:26:23 -04'00' SECTION I - INTRODUCTION Purpose of the Inspection Objective A Compliance Evaluation Inspection (CEI) was conducted to determine the facility's compliance with the Resource Conservation and Recovery Act (RCRA) requirements for hazardous waste management. The facility has been inspected by EPA for RCRA compliance in the previous year, with a finding of non-compliance with universal waste requirements, and has had a notification history as a small and very small quantity generator: Opening Conference 2|Page RCRA Compliance Branch KINGSBROOK JEWISH MEDICAL CENTER INSPECTION REPORT 12 Feb 2024. I, EPA Region 2 RCRA inspector Plssl, arrived at the main entrance to the Briger Pavilion entrance to the Kingsbrook Jewish Medical Center (Kingsbrook) at ~2:06 pm for an unannounced inspection of the hospital. I announced and identified myself at the reception desk and contacted Joseph Lubrano, Assistant Director Building Services, and I was subsequently met by him. Mr. Lubrano was familiar the nature of federal RCRA inspections from my previous site visits. We moved to the Masin Pavilion to check on the universal waste storage room in the basement. Facility/Site Description From Wikipedia: Kingsbrook Jewish Medical Center is a 303-bed full-service community teaching hospital with an estimated 2,100 full-time employees, located in the neighborhood of East Flatbush in Brooklyn, New York. The hospital is made up of a complex of eight conjoined buildings which are dispersed over a 366,000 square foot city block. From One Brooklyn Health (for full text, see Appendix): It is currently under the network of Kingsbrook Healthcare System Corporation which, in addition to the hospital, comprises Rutland Nursing Home, containing 466 short and long term-care beds, Rutland Adult Day Healthcare Center, and its ancillary outpatient clinics. The hospital serves a diverse population from a wide range of ethnic backgrounds. Kingsbrook is accredited by the Joint Commission and is a non-for-profit of both the Greater New York Hospital Association and the Healthcare Association of New York State. member Kingsbrook provides ambulatory surgery, cardiology, critical care medicine, emergency/urgent care, gastroenterology, pulmonary, a ventilator dependent unit, wound care including hyperbaric chambers, diagnostic imaging including MRI and CT scanning, and an outpatient center. The hospital is part of an ongoing merger of Brooklyn hospitals under the banner of One Brooklyn Health System including Brookdale University Hospital and Medical Center and Interfaith Medical Center with which New York State has invested nearly $700 million. According to Mr. Lubrano, et. al.: 3|Page RCRA Compliance Branch KINGSBROOK JEWISH MEDICAL CENTER INSPECTION REPORT General o Mr. Lubrano has worked here for some 4 years o Many hospital services have been shut down, including chemotherapy Infusion center closed for at least 1 year o Biomedical stores and disposes of surplus medical equipment o Pharmacy is the main generator of hazardous waste o Stericycle is the main waste hauling and disposal vendor o Clean Earth is the universal waste vendor o Hazardous waste storage is on the 1st floor of Lafrak o Universal waste storage is in the basement of Masin o Central Supply closed down and Materials Management replaced it on site o Clinical Engineering is managing the surplus equipment and supply management and the determination as to dispositions: transfer to other network facilities; resale as viable equipment; disposal as scrap, medical waste, pharmaceutical waste, hazardous,... Hazardous wastes regularly generated from the Pharmaceutical Department: o The Pharmacy now just services the needs of the nursing home Fill medical prescriptions and deliver twice per week to units No longer provide IV services In the past, a range of lab services were conducted on site (downsized) o Expired, unopened pharmaceuticals are mainly disposed thru takeback program with a vendor InMar o Open, expired and/or surplus pharmaceuticals are disposed thru Stericycle o Pharmacy wastes: alcohols, mercury, silver, chloroform, m-cresol, lindane (cyclohexane, 1,2,3,4,5,6-hexachloro-, (1alpha, 2alpha, 3beta, 4alpha, 5alpha, 6beta)-) (U129), phenol (U188), selenium sulfide (U205) o Stericycle picks up from Pharmacy every Thursday Other hazardous waste generation o Surplus, damaged, or spent diagnostic equipment and other medical supplies Biomedical Dept. is responsible o Dental amalgam from the Dental Department o Spent fluorescent lamps o Old paints and spent cleaning and painting solvents o Spent lead acid, NiCd, and lithium batteries o E-wastes Waste dispositions o Universal waste picked up every 6 months with Stericycle subcontracting with Clean Earth for disposal o No special management for broken fluorescent bulbs o Dental sends amalgam to Engineering for disposal (no available records) The dental amalgam waste container was difficult for the dental staff to locate 4|Page RCRA Compliance Branch KINGSBROOK JEWISH MEDICAL CENTER INSPECTION REPORT 5|Page RCRA Compliance Branch KINGSBROOK JEWISH MEDICAL CENTER INSPECTION REPORT Facility has notified and is operating as a very small quantity generator (conditionally-exempt small quantity generator under NYSDEC regulations). Since 2018, Brooklyn Hospital has been averaging some 1,400-lbs/year or 117-lbs/month. Records requested in the past: o Universal waste invoices (not received) o Explanation for the regular generation of m-cresol (not received) Additional records requested during inspection: o Engineering Department's surplus equipment lists (received)(see attachment) SECTION II - OBSERVATIONS The accompanying Kingsbrook Jewish Medical Center Inspection Photos.pptx document is the complete set of inspection observations made during the facility walkthrough with Messrs. Lubrano and Alas and Ms Rojas. SECTION III - AREAS OF CONCERN Concerns Regular waste dental amalgam management practices were unclear to staff and hazardous waste container was difficult for the staff to locate. Formal hazardous waste determinations were due on stockpiled surplus equipment and supplies. Universal Waste Storage Room (Basement, Masin Pavilion): o Various fluorescent lamps were stored in containers that were not structurally sound or adequate to prevent breakage. o Some fluorescent lamps containers were not closed. 6|Page RCRA Compliance Branch KINGSBROOK JEWISH MEDICAL CENTER INSPECTION REPORT o Fluorescent lamps were stored in unlabeled containers, i.e., not labeled or marked clearly with one of the following phrases: "Universal Waste--Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)." o Universal waste batteries (i.e., each battery), or a container in which the batteries are contained, were not labeled or marked clearly with any one of the following phrases: "Universal Waste--Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies);" o No demonstration of the length of time that the universal waste had been accumulated from the date it becomes a waste or was received. o Other waste, labeled "Obsolete Equipment," while determined to be a waste, had not been subject to a hazardous waste determination (likely contained batteries). o Employee universal waste education did not adequately train in the proper handling appropriate to the type(s) of universal waste handled at the facility. Closing Conference In Engineering, Mr. Alas, Ms Rojas, and I reviewed my findings and we discussed any follow up. Ms Rojas said that she would email me the surplus equipment lists shortly (received). I told them that I would send a copy of a medical facility waste determination guidance that we had found useful. I returned to the Facilities offices where I met with Nayyer Pervez, Director of Safety & Emergency, to review findings and to request universal waste and dental amalgam disposal records, one year each. INSPECTION PHOTOGRAPHS: See Kingsbrook Jewish Medical Center Inspection Photos 12 Feb 2024.pptx UNIVERSAL WASTE REGULATIONS: See Appendix 1 FOLLOW UP EMAILS: See Appendix 2 SURPLUS EQUIPMENT LISTS: See Appendix 3 ATTACHMENT: Surplus Equipment Lists (Complete) 7|Page RCRA Compliance Branch KINGSBROOK JEWISH MEDICAL CENTER INSPECTION REPORT Appendix 1: Certain, Applicable Universal Waste Regulations Title 40 Chapter I Subchapter I Part 273 Small quantity handler of universal means a universal waste handler who does not accumulate 5,000 kilograms or more of universal waste (batteries, pesticides, mercury-containing equipment, lamps, or aerosol cans, calculated collectively) at any time. A small quantity handler of universal waste is: (a) Prohibited from disposing of universal waste; and (b) Prohibited from diluting or treating universal waste, except by responding to releases as provided in 40 CFR 273.17; or by managing specific wastes as provided in 40 CFR 273.13. Lamps. A small quantity handler of universal waste must manage lamps in a way that prevents releases of any universal waste or component of a universal waste to the environment, as follows: (1) A small quantity handler of universal waste must contain any lamp in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents of the lamps. Such containers and packages must remain closed and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions. (2) A small quantity handler of universal waste must immediately clean up and place in a container any lamp that is broken and must place in a container any lamp that shows evidence of breakage, leakage, or damage that could cause the release of mercury or other hazardous constituents to the environment. Containers must be closed, structurally sound, compatible with the contents of the lamps and must lack evidence of leakage, spillage or damage that could cause leakage or releases of mercury or other hazardous constituents to the environment under reasonably foreseeable conditions. A small quantity handler of universal waste must label or mark the universal waste to identify the type of universal waste as specified below: (a) Universal waste batteries (i.e., each battery), or a container in which the batteries are contained, must be labeled or marked clearly with any one of the following phrases: "Universal Waste-- Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies);" (e) Each lamp or a container or package in which such lamps are contained must be labeled or marked clearly with one of the following phrases: "Universal Waste--Lamp(s)," or "Waste Lamp(s)," or "Used Lamp(s)". A small quantity handler of universal waste may accumulate universal waste for no longer than one year from the date the universal waste is generated, or received from another handler, unless the requirements of paragraph (b) of this section are met. A small quantity handler of universal waste who accumulates universal waste must be able to demonstrate the length of time that the universal waste has been accumulated from the date it becomes a waste or is received. The handler may make this demonstration by: 8|Page RCRA Compliance Branch KINGSBROOK JEWISH MEDICAL CENTER INSPECTION REPORT (1) Placing the universal waste in a container and marking or labeling the container with the earliest date that any universal waste in the container became a waste or was received; (2) Marking or labeling each individual item of universal waste (e.g., each battery or thermostat) with the date it became a waste or was received; (3) Maintaining an inventory system on-site that identifies the date each universal waste became a waste or was received; (4) Maintaining an inventory system on-site that identifies the earliest date that any universal waste in a group of universal waste items or a group of containers of universal waste became a waste or was received; (5) Placing the universal waste in a specific accumulation area and identifying the earliest date that any universal waste in the area became a waste or was received; or (6) Any other method which clearly demonstrates the length of time that the universal waste has been accumulated from the date it becomes a waste or is received. A small quantity handler of universal waste must inform all employees who handle or have responsibility for managing universal waste. The information must describe proper handling and emergency procedures appropriate to the type(s) of universal waste handled at the facility. 9|Page RCRA Compliance Branch KINGSBROOK JEWISH MEDICAL CENTER INSPECTION REPORT Appendix 2: Follow Up Emails From: Pervez, Nayyer <Nayyer.Pervez@obhny.org> Sent: Tuesday, February 13, 2024 11:55 AM To: Plossl, Carl <Plossl.Carl@epa.gov> Subject: RE: [EXT] RE: Kingsbrook - Unclaimed Equipment List Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Thank You for sharing very useful information. I will work with pharmacy for compliance. Please send me information regarding EPA scope of survey for healthcare facilities, such as universal waste, dental or any. Regards, Nayyer Pervez. MS. CHSP. CHEP. Director, Safety and Emergency Management. Safety Officer. One Brooklyn Health l Kingsbrook Jewish Medical Center l Rutland Nursing Home 585 Schenectady Avenue. Brooklyn, NY 11203 P. 718-604-5227 Fax. 5852 C. 929-675-1559 E. nayyer.pervez@obhny.org From: Plossl, Carl <Plossl.Carl@epa.gov> Sent: Tuesday, February 13, 2024 10:57 AM To: Rojas, Nancy <NRojas@interfaithmedical.org> 10 | P a g e RCRA Compliance Branch KINGSBROOK JEWISH MEDICAL CENTER INSPECTION REPORT Cc: Pervez, Nayyer <Nayyer.Pervez@obhny.org>; Alas, Antonio <AAlas@INTERFAITHMEDICAL.org> Subject: [EXT] RE: Kingsbrook - Unclaimed Equipment List Thank you Nancy. Attached is Florida Department Of Environmental Protection's List of Pharmaceuticals that are Potentially Hazardous Wastes When Discarded, that we discussed. While not entirely comprehensive, it is the closest that I've found. Carl **************************************************************** CARL F. PLSSL Environmental Engineer, Enforcement Officer plossl.carl@epa.gov Direct Dial: (212) 637-4088 Fax: email Mobile: (646) 567-0597 **************************************************************** U.S. Environmental Protection Agency Enforcement and Compliance Assurance Division RCRA Compliance Branch, RCRA Senior Enforcement Team 290 Broadway, 21st Floor NYC, NY 10007-1866 **************************************************************** From: Rojas, Nancy <NRojas@interfaithmedical.org> Sent: Monday, February 12, 2024 2:56 PM To: Plossl, Carl <Plossl.Carl@epa.gov> 11 | P a g e RCRA Compliance Branch KINGSBROOK JEWISH MEDICAL CENTER INSPECTION REPORT Cc: Pervez, Nayyer <Nayyer.Pervez@obhny.org>; Alas, Antonio <AAlas@INTERFAITHMEDICAL.org> Subject: Kingsbrook - Unclaimed Equipment List Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Hello Carl, As requested, please see attached current inventory of unclaimed medical equipment at Kingsbrook Jewish Medical Center. Best, Nancy Rojas Clinical Engineering Lead Technician Kingsbrook Jewish Medical Center 585 Schenectady Ave Brooklyn, NY 11203 Office: (718) 604 - 5732 Cell: (929) 271 - 2746 nrojas@interfaithmedical.org 12 | P a g e RCRA Compliance Branch KINGSBROOK JEWISH MEDICAL CENTER INSPECTION REPORT Appendix 3: Engineering Department's Surplus Equipment Lists See Attached PDF for complete list 13 | P a g e