Corporate Misconduct Accountability Project
University of Maryland Baltimore Washington Medical Center · EPA Enforcement Settlement
Maryland Hospital Fined Just $13,750 for Years of Hazardous Waste Violations
University of Maryland Baltimore Washington Medical Center systematically violated federal hazardous waste laws for years, exposing workers and the community to dangerous chemicals, then paid a penalty smaller than a single executive’s monthly salary.
HIGH SEVERITY
TL;DR
For nearly four years, UM Baltimore Washington Medical Center operated as a large quantity generator of hazardous waste while systematically violating federal safety requirements. EPA inspectors found open containers of flammable chemicals, unlabeled hazardous waste throughout the facility, no weekly inspections, inadequate employee training, and deficient emergency plans. The hospital resolved all violations by paying just $13,750, a sum so small it incentivizes continued non-compliance over investing in proper safety measures.
This settlement shows why minimal fines fail to protect workers and communities from corporate cost-cutting.
$13,750
Total penalty for 4 years of violations
4 years
Duration of known violations as LQG
11
Distinct regulatory violations cited
3
Types of hazardous chemicals improperly stored
The Allegations: A Breakdown
Core Allegations
What they did · 8 points
| 01 | The hospital operated without a valid permit because it failed to meet basic exemption conditions, including proper labeling, container closure, and weekly inspections. EPA found the facility violated RCRA requirements that would have allowed it to operate without a full permit. | high |
| 02 | Inspectors discovered multiple satellite accumulation containers in the Gross Room, Pour Room, Hematology Room, and Main Pharmacy Area that completely lacked the required ‘Hazardous Waste’ labels. Workers handled these containers without knowing their contents posed hazards. | high |
| 03 | The hospital left hazardous waste containers open in multiple locations. The Pour Room had an open funnel on a container of xylene and hematoxylin. The Pharmacy IV Prep room had an open 18-gallon hazardous waste container. Room EL017 had a container with a split lid containing IV bags and tubing. | high |
| 04 | UM BWMC admitted that hazardous waste accumulation areas in Rooms NL-46 and EL-017 received no weekly inspections, directly violating mandatory safety protocols designed to catch leaks, spills, or deteriorating containers before they cause harm. | high |
| 05 | The hospital failed to document any of the weekly inspections it did perform in other areas. Without inspection logs, the facility could not demonstrate compliance and left no record to identify patterns of problems or verify corrective actions. | medium |
| 06 | The facility’s contingency plan lacked critical information, including a complete list of emergency coordinators and emergency equipment locations. In an actual emergency involving hazardous waste, responders would not know who to contact or where to find needed equipment. | high |
| 07 | Employee training occurred only once every three years instead of the required annual review. Job descriptions failed to specify hazardous waste management duties. Workers handling dangerous chemicals operated without current knowledge of proper procedures. | high |
| 08 | The hospital discarded waste aerosol cans in regular trash without making any hazardous waste determination. This practice meant potentially hazardous materials entered the regular waste stream with no safety evaluation. | medium |
Regulatory Failures
Why enforcement failed · 5 points
| 01 | The hospital operated as a registered large quantity generator for nearly four years before EPA conducted its first compliance inspection. Despite Maryland having an authorized state program, no state inspections caught these widespread violations earlier. | high |
| 02 | EPA waited until June 2024 to notify Maryland’s Department of the Environment of enforcement action, more than four months after the February inspection documented serious violations. This delay allowed unsafe conditions to persist. | medium |
| 03 | The settlement used the Expedited Settlement Agreement process, designed for quick resolution. This streamlined approach produced a minimal penalty without public hearing or detailed examination of how long violations actually existed before 2020. | medium |
| 04 | The settlement agreement states EPA ‘considered’ statutory factors and penalty policies but provides no breakdown showing how the $13,750 figure relates to actual harm risked, economic benefit gained, or deterrence needed. | medium |
| 05 | No independent monitor or third-party auditor was required as part of the settlement. EPA accepted the hospital’s certification that violations ‘have been corrected’ without mandating ongoing verification or public reporting. | medium |
Profit Over People
The cost-benefit calculation · 5 points
| 01 | Proper compliance would require annual training for approximately 200 employees handling hazardous waste, plus costs for proper containers, weekly inspection staff time, and documentation systems. The hospital avoided these recurring costs for years while risking only a one-time $13,750 penalty. | high |
| 02 | The settlement amount equals roughly one month’s compensation for a single senior hospital executive. For an institution that is part of the University of Maryland Medical System, this penalty represents a negligible fraction of operating budget. | high |
| 03 | By failing to conduct or document weekly inspections, the hospital avoided dedicating staff time and resources to compliance activities. Each uninspected week represented salary savings that accumulated across multiple storage areas over four years. | medium |
| 04 | The hospital’s decision to provide training only every three years instead of annually cut training costs by roughly two-thirds. Employee safety knowledge degraded over time while the institution preserved budget for other priorities. | medium |
| 05 | Discarding aerosol cans in regular trash instead of making hazardous determinations and using proper disposal channels saved per-item hazmat disposal fees. The hospital externalized these costs onto workers and waste handlers who unknowingly managed potentially dangerous materials. | medium |
Public Health and Safety
Who was endangered · 6 points
| 01 | Workers in the Gross Room, Pour Room, Hematology Room, and Pharmacy areas handled unlabeled containers daily without knowing they contained hazardous substances. Formalin, methanol, xylene, and silver nitrate all pose serious health risks including respiratory damage and chemical burns. | high |
| 02 | Open containers of xylene and hematoxylin in the Pour Room released fumes into the workplace atmosphere. Xylene exposure causes dizziness, headaches, and long-term neurological effects. Workers in this area breathed contaminated air during their shifts. | high |
| 03 | The split lid on an 18-gallon container in Room EL017 meant hazardous waste could spill or release vapors. IV bags and tubing in this damaged container likely contained pharmaceutical residues or other chemical contaminants. | high |
| 04 | Without a complete list of emergency coordinators and equipment locations, any spill or exposure incident would face delayed response. Workers suffering chemical exposure would wait longer for treatment while responders searched for safety equipment and responsible personnel. | high |
| 05 | The facility generated and stored ethanol classified as both D001 (ignitable) and F003 (spent solvent). Open containers and improper storage of ignitable waste created fire hazards that could endanger patients, visitors, and staff throughout the hospital. | high |
| 06 | Universal waste batteries throughout the facility lacked proper labels and accumulation start dates. Workers could not identify when batteries exceeded the one-year accumulation limit, increasing the risk of leakage, corrosion, and heavy metal exposure. | medium |
Worker Exploitation
How employees were put at risk · 5 points
| 01 | The hospital required employees to handle hazardous waste without providing annual refresher training. Workers operated with outdated knowledge for up to three years, leaving them unable to recognize new hazards or follow updated safety procedures. | high |
| 02 | Job descriptions for employees handling hazardous waste failed to specify their duties related to waste management. Workers had no clear understanding of their safety responsibilities or authority to refuse unsafe tasks. | medium |
| 03 | Employees working near open hazardous waste containers in the Pour Room, Pharmacy IV Prep, and Room EL017 breathed chemical fumes as a routine part of their workday. The hospital normalized this exposure rather than enforcing basic container closure rules. | high |
| 04 | Staff in areas with uninspected hazardous waste storage worked without the weekly safety checks designed to identify problems before they caused injury. The hospital denied these employees the protection that regular inspections provide. | medium |
| 05 | Workers handled satellite accumulation containers marked only with chemical names like ‘Methanol Waste’ but lacking ‘Hazardous Waste’ labels. This incomplete labeling prevented employees from immediately recognizing the danger level and taking appropriate precautions. | medium |
Corporate Accountability Failures
How they avoided consequences · 6 points
| 01 | Senior Vice President and Chief Operating Officer John Greely signed the settlement, confirming that top hospital leadership knew of the violations. Despite this executive-level awareness, the penalty imposed no personal consequences for decision-makers. | high |
| 02 | The agreement allowed the hospital to ‘neither admit nor deny’ the specific factual allegations while admitting only jurisdictional facts. This language lets UM BWMC avoid public acknowledgment of wrongdoing in the violations themselves. | medium |
| 03 | The settlement includes no requirement for public disclosure of compliance status going forward. The hospital can return to business as usual without ongoing transparency about whether it maintains proper hazardous waste practices. | medium |
| 04 | EPA reserved the right to pursue future enforcement but imposed no enhanced monitoring or mandatory self-reporting. The agency relies on chance future inspections to verify compliance rather than proactive oversight. | medium |
| 05 | The hospital certified that ‘alleged violations have been corrected’ but the settlement provides no detail about what corrective actions were taken or how the facility verified their effectiveness. The public receives no information about whether problems actually stopped. | medium |
| 06 | By agreeing to an expedited settlement, the hospital avoided a public hearing where community members and workers could learn details about the violations and their duration. The process favored speed and secrecy over public accountability. | medium |
Exploiting Delay
How they prolonged unsafe conditions · 4 points
| 01 | The hospital registered as a large quantity generator in February 2020 but faced its first EPA compliance inspection four years later in February 2024. During this entire period, the facility operated with widespread violations that remained undetected. | high |
| 02 | After EPA documented violations on February 6, 2024, the agency waited until June 24 to formally notify Maryland’s Department of the Environment. This four-month gap allowed unsafe conditions to continue while bureaucratic notifications proceeded. | medium |
| 03 | The expedited settlement process moved the case from inspection in February to final order by September 2024, presenting this speed as efficiency. In reality, the quick settlement prevented deeper investigation into how long before 2020 these practices existed. | medium |
| 04 | The settlement imposes a 30-day payment deadline but includes no specific timeline for the hospital to demonstrate sustained compliance improvements. Short-term payment obligations replaced long-term behavioral requirements. | medium |
The Bottom Line
What this case reveals · 5 points
| 01 | A major hospital within the University of Maryland system calculated that paying a trivial fine cost less than implementing required safety measures. The settlement proves this calculation was correct, incentivizing future violations across the healthcare industry. | high |
| 02 | Workers and nearby communities bore the actual costs through chemical exposure risks while the hospital kept the financial savings from non-compliance. This wealth transfer from vulnerable populations to institutional budgets is environmental injustice in action. | high |
| 03 | The enforcement system failed at every level. State regulators conducted no inspections for four years. Federal EPA inspectors arrived once and departed with a settlement that changes nothing. No one faced personal consequences despite executive-level involvement. | high |
| 04 | Healthcare institutions receive public trust and often public funding, yet this case shows they exploit the same regulatory weaknesses as any corporation. Hospitals will cut safety corners when the financial incentive exists and enforcement remains weak. | high |
| 05 | The $13,750 penalty sends a clear message to every hospital and healthcare facility in the region: hazardous waste violations carry no meaningful consequences. Expect similar cost-benefit analyses at institutions throughout Maryland and beyond. | high |
Timeline of Events
February 2020
UM BWMC notifies Maryland Department of Environment that facility is a large quantity generator of hazardous waste, triggering heightened regulatory requirements
February 6, 2024
EPA conducts Compliance Evaluation Inspection and discovers widespread violations of RCRA hazardous waste regulations throughout the facility
June 24, 2024
EPA sends formal notice to Maryland Department of Environment announcing intention to pursue enforcement action against the hospital
August 23, 2024
Hospital Senior Vice President John Greely signs Expedited Settlement Agreement accepting $13,750 penalty without admitting or denying specific violations
September 10, 2024
Regional Judicial Officer Joseph Lisa signs Final Order, officially closing the case and making the minimal settlement effective
Direct Quotes from the Legal Record
QUOTE 1
Operating without a permit
allegations
“On February 6, 2024, Respondent operated the Facility without a permit, in violation of COMAR 26.13.07.01A. The following acts or omissions prevented Respondent from meeting the regulatory permit exemption conditions set forth at COMAR 26.13.03.05E”
💡 The hospital violated the fundamental requirement to either obtain a permit or meet exemption conditions, making its entire hazardous waste operation illegal.
QUOTE 2
Unlabeled satellite containers
allegations
“On February 6, 2024, the EPA inspector observed containers marked with their contents as follows, the Gross Room (Formalin, 5gal), Pour Room (cardboard box ‘Methanol Waste’, 2.5gal), Hematology Room EL07 (Plastic container within a cardboard box ‘Methanol Waste’, 2.5gal) & Main Pharmacy Area (silver nitrate sticks, 5gal). Each of these containers were considered satellite accumulation areas by the Facility. The containers were not marked with the words ‘Hazardous Waste’.”
💡 Workers throughout the hospital handled dangerous chemicals in containers that failed to warn them of hazardous content, creating preventable exposure risks.
QUOTE 3
Open hazardous waste containers
health
“On February 6, 2024, the EPA inspector observed open containers in the following areas. The Pour Room hazardous waste accumulation area had an open funnel on top of a container marked ‘Hazardous Waste’ and ‘Xylene, Hematoxylin’. In the Pharmacy IV Prep room, an 18-gallon container labeled as hazardous waste was open. Room EL017 is a hazardous waste storage area that had an 18-gallon container, which had a split in its lid, labeled ‘Hazardous Waste’ and containing intravenous (IV) bags and tubing.”
💡 Open containers release toxic fumes into workplace air and create spill risks, directly exposing workers to chemicals that cause respiratory and neurological damage.
QUOTE 4
No weekly inspections conducted
allegations
“On February 6, 2024, the Facility stated that inspections of the hazardous waste accumulation areas in the Rooms NL-46 and EL-017, as described by the Facility, are not inspected weekly.”
💡 The hospital admitted it completely skipped required weekly safety inspections designed to catch leaks, spills, and container failures before they harm people.
QUOTE 5
No inspection documentation
allegations
“On February 6, 2024, the Facility stated inspections of the hazardous waste accumulation areas that are performed weekly are not documented.”
💡 Even where inspections allegedly occurred, the hospital kept no records, making it impossible to verify compliance or identify patterns of problems.
QUOTE 6
Deficient contingency plan
health
“On February 6, 2024, the inspector reviewed the Facility’s contingency plan and did not observe a list of the emergency coordinators and a list of the emergency equipment along with the location of the equipment”
💡 In a chemical emergency, responders would not know who to contact or where to find safety equipment, delaying life-saving response to worker exposures.
QUOTE 7
Training only every three years
workers
“On February 6, 2024, the Facility stated training for employees occurs every three years. Respondent failed to ensure employees take part in an annual review of initial training as required by COMAR 26.13.03.05E(1)(g).”
💡 Workers handled dangerous chemicals with knowledge that was up to three years out of date, unable to follow current safety procedures or recognize new hazards.
QUOTE 8
Job descriptions missing hazmat duties
workers
“On February 6, 2024, the job descriptions reviewed the by the inspector did not specify the duties of the employee as it relates to hazardous waste management.”
💡 Employees had no clear written guidance about their safety responsibilities, leaving them unable to refuse unsafe tasks or understand their authority.
QUOTE 9
No hazardous waste determination
allegations
“On February 6, 2024, the facility stated waste aerosol cans are discarded in regular trash. Respondent failed to make a hazardous waste determination as required by COMAR 26.13.03.02.A.(1)(a).”
💡 The hospital put potentially hazardous materials into regular trash without even checking if they posed dangers, endangering waste workers and the public.
QUOTE 10
Missing manifest signatures
accountability
“On February 6, 2024, the inspector reviewed the Facility’s uniform hazardous waste manifests and observed manifest #017744967FLE maintained by the Facility was not signed by the designated facility.”
💡 Incomplete manifests mean the hospital could not prove hazardous waste reached proper disposal facilities, potentially allowing illegal dumping.
QUOTE 11
Settlement amount
profit
“Complainant and Respondent agree that settlement of this matter for a total penalty of THIRTEEN THOUSAND SEVEN HUNDRED AND FIFTY DOLLARS ($13,750.00) is in the public interest.”
💡 This trivial penalty for four years of widespread violations proves that safety violations cost far less than actual compliance, incentivizing future misconduct.
QUOTE 12
Executive signature confirms leadership knowledge
accountability
“The undersigned representative certifies that she/he is fully authorized to execute this Agreement and to legally bind the University of Maryland Baltimore Washington Medical Center. [Signed by] John Greely, Senior Vice President & Chief Operating Officer”
💡 The hospital’s second-highest executive signed the settlement, proving top leadership knew of the violations yet faced no personal consequences.
QUOTE 13
Neither admits nor denies
accountability
“In signing this Agreement, Respondent: admits the jurisdictional allegations in this Agreement; neither admits nor denies the specific factual allegations in this Agreement, except as provided in the jurisdictional admission above”
💡 This standard legal language lets the hospital avoid publicly acknowledging its wrongdoing while still resolving the case.
QUOTE 14
Violations certified as corrected
accountability
“By its signature below, Respondent certifies, subject to civil and criminal penalties for making a false submission to the United States Government, that (1) the alleged violations have been corrected, and (2) any documentation or information provided to EPA was true and accurate.”
💡 The settlement requires only the hospital’s self-certification of corrective action, with no independent verification or ongoing monitoring to protect workers.
QUOTE 15
Hazardous wastes generated
health
“At all times relevant to the allegations described in this Agreement, Respondent generated and stored Xylene (D001), Ethanol (D001, F003), and Silver Nitrate (D001, D011), which are ‘hazardous waste(s)’ at the Facility”
💡 These chemicals cause serious health effects including neurological damage, respiratory harm, and chemical burns, making proper handling essential to worker safety.
Frequently Asked Questions
What exactly did the University of Maryland Baltimore Washington Medical Center do wrong?
The hospital systematically violated federal hazardous waste laws for at least four years. EPA inspectors found unlabeled containers of dangerous chemicals, open containers releasing toxic fumes, areas that received no safety inspections, employees who got training only once every three years instead of annually, and emergency plans missing critical information. The hospital essentially skipped basic safety requirements designed to protect workers and the community from exposure to hazardous chemicals.
How much did the hospital pay for these violations?
The hospital paid exactly $13,750 to settle all violations discovered during the four-year period. For context, this amount is roughly equivalent to one month’s salary for a single senior hospital executive, and represents a tiny fraction of what proper compliance would have cost during those four years. The penalty is so small that it actually incentivizes future violations rather than deterring them.
Were any workers actually harmed by these violations?
The settlement documents do not report specific injuries, but that misses the point. Workers throughout the hospital handled unlabeled containers of toxic chemicals, breathed fumes from open containers of xylene and other solvents, and worked in areas that received no safety inspections. These exposures create serious health risks including respiratory damage, neurological effects, and chemical burns. The absence of documented injuries reflects luck and worker resilience, not the hospital’s safety practices.
Why did it take four years for EPA to inspect this facility?
EPA and state environmental agencies have limited inspection resources and must oversee thousands of facilities. The hospital registered as a large quantity generator in February 2020, but EPA did not conduct a compliance inspection until February 2024. This gap reflects chronic underfunding of environmental enforcement and the practical reality that most facilities operate for years between inspections. Hospitals and other regulated entities know this and can calculate the low odds of getting caught.
What happened to the executives who allowed this to happen?
Nothing. Senior Vice President and Chief Operating Officer John Greely signed the settlement agreement, confirming that top hospital leadership knew about the violations. However, the settlement imposed no personal consequences for any executive or manager. No one was fired, fined individually, or held personally accountable. The hospital paid a small institutional fine and everyone involved kept their jobs and salaries.
Is the hospital required to make changes to prevent this from happening again?
The settlement requires the hospital to certify that violations have been corrected, but provides no specifics about what corrective actions were taken or how their effectiveness is verified. There is no independent monitor, no mandatory third-party audits, no public reporting of compliance status, and no enhanced oversight. The hospital essentially certified its own compliance and the case was closed. EPA retains the right to conduct future inspections, but those could be years away.
Can the hospital get in trouble for the same violations again?
Yes, technically the settlement only resolves the specific violations discovered during the February 2024 inspection. If EPA returns and finds the same problems, it could pursue new enforcement. However, the practical message sent by this settlement is clear: violations carry minimal financial consequences and no personal accountability. This creates an incentive structure where repeat violations make economic sense as long as the hospital believes another inspection is years away.
What chemicals were involved and why are they dangerous?
EPA found improper handling of xylene, ethanol, silver nitrate, formalin, and methanol. Xylene causes dizziness, headaches, and long-term neurological damage. Methanol and ethanol are highly flammable and toxic. Formalin is a carcinogen. Silver nitrate causes severe skin and eye burns. These are serious industrial chemicals that require proper labeling, closed containers, trained handling, and emergency preparedness. The hospital treated them casually, exposing workers to preventable risks.
Does this mean other hospitals are doing the same thing?
This case demonstrates that even major healthcare institutions will cut corners on environmental compliance when the financial incentive exists and enforcement is weak. There is no reason to believe UM Baltimore Washington Medical Center is unique. Hospitals throughout Maryland and across the country face the same cost pressures, the same infrequent inspections, and the same minimal penalties when caught. Expect similar violations at facilities that run the same cost-benefit calculations.
What can workers at this hospital do to protect themselves?
Workers who handle chemicals should demand proper training, refuse to work with unlabeled containers, insist on closed containers when not actively adding or removing waste, and report missing inspections or inadequate emergency plans. Federal and Maryland laws protect whistleblowers who report environmental violations. Workers can also contact EPA Region 3 directly or file anonymous complaints through the EPA tips and complaints system. Collective action through unions or employee groups is often most effective for forcing systemic changes.
What can community members do about this?
Community members can demand accountability from the University of Maryland Medical System board of directors, ask local media to investigate the settlement, contact Maryland state legislators to push for stronger healthcare facility oversight, and submit Freedom of Information Act requests for inspection records and compliance documents. Public pressure works when it is sustained and visible. Hospital administrators care deeply about institutional reputation, and negative publicity can drive reforms that small fines cannot.
💡 Explore Corporate Misconduct by Category
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- 💼 Labor Exploitation — Wage theft, worker abuse, and unsafe conditions.
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- 💵 Financial Fraud & Corruption — Lies, scams, and executive impunity.
