The Non-Financial Ledger

Think about what a hospital laboratory actually looks like on a slow Tuesday afternoon in December. Researchers are finishing up work before the holiday break. Technicians are processing tissue samples. Support staff are cleaning up. And somewhere in that building, at that exact moment, containers of xylene and formaldehyde — chemicals that can cause cancer, damage the nervous system, and trigger severe respiratory reactions — are sitting on shelves or lab benches with no labels. No warning. No required words that tell the next person who picks up the bottle exactly what they are holding and why it matters.

That is not a hypothetical. That is what EPA inspectors documented at the University of Kansas Medical Center on May 14 through 16, 2024.

Formaldehyde and formalin are used to preserve biological tissue. Xylene is a solvent used to process tissue samples for microscopy. Paraformaldehyde is a fixative. Acetone is a degreaser. These are not exotic chemicals locked in a vault somewhere. They are handled by lab techs, graduate students, maintenance workers, and cleaning staff. Some of those workers are young. Some may be pregnant. Some may have no idea that a container left on a bench without a hazardous waste label is, in fact, regulated toxic waste that requires specific handling, storage, and disposal.

Federal law exists precisely because of this reality. The required label “Hazardous Waste” is not a formality. It is the first and often only warning that tells a worker: do not pour this down the sink, do not move it without protection, this material has a documented path to proper disposal for a reason. Strip that label — or just never put it on — and you strip the worker of information they need to protect themselves.

The Medical Center also skipped its required weekly inspection of hazardous waste storage areas during the same week three consecutive years in a row. Those three December weeks are the holiday period. The implication is that when the institution went on break, the oversight went with it. For three straight years, no one walked through the hazardous waste storage area to check for leaks, overflows, damaged containers, or improper accumulation — all things the weekly inspection is designed to catch before they become a worker injury, a chemical spill, or a contamination event.

Then there are the fluorescent lamps. Ten containers holding approximately 150 lamps, all left open, all unlabeled. Fluorescent lamps contain mercury. Mercury is a potent neurotoxin. It is exactly the kind of material that demands closed, labeled storage because a cracked lamp in an open box is a mercury vapor release waiting to happen. The regulations around universal waste lamps exist because institutions have, historically, treated fluorescent bulbs like ordinary trash. The University of Kansas Medical Center was still doing exactly that in 2024.

The penalty settled all of it for $11,250. At a medical institution that runs on tens of millions of dollars in federal research grants and tuition revenue, that number is a rounding error. What it is not is accountability.

Legal Receipts: What the EPA Document Actually Says

Every violation listed below comes verbatim from EPA Docket No. RCRA-07-2025-0010, signed and filed March 17, 2025. This is not reporting. This is the institution’s own settlement agreement.

“The EPA determined that the respondent did not determine whether a box of fluorescent lamps, pails of paint, and lead acid batteries were hazardous waste.”

• This admits the Medical Center was storing lead acid batteries, paint, and fluorescent lamps without conducting the federally required waste determination. Under 40 C.F.R. § 262.11(a), a generator is legally required to know, before anything else happens, whether its waste is hazardous. KUMC skipped that first step entirely for these materials.
• Lead acid batteries and fluorescent lamps both contain regulated toxic materials. A failure to make the initial hazardous waste determination means there is no guarantee these items were disposed of properly at all.

“The EPA determined that the respondent did not mark the following satellite containers of hazardous waste with the words ‘hazardous waste’: a) 1-liter solvent b) 1-liter solvent c) 1-liter formalin d) 4-liters xylene e) 4-liters xylene f) 4-liters formaldehyde g) 3-liters acetone h) 4 liters acetone i) 4 liters xylene j) 4 liters formaldehyde k) approximately 500-ml xylene l) 1-liter xylene m) 100 ml oil Red O n) approximately 75-ml decalcification waste o) approximately 75-ml PFA waste p) 150-ml PFA waste q) 75-ml hematoxylin waste”

• That is 17 individual containers of hazardous chemical waste, including multiple carcinogens and neurotoxins, stored in active lab spaces without the legally required “Hazardous Waste” label. The regulation at K.A.R. 28-31-262(c)(7) is unambiguous: every satellite container must be marked.
• Xylene appears six separate times on this list. Xylene is classified as a hazardous air pollutant and can cause headaches, dizziness, liver damage, and central nervous system harm with repeated exposure. The people working near these unlabeled containers may not have known what they were breathing near.
• Paraformaldehyde (PFA) appears three times. PFA is a potent allergen and respiratory sensitizer. A worker with no label to warn them might handle the container without appropriate respiratory protection.

“The EPA determined that the respondent did not inspect the hazardous waste storage area during the weeks of 12/26/2021, 12/25/2022, and 12/24/2023.”

• The weekly inspection requirement under 40 C.F.R. § 265.174 exists to catch spills, leaking containers, and accumulation problems before they escalate. Three consecutive years of the same week going uninspected is a pattern, not an accident.
• The timing — the week of Christmas, every single year — points directly to the institutional practice of reducing staff and oversight during the holiday closure. Workers returning in January would have no documented record of what the storage area looked like before the break.

“The EPA determined that the respondent did not close ten containers holding approximately 150 universal waste lamps… [and] did not mark ten containers holding approximately 150 universal waste lamps with the words ‘Universal Waste – Lamps,’ or ‘Waste Lamps’ or ‘Used Lamps.'”

• Fluorescent lamps contain mercury. Open containers mean mercury vapor can escape into the surrounding air. The requirement under 40 C.F.R. § 273.13(d)(1) that containers remain closed is directly tied to preventing mercury exposure for anyone working in or near the storage area.
• The combined failure — open and unlabeled — means these containers were simultaneously a vapor exposure risk and an identification risk. Anyone who encountered them had no legal notice they contained regulated toxic waste.

“EPA has determined and Respondent agrees that settlement of this matter for a civil penalty of eleven thousand two hundred and fifty dollars ($11,250) is in the public interest.”

• This language means both parties signed off on this number as adequate. No independent public health body reviewed whether $11,250 reflects the actual risk exposure created by these violations over the period they persisted.
• The settlement explicitly states the fine resolves only federal civil penalty liability for the violations alleged herein. The EPA reserves the right to act on any other past, present, or future violations — meaning the $11,250 is a floor, not a full accounting.

Societal Impact Mapping

Environmental Degradation

Improper hazardous waste handling at a medical institution does not stay inside the building. The violations documented here each represent a pathway for regulated toxic materials to enter the broader environment.

• Fluorescent lamps stored in open, unlabeled containers are at high risk of breakage. A broken fluorescent lamp releases mercury vapor directly into the air and mercury particulate onto surfaces. Mercury does not biodegrade. It accumulates in ecosystems and in human tissue, particularly affecting the nervous system and kidneys.
• Used oil stored in an unlabeled 15-gallon container raises the risk that the material is misidentified and disposed of incorrectly. Used oil can contain heavy metals and hazardous chemical residues from engine or machinery use. One gallon of used oil can contaminate one million gallons of drinking water if it reaches a waterway.
• Xylene, formaldehyde, and acetone are volatile organic compounds (VOCs). Open or improperly sealed containers in a lab setting release vapors into indoor air, which then exhausts into the surrounding environment. All three are regulated air pollutants under federal and Kansas state law.
• Lead acid batteries left without a waste determination have no documented disposal path. Lead is a persistent environmental contaminant. If treated as ordinary trash and sent to a municipal landfill, lead from battery acid can leach into groundwater serving the Kansas City, Kansas community.

Public Health

The workers and students inside the KUMC facility face the most direct exposure risk. The facility is an active medical campus with lab technicians, researchers, graduate students, custodial staff, and maintenance personnel moving through these spaces daily.

• Formaldehyde is classified as a known human carcinogen by the International Agency for Research on Cancer. Workers in labs where formaldehyde containers are unlabeled and one confirmed container was left open face chronic low-dose inhalation exposure that may not be tracked or recognized.
• Xylene exposure at chronic low doses causes headaches, dizziness, impaired coordination, memory loss, and liver and kidney damage. With six separate unlabeled xylene containers documented, workers had no material cue to trigger protective measures or report exposure incidents.
• Paraformaldehyde is a respiratory sensitizer. Workers who develop PFA sensitization can experience asthma-like symptoms for the rest of their lives after a single high-dose exposure. Three PFA containers were found without required labeling.
• The open formalin container represents an active inhalation risk. Formalin is a solution of formaldehyde in water. An unsealed 1-liter container in a lab room continuously off-gasses formaldehyde vapor into the breathing zone of anyone working nearby.
• Mercury vapor from open fluorescent lamp storage is invisible, odorless at low concentrations, and acutely toxic to the kidneys and central nervous system. The ten open containers holding approximately 150 lamps were found during a formal inspection. The question of how long they were open before that inspection is unanswered in the document.
• Custodial and maintenance workers are at particular risk in these scenarios. They enter spaces to clean and repair, often without advance knowledge of what chemicals are present. An unlabeled container provides them no protection.

Economic Inequality

The financial structure of this settlement makes the power imbalance visible. The people most exposed to harm are the least compensated. The institution paid a fine that represents a fraction of a fraction of its operating budget.

• The $11,250 fine was assessed against a major academic medical center operating in a major metropolitan area with significant federal funding. This is not a small business. The fine does not scale to the institution’s resources or to the duration of the violations.
• The workers most at risk from unlabeled hazardous waste in medical labs are overwhelmingly lower-wage employees: lab technicians, custodial staff, and facilities workers. They are the least positioned to advocate for safe conditions or to pursue independent legal action if harmed.
• The settlement includes a provision that the fine is not tax-deductible, which is standard. It does not include any community remediation fund, enhanced monitoring, worker notification requirement, or compensation mechanism for anyone who may have been exposed during the violation period.
• The document confirms the violations have been corrected and that KUMC certified compliance. There is no independent verification mechanism built into the settlement. The institution self-certifies under penalty of making a false submission to the federal government — a deterrent that relies entirely on institutional honesty going forward.

The Cost of a Life Metric

What Now?

This case closed with a fine that the institution can absorb without consequence. The people positioned to push for real accountability are regulators, workers, and the public — and each has a specific lever to pull.

Who Is Accountable at KUMC

• The settlement was signed on behalf of KUMC by Ryan Lickteig, Director of Environmental Health and Safety, whose email (RLICKTEIG@KUMC.EDU) is the designated contact. He is the institutional official responsible for the compliance program that produced these violations.
• The EPA approved the settlement through David Cozad, Director, Enforcement and Compliance Assurance Division, EPA Region 7, and attorney Christopher Muehlberger, Office of Regional Counsel.
• The Final Order was signed by Karina Borromeo, Regional Judicial Officer, and entered into record March 17, 2025.

Watchlist: Who Has Ongoing Jurisdiction

• EPA Region 7: Holds RCRA enforcement authority over KUMC. The settlement explicitly reserves EPA’s right to pursue any other past, present, or future violations. Workers or community members can submit tips to EPA Region 7’s enforcement line.
• Kansas Department of Health and Environment (KDHE): Was notified of this settlement as required. KDHE’s Bureau of Waste Management (Director: Julie Coleman) and Compliance and Enforcement Section (Jeff Walker) both received the final order. KDHE has parallel state enforcement authority under Kansas hazardous waste rules.
• OSHA: Federal OSHA has jurisdiction over worker exposure to hazardous chemicals in laboratory settings under the Hazard Communication Standard and the Laboratory Standard (29 C.F.R. § 1910.1450). The violations documented here are directly relevant to worker right-to-know and exposure protection obligations that OSHA enforces independently of EPA.

What You Can Do

• If you work at KUMC or any research institution and have observed unlabeled chemical waste, open hazardous containers, or missed inspections: you can file a confidential report with EPA Region 7 at (913) 551-7003 or submit an anonymous tip through the EPA’s online reporting portal. Retaliation against workers who report environmental violations is prohibited under RCRA’s whistleblower provisions.
• Contact KDHE’s Bureau of Waste Management directly (julie.coleman@ks.gov) to request public records on any follow-up inspection or compliance verification at KUMC. You have the right to that information under Kansas open records law.
• Connect with local environmental justice organizations in the Kansas City metro area that monitor industrial and institutional chemical compliance. Groups doing this work are your most effective local watchdogs for holding institutions like KUMC to standards their $11,250 fines clearly do not enforce on their own.
• If you are a KUMC employee, graduate student, or contractor who believes you were exposed to unlabeled hazardous chemicals without proper warning during the period covered by these violations, consult an occupational health attorney. The EPA settlement does not extinguish private civil rights or workers’ compensation claims.