A prestigious Philadelphia hospital stored a container of hazardous pharmaceutical waste for 718 consecutive days — more than eight times longer than federal law allows — while patients and staff moved through the same building every single day.
A Hospital That Played By Its Own Rules on Toxic Waste
Thomas Jefferson University Hospital operates across multiple addresses in central Philadelphia. According to the EPA’s enforcement document, the hospital runs facilities at 900 Walnut Street, 1020 Locust Street, and 111 S. 11th Street — all within blocks of each other, all in the dense urban core of one of America’s most populated cities.
On March 8, 2023, EPA inspectors conducted what is called a Compliance Evaluation Inspection across these facilities. What they found was a pattern of violations — seven separate counts in total — that paint a picture of a hospital that had normalized illegal hazardous waste handling as routine operating procedure.
The violations were not minor paperwork errors. They included physical evidence of a chemical spill already visible on the floor of a clinical lab, containers of toxic waste with their lids wide open, mercury-containing medical equipment sitting loose and uncontained on a shelf, and a storage room so cluttered that EPA inspectors could not even read the labels on the containers inside it.
Timeline of Key Violations — Thomas Jefferson University Hospital
Seven Counts of Violations. One Hospital. One City.
The EPA charged Thomas Jefferson University Hospital with seven separate counts under the Resource Conservation and Recovery Act (RCRA) — the federal law that governs how hazardous waste must be stored, tracked, and disposed of. These counts cover: operating a hazardous waste storage facility without a permit; failing to keep containers closed; failing to maintain training records for emergency coordinators; failing to properly operate the facility to prevent releases; failing to maintain clear aisle space for emergency access; failing to complete shipping manifests correctly; and mishandling universal waste including fluorescent lamps, mercury-containing equipment, and batteries.
Each of these violations existed simultaneously across multiple buildings in downtown Philadelphia. This was a system-wide failure, not an isolated incident in a forgotten corner of one campus.
What Money Can’t Measure: The Human Cost of “Routine” Toxic Negligence
There is a reason hazardous waste laws exist. They exist because chemicals like D001 — the EPA designation for ignitable hazardous waste, the category covering flammable pharmaceutical solvents — can cause serious harm to human health when they leak into the air, soak into floors, or migrate through drainage systems. Pharmaceutical hazardous waste includes substances that can irritate the skin and respiratory system on contact. The workers in the labs, hallways, and storage rooms where these open containers sat were never told that the lids were off. They were never given a choice.
The inspection also identified F003 waste — a category that includes solvents such as xylene and acetone — sitting in open 10-gallon containers in the Histology Laboratory (Room P420 in the Foerderer Pavilion Building) and in Room 2290B of the Gibbon East Building. Histology labs are spaces where technicians process tissue samples, often for cancer diagnosis. These are not warehouse workers trained for chemical exposure. These are laboratory professionals and clinical staff who came to work at a hospital believing their employer was following the law.
“Inspectors observed blue staining on a container in storage holding D001 hazardous waste, and blue staining on the spill pallet and on the floor.”
The chemical spill documented in Room P307 of the Foerderer Pavilion Building was not a future risk. It was a present reality on the day of the inspection. The spill had already happened. Blue staining appeared on the container, the spill pallet, and the floor. Someone worked in that room after that spill occurred. Someone cleaned around it, stepped over it, or simply never noticed it because it had been there long enough to be treated as normal. That is what institutional negligence produces: a slow normalization of danger until danger becomes furniture.
The blocked aisle space documented at the Walnut Street Facility, Room 185A deserves its own reckoning. Federal law requires that emergency personnel, fire suppression equipment, and decontamination gear must be able to move freely through any hazardous waste storage area without obstruction. The EPA’s inspection found containers stacked so densely that inspectors themselves could not read the labels on the containers inside. In a real fire or a real spill emergency, first responders would have been unable to navigate that room. The people most at risk in that scenario would not be executives. They would be the workers already inside the building.
Straight From the Document: The Words They Signed Their Names To
The following are direct, verbatim quotations and factual findings from the EPA’s Consent Agreement and Final Order. Thomas Jefferson University Hospital signed this document. These are the facts they agreed not to contest.
“From at least March 20, 2021 until March 17, 2023, Respondent stored a 5-gallon pail of pharmaceutical hazardous waste (D001) in the hazardous accumulation area in the Walnut Street Facility, Room 185A, for a total accumulation time of 718 days, which is in excess of the 90 day and 180 day accumulation time limits allowed.”
EPA Consent Agreement, Count 1(a) — Accumulation of Hazardous Waste for Greater than 90 and 180 Days
“During the Inspection on March 8, 2023, EPA inspectors observed, in the clinical lab in room P307 of the Foerderer Pavilion Building at the 1020 Locust Facility, under a counter, on a spill pallet, blue staining on a container in storage holding D001 hazardous waste, and blue staining on the spill pallet and on the floor.”
EPA Consent Agreement, Count 4 — Failure to Maintain and Operate a Facility
“During the March 8, 2023 Inspection of the hazardous waste accumulation area in Room 185A of the Walnut Street Facility, containers were stacked in a manner which prevented the inspectors from being able to view the containers and their labels to discern the contents of the containers.”
EPA Consent Agreement, Count 5 — Failure to Maintain Aisle Space
“In the Histology Laboratory (Room P420) located in the Foerderer Pavillion Building (125 S. 11th Street Facility), the inspectors observed multiple open plastic 10-gallon containers of D001 and F003 hazardous waste.”
EPA Consent Agreement, Count 2 — Failure to Keep Containers of Hazardous Waste Closed
“Respondent did not have the hazardous waste training records for the employees listed as the primary and secondary emergency coordinators at the 1020 Locust Facility.”
EPA Consent Agreement, Count 3 — Failure to Maintain Records of Hazardous Waste Training
“Respondent’s hazardous waste manifests did not have a generator RCRA ID number associated with the following seven shipments of hazardous waste sent for offsite treatment, storage, or disposal.”
EPA Consent Agreement, Count 6 — Failure to Properly Complete Uniform Hazardous Waste Manifests
This Isn’t Just a Paperwork Problem: Real Stakes for a Real City
Environmental Degradation: When Toxic Waste Becomes Somebody Else’s Problem
The EPA’s enforcement framework under RCRA exists for a specific reason: hazardous waste that is improperly stored, labeled, or shipped does not stay in the room where it was left. D001 ignitable waste and F003 solvents can volatilize into the air. They can leach into drainage systems. In a dense urban environment like central Philadelphia — where the three TJUH facilities sit within blocks of each other, surrounded by residential neighborhoods, schools, and other hospitals — the potential radius of exposure from a spill or fire is not limited to the hospital’s square footage.
The seven manifests sent without proper RCRA ID numbers represent seven loads of hazardous material that moved through Philadelphia’s streets and waste-management infrastructure without a proper accountability trail. RCRA manifest requirements exist so that regulators can trace hazardous waste from the point of generation to its final disposal. When a hospital strips its identifying information from those manifests, it breaks the chain of custody. Nobody can verify where that waste actually ended up.
The documented spill in Room P307 — blue staining on the container, the spill pallet, and the floor — is physical evidence that a containment failure had already occurred before the inspection date. The law requires facilities to be operated to “minimize the possibility of any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water.” That standard was not met. A release had happened. It stained the floor.
“Seven loads of hazardous material moved through Philadelphia’s streets without a proper accountability trail. Nobody can verify where that waste ended up.”
Public Health: Patients and Workers in a Building Full of Open Toxic Containers
The specific waste types documented in this case are not benign. D001 is the EPA’s hazardous waste code for ignitable materials — substances that can catch fire at low temperatures or generate fumes. F003 is the code for spent non-halogenated solvents including xylene, acetone, ethyl acetate, ethyl benzene, and cyclohexane. These are chemicals with known health effects: xylene exposure causes headaches, dizziness, confusion, and in high concentrations, damage to the central nervous system. Acetone, while common, irritates mucous membranes. In an enclosed laboratory or storage room with poor ventilation, open 10-gallon containers of these substances are a chronic inhalation risk.
The Histology Laboratory where open containers were found is a working clinical space. Histology technicians perform specialized, precision work: slicing tissue samples thin enough to mount on microscope slides, staining them with chemical dyes, and preparing them for pathologists to read. They lean over benches. They work in close proximity to the surfaces and the air. The finding that “multiple open plastic 10-gallon containers” of D001 and F003 hazardous waste were present in that room on the inspection date is a direct health finding, not a regulatory abstraction.
The mercury-containing equipment found loose on a shelf at the 1020 Locust Street facility presents a distinct hazard. Mercury is a potent neurotoxin. Regulations require it to be containerized precisely because loose or broken mercury-containing devices can release mercury vapor into the surrounding air. The hospital stored these devices uncontained on an open shelf in the same area where other hazardous waste was accumulating. The emergency coordinators for that facility — the people designated by law to respond if something went wrong — did not even have documented training records on file.
Economic Inequality: Who Bears the Risk When a Hospital Cuts Corners
Thomas Jefferson University Hospital is not a struggling community clinic operating on bare-bones resources. It is a major academic medical center in Philadelphia, part of the Jefferson Health system. The violations documented in this case were not the result of resource scarcity. They were the result of institutional indifference. The cost of proper labeling, container closure, and annual training documentation is negligible compared to the operational budget of a hospital system of this size. These rules were not burdensome. They were simply ignored.
The penalty — $107,535 ($107,535, roughly what two full-time American workers earning median wages bring home in a combined year) — is, in the context of a major health system, a rounding error. It does not compensate the workers who breathed fumes from open solvent containers. It does not remediate any contamination that may have migrated from improperly stored waste. It does not restore any trust that patients and staff placed in the institution. The fine is the floor of accountability, not the ceiling — and it is a very low floor.
The communities immediately surrounding Thomas Jefferson University Hospital’s campuses on Walnut Street, Locust Street, and South 11th Street in Center City Philadelphia are mixed-income urban neighborhoods. Hospital workers — the technicians, custodians, and support staff most likely to move through storage rooms and lab spaces on a daily basis — are disproportionately lower-wage workers. They are the people who had no idea that their employer was stockpiling pharmaceutical hazardous waste for 718 days, that chemical spills were staining lab floors, or that the person designated to coordinate their emergency response had no documented training for the job.
What They Paid to Settle. What It Actually Means.
Please click on this link on the EPA’s website for a copy of the above PDF: https://yosemite.epa.gov/oa/rhc/epaadmin.nsf/Filings/40B5EB02F45977E585258C9D006F0046/$File/Thomas%20Jefferson%20University%20Hospital_RCRA%20CAFO_June%202%202025.pdf
Explore by category
Product Safety Violations
When companies sell dangerous goods, consumers pay the price.
View Cases →Financial Fraud & Corruption
Lies, scams, and executive impunity that distort markets.
View Cases →
