The Non-Financial Ledger: What Numbers Don’t Capture

Think about what a hospital is supposed to be. It is the place you go when your body is failing you. You are already scared. You are already vulnerable. The people inside that building, the nurses, the pharmacy techs, the lab workers, the maintenance crew, signed up to help. They did not sign up to work next to open containers of Xylene leaking fumes in a room with no documented emergency exit plan.

Xylene is a solvent. Breathing it causes headaches, dizziness, and nausea. Prolonged or high-level exposure can damage your nervous system and your liver. It is exactly the kind of chemical that requires a closed container, a labeled container, a monitored container, and trained workers who know exactly what to do if it spills. At UMBWMC on February 6, 2024, it had an open funnel sitting on top of it. In the Pour Room. In a hospital.

The people most at risk from these failures are not executives. They are the lab technicians who work in the Gross Room where Formalin sat in an unmarked container. They are the pharmacy staff who walked past an open 18-gallon drum of hazardous waste in the IV Prep Room every single shift. They are the maintenance workers in the Annex who handled used fluorescent lamps containing heavy metals without a single label telling them those lamps were hazardous waste.

These workers trusted that their employer had followed the rules. That trust was misplaced. The hospital itself acknowledged that inspections of certain hazardous waste storage rooms were not being done weekly as required, and that the inspections that were being done were not written down anywhere. There was no paper trail. No accountability. Just the assumption that everything was fine, enforced by silence.

The training failure is the one that should stay with you. Federal law requires annual hazardous waste training refreshers. UMBWMC was doing it every three years. That means for two out of every three years, the people handling these chemicals were working on outdated knowledge, with no documented job duties telling them what their responsibilities even were. If something had gone wrong, there would have been no clear chain of accountability, because the accountability chain was never built.

Patients in that building were receiving IV treatments in a room where a cracked-lid container of hazardous waste sat unsecured. They did not know that. They were not told. They were lying in beds, trusting the institution around them, while the institution was throwing aerosol waste cans into regular trash and calling it a day.

The $13,750 fine does not compensate a single worker for a single headache. It does not restore the dignity of employees who deserved better training and clearer instructions. It does not account for every bag of trash that left that building containing materials that should have gone through regulated hazardous disposal. The ledger the EPA produced measures violations. This ledger measures something else.

Legal Receipts: What the EPA Document Actually Says

These are the verbatim findings from EPA Docket No. RCRA-03-2024-0118, filed September 10, 2024. Every quote below is lifted directly from the settlement agreement signed by UMBWMC’s Senior Vice President and Chief Operating Officer, John Greely.

“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) and 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’.”

EPA Docket RCRA-03-2024-0118, Paragraph 10(a)(1)

“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.”

EPA Docket RCRA-03-2024-0118, Paragraph 10(a)(3)

“On February 6, 2024, the Facility stated that 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).”

EPA Docket RCRA-03-2024-0118, Paragraph 10(b)

“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).”

EPA Docket RCRA-03-2024-0118, Paragraph 10(a)(7)

“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, as required by COMAR 26.13.05.04C.”

EPA Docket RCRA-03-2024-0118, Paragraph 10(g)

“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.”

EPA Docket RCRA-03-2024-0118, Paragraph 11

Societal Impact Mapping: Who Actually Bears the Cost

Public Health

Every failure in the EPA document maps directly to a potential exposure pathway for real people inside and around this hospital.

• Open containers of Xylene in the Pour Room create inhalation hazards for lab technicians and anyone passing through that area. Xylene vapor causes central nervous system effects including headaches, dizziness, and impaired coordination, and chronic exposure is associated with liver and kidney damage.
• Formalin, stored in an unlabeled 5-gallon container in the Gross Room (where tissue samples are processed), is a known human carcinogen per the International Agency for Research on Cancer. Workers in that room had no label warning them of its hazardous classification.
• An open 18-gallon hazardous waste container in the Pharmacy IV Prep Room, where medications are prepared for injection into patients, represents a contamination vector that could affect medication integrity and patient safety.
• Used fluorescent lamps in the maintenance Annex contain mercury. Workers handling these lamps without hazardous waste labeling or training have no mechanism to understand the neurological risks of mercury exposure or to handle breakage correctly.
• Aerosol cans disposed of in regular trash can be crushed or incinerated in municipal systems without controls designed for flammable or chemically reactive waste, creating exposure risks for sanitation workers and communities near disposal facilities.
• The absence of an annual training program means that for two years out of every three, staff handling these chemicals were working without the most current knowledge of regulatory standards or response protocols, compounding every other risk listed here.

Economic Inequality

The financial structure of this enforcement action transfers the full cost of the hospital’s non-compliance onto the public while protecting institutional wealth.

• A $13,750 fine against a hospital that is part of the University of Maryland Medical System, one of Maryland’s largest healthcare organizations, is economically meaningless as a deterrent. The fine does not scale to the institution’s operational capacity or the revenue it generates.
• The workers most exposed to these chemicals, lab techs, pharmacy staff, maintenance workers, are typically among the lower-paid employees in a hospital system. They bore the physical risk of the violations and received nothing from the settlement.
• Regulated hazardous waste disposal has a cost. By throwing aerosol cans in regular trash, the hospital offloaded that disposal cost onto the public waste system, meaning taxpayers and municipal systems absorbed the cost the hospital avoided.
• Under the settlement terms, UMBWMC cannot deduct the civil penalty as a federal tax expense. That provision, while standard, does not change the fact that $13,750 does not functionally deter a healthcare institution operating at scale.
• Communities near municipal waste facilities in Anne Arundel County, which skews lower-income compared to wealthier Baltimore suburbs, are the downstream recipients of improperly disposed hazardous waste from facilities like UMBWMC. They bear environmental and health costs they did not choose and were not compensated for.
• The “neither admits nor denies” settlement structure ensures that UMBWMC carries no formal liability beyond the fine, eliminating any pathway for affected workers to use this enforcement action as the basis for workplace safety claims.

The “Cost of a Violation” Metric

What Now? The Resistance and the Watchlist

This enforcement action is closed. The fine is paid. But the systems that made these violations possible, and the penalties too small to matter, are still operating. Here is who is watching and where pressure can be applied.

Accountability at UMBWMC

The settlement document names the following individuals as the institution’s authorized representatives:

• John Greely, Senior Vice President and Chief Operating Officer, University of Maryland Baltimore Washington Medical Center. He signed the settlement agreement on behalf of the institution.
• Kristin H. Feliciano, Senior Vice President, Strategy and Program Development, UMBWMC. She was served a copy of the final order by the Regional Hearing Clerk.

These are the executives who run the operational side of this hospital. They are the appropriate contacts for public accountability regarding workplace safety and environmental compliance.

Regulatory Watchlist

• The U.S. Environmental Protection Agency, Region 3 (Philadelphia) has jurisdiction over this facility. EPA compliance officer Stephen Forostiak is the named enforcement contact for Docket RCRA-03-2024-0118. EPA Region 3 can be contacted to report new or ongoing hazardous waste violations.
• The Maryland Department of the Environment (MDE) administers the federally authorized hazardous waste program for the state. MDE received prior notice of this enforcement action and has concurrent authority over UMBWMC’s RCRA compliance. Maryland residents can file complaints directly with MDE’s Land and Materials Administration.
• The Occupational Safety and Health Administration (OSHA) has authority over workplace chemical exposure standards independent of RCRA. Workers who believe they were exposed to unlabeled or improperly stored hazardous chemicals can file a complaint with OSHA Region 3 without fear of retaliation under Section 11(c) of the OSH Act.
• The Joint Commission accredits UMBWMC as a hospital. Environmental safety failures that affect patient or staff safety can be reported to The Joint Commission’s Office of Quality and Patient Safety, which accepts anonymous complaints.

Mutual Aid and Grassroots Resistance

• If you are a healthcare worker in Maryland, connect with your union or, if unrepresented, with the Maryland State and DC AFL-CIO. Collective bargaining agreements can mandate hazardous waste training standards above the regulatory minimum and create enforceable grievance processes for safety violations.
• Anne Arundel County residents near Glen Burnie can contact their County Council representative to ask whether the county’s environmental health office conducts independent monitoring of medical facility waste disposal near residential areas and municipal waste streams.
• Push Maryland legislators to introduce or support legislation increasing the minimum penalty floor for RCRA violations at Large Quantity Generator facilities operating inside populated areas. $13,750 for 11 violations at a hospital is a policy choice. It can be changed.
• Share this enforcement document. Public federal records have no copyright. Screenshot Paragraph 11. Post it. The full docket number is RCRA-03-2024-0118 and it is searchable in the EPA’s public enforcement database. Sunlight is the oldest disinfectant.