Hospitals occupy a rarefied space in society. They are sanctuaries where lives are saved, and medical professionals work tirelessly to advance the well-being of patients. The concept of corporate misconduct within a hospital setting initially seems antithetical to the mission of healing. Yet, as the University of Maryland Baltimore Washington Medical Center scandal demonstrates, corporate ethics and corporate accountability issues can arise anywhere that neoliberal capitalism imposes bottom-line thinking.

At the heart of this story is a set of legal documents from the U.S. Environmental Protection Agency (EPA) detailing how UM BWMC systematically violated hazardous waste disposal regulations. This includes open containers of flammable solvents, unlabeled containers of potentially toxic chemicals, inadequate training for employees handling dangerous materials, and incomplete contingency plans for emergencies. To the uninitiated, these might seem like administrative slip-ups—perhaps scattered oversight in the hustle of patient care. But in the broad context of economic fallout, systemic deregulation, regulatory capture, and the incentives that drive corporate behavior in the healthcare sector, these issues reveal a deeper pattern of corporate greed and corporate corruption.

This article meticulously dissects that pattern: how it was enabled by the “corporate playbook” of delay and minimal compliance, why regulators did not step in sooner, and how the subsequent settlement not only fails to deter future abuses but exemplifies the structural flaws embedded in neoliberal capitalism. By weaving in parallels from other high-profile corporate scandals, we see that the same dynamic—crime pays—applies whether one is dealing with an oil giant polluting the Gulf of Mexico or a hospital disregarding RCRA requirements.

Why This Story Matters

Beyond the immediate concern for worker safety and environmental well-being, this case underscores the difficulty of enforcing corporate social responsibility in institutions vital to public health. Because hospitals are typically viewed as community pillars, we risk ignoring or rationalizing their failures of compliance. Yet such failures can lead to serious health and environmental consequences, from chemical exposure in staff to potential contamination of local ecosystems if waste is not safely contained.

Moreover, the story of a hospital engaged in such violations challenges the narrow perspective that “healthcare = benevolence.” It unravels the ways in which market pressures, executive priorities, and underfunded or captured regulators converge to produce real, tangible harm.

Corporate Intent Exposed

When the EPA inspectors arrived in February 2024, they found a system that can only be described as deliberately mismanaged. Multiple unlabeled containers of hazardous chemicals, left open, were discovered in areas accessible to employees. This is not the ephemeral oversight of a single day; such mismanagement is typically the result of months—if not years—of normalized disregard.

While the settlement agreement does not include an explicit internal memo reading “We can save money by ignoring these rules,” the chain of facts strongly implies a cost-benefit calculation. The Hospital had:

• Known of its status as an LQG since 2020.
• A standard set of well-publicized, well-known rules to follow regarding labeling, training, and inspection of containers.
• Sufficient administrative infrastructure to ensure compliance, given it is part of a large medical system.

And yet, these rules were systematically broken. The only logical conclusion is that the potential cost of non-compliance (occasional inspections, sporadic fines) was judged to be lower than the cost of compliance (annual training, rigorous labeling, frequent audits).

Indeed, the settlement references how the Hospital paid $13,750 to resolve these violations. For a major medical center, this is a negligible sum—comparable to the cost of a single top executive’s monthly compensation package or the margin on a handful of specialized surgeries. Put bluntly, it was cheaper for the Hospital to risk harming workers and the environment than to ensure robust compliance.

In the realm of corporate accountability, this is a textbook example of an institution weighting immediate financial convenience over its ethical and legal duties. For a facility that presumably invests tens of millions in advanced medical equipment, fulfilling basic EPA requirements for labeling and container management should not represent an insurmountable challenge.

Bullet Summary Revisited

• Key Violation: Repeated contravention of RCRA Subtitle C hazardous waste regulations.
• Scale of Harm: Potentially endangering staff, patients, and the local environment; the scale is unquantified, but the risk is evidently significant.
• Broader Implication: Under neoliberal capitalism, such corporate cost-cutting thrives when regulators lack resources to enforce laws vigorously, and legal or political structures favor corporate interests.

The Corporate Playbook / How They Got Away With It

Detailed Timeline

1. Pre-2020: While we only have partial data before 2020, it is likely that some form of mismanagement preceded the official LQG designation. Often, organizations incorrectly categorize waste or operate under the threshold to avoid robust regulation.
2. February 13, 2020: UM BWMC notifies the state of Maryland about its LQG status. This notification triggers heightened regulatory expectations.
3. February 6, 2024: EPA inspectors arrive for a Compliance Evaluation Inspection (CEI). They find widespread infractions. Significantly, this means the Hospital operated for nearly four years under the LQG status with subpar compliance.
4. June 24, 2024: The EPA notifies the MDE of its intention to pursue enforcement action, culminating in the expedited settlement that year.

Executives and Department Roles

• John Greely, Senior Vice President & Chief Operating Officer: Signed the settlement, indicating a direct line of authority to the compliance processes at UM BWMC.
• Kristin H. Feliciano, Senior Vice President, Strategy & Program Development: Listed as a key contact. Her role might include aligning hospital strategy with legislative or regulatory frameworks, though the settlement does not provide details.

Given these positions, it is unlikely that the hospital’s hazardous waste mismanagement was unknown to top-level administration. Indeed, large institutions typically hold monthly or quarterly compliance reviews, especially in regulated areas like hazardous waste.

Ethical Violations

Ethics in a healthcare setting are typically outlined by missions that emphasize care, safety, and community well-being. Violations of RCRA, while seemingly “technical,” strike at the heart of these ethical commitments. Each open container of xylene or unlabeled box of methanol waste is a potential hazard for employees, who might inhale fumes or inadvertently mishandle flammable chemicals.

From a corporate social responsibility standpoint, even a single oversight that jeopardizes worker health contravenes standard CSR principles. Repeated and systemic oversights intensify the breach. The hospital’s approach was not just a one-off: it was embedded in daily operations for years.

Tactics to Evade or Delay Enforcement

While the settlement document does not detail all the legal arguments UM BWMC might have made, it is standard corporate procedure to:

1. Argue that “no actual harm” occurred, even if the potential risk was enormous.
2. Frame violations as “clerical” or “administrative,” minimizing their seriousness.
3. Offer partial solutions to pass immediate re-inspection without ensuring holistic reforms.
4. Rely on the slow churn of the regulatory process, knowing that agencies can only inspect a fraction of facilities each year.

Hospitals, like other large corporations, often operate with in-house legal teams, external counsel, and a compliance division that can strategically parse regulations, reducing the chance of immediate detection or ensuring minimal penalties once discovered.

Crime Pays / The Corporate Profit Equation

Cost Savings vs. Fines

Consider a hypothetical budget scenario for a hospital of UM BWMC’s size:

• Annual Training: If each staff member who handles hazardous waste requires, say, 4 hours of dedicated training, and you have 200 relevant employees, that’s 800 staff hours. Multiply that by an average wage plus overhead, then add the cost of training materials or external trainers, and you might easily reach tens of thousands of dollars per year.
• Proper Labeling and Container Management: This might include specialized equipment (closed funnel systems, lockable waste containers), routine monitoring, and consistent disposal scheduling with a licensed vendor. Over months and years, corners cut here can save thousands of dollars.
• Documentation: Keeping thorough logs of weekly inspections, job descriptions, universal waste start dates, and so forth requires dedicated staff time or specialized software.

Now weigh these ongoing costs against a $13,750 penalty. If the hospital avoided a combined $50,000 or more in compliance costs over a few years, the math is clear: it was financially advantageous to run the risk of a fine.

Stockholder or Stakeholder Rewards

As part of the University of Maryland Medical System, UM BWMC might not issue traditional stocks and dividends, but the institutional leadership can still benefit from cost savings:

1. Executive Compensation: Top executives often receive bonuses tied to the hospital’s financial performance. Minimizing compliance expenditures can bolster net operating margins.
2. Capital Projects: Freed funds can be diverted to expansions, new marketing campaigns, or technology investments that enhance the institution’s prestige.
3. Perceived Efficiency: In internal or board-level communications, a department that keeps operational costs down might be lauded, ignoring the possibility that those cost savings came from ignoring regulations.

Through these mechanisms, skipping environmental compliance fosters a culture in which staff are rewarded for “making numbers work,” even if that means turning a blind eye to potential hazards.

System Failure / Why Regulators Did Nothing

Budget Constraints on Regulators

The Resource Conservation and Recovery Act enforcement branch at the EPA, like many agencies, has faced budgetary pressures. Each region is responsible for overseeing thousands of facilities, from chemical plants to waste handlers, and yes, hospitals. Federal allocations to environmental enforcement often fluctuate with political cycles, with certain administrations prioritizing deregulation and corporate-friendly policies.

Maryland Department of the Environment (MDE) similarly wrestles with limited staff. Coupled with the healthcare sector’s political clout—health systems are often major employers and philanthropic donors—there is a disincentive to aggressively penalize or publicize hospital infractions. This dynamic is a textbook case of regulatory capture, where the entity being regulated influences or co-opts the regulatory agency designed to oversee it.

Judicial Deference and the Revolving Door

• Judicial Deference: Courts frequently require regulators to prove “significant harm” or “gross negligence” to impose high penalties, allowing hospitals to downplay the “potential” hazards of open chemical containers if no immediate injuries occurred.
• Revolving Door: A potential scenario in which individuals move between compliance or oversight roles in the healthcare industry and positions within the regulatory agencies. Such relationships can undermine rigorous enforcement, as personal connections or future job prospects shape decisions.

These systemic forces interact to produce the ultimate outcome: a minimal fine and a quietly signed settlement. The hospital can then proceed with business as usual.

This Pattern of Predation Is a Feature, Not a Bug

A Normalized Culture of Non-Compliance

UM BWMC’s alleged “administrative oversights” echo the cost-benefit analyses done in large corporations everywhere: “If the worst-case penalty is small, it’s worth the risk.” Indeed, this line of thinking is embedded in the ethos of neoliberal capitalism, where corporations are incentivized to push the boundaries of compliance, or even cross them, if the repercussions are mild.

Parallel Cases

• Flint Water Crisis: Although not a private corporation’s scandal per se, the decision to switch water sources in Flint, Michigan, to save money demonstrates the same underlying dynamic: short-term cost savings overshadowed human health. While the context differs, the structural impetus to cut corners is the same.
• Wal-Mart’s Labor Violations: Wal-Mart has repeatedly faced lawsuits and fines for wage theft, forced overtime, and poor working conditions. The fines and settlements paid pale in comparison to the billions saved through these exploitative practices.
• Pharmaceutical Industry’s Off-Label Marketing: Companies like Pfizer and Johnson & Johnson have been fined billions for illegally promoting off-label uses of drugs. Yet the profits from those practices often exceed the financial penalties, incentivizing repeated misconduct.

All of these examples illustrate how the system is designed such that compliance is often more expensive than defiance. When the latter is discovered, negotiated settlements rarely exceed the gains from the violation. All of these cases can be found by visiting other parts of evilcorporations.org

The PR Playbook of Damage Control

Sequencing the “Reputation Recovery”

1. Immediate Internal Memo: After settlement, large institutions typically send out a carefully worded memo to staff, portraying the settlement as a routine administrative matter, ensuring employees that “we have addressed the issues.”
2. Public Statements: If pressed by local media, the hospital might emphasize its “commitment to patient care” and reframe the settlement as a “technical violation” that never jeopardized anyone’s safety.
3. Community Outreach: Sponsoring local health fairs, awarding scholarships, or donating to environmental causes helps overshadow negative publicity. The mismatch between public philanthropic statements and internal cost-cutting, however, can be stark.

Token Fines vs. Ongoing Harm

As with many large institutions that pay fines or settlements, UM BWMC might claim finality: “We have learned our lesson, the matter is closed.” But the systemic drivers remain: so long as cost savings overshadow the risk of punishment, there is a structural impetus for repeat violations. This is precisely why smaller settlements rarely produce long-term behavioral change.

Corporate Power vs. Public Interest

Neoliberal Capitalism’s Structural Flaws

Under neoliberal capitalism, public health interests often rank below the imperative of growth and cost-efficiency. The expectation is that market forces, combined with minimal regulation, will produce beneficial outcomes for society. The UM BWMC scandal demonstrates a counterpoint: in healthcare (as in other sectors), lack of robust oversight can allow for corners to be cut with potentially grave consequences.

The Role of Public Outrage and Activism

Yet, all is not lost. There are historical precedents for meaningful change:

• Public Outcry: If local media, patient advocacy groups, or environmental organizations amplify these violations, there can be reputational damage that might spur deeper reforms than a $13,750 fine.
• Stronger Legislative Standards: Maryland’s legislature could tighten hazardous waste management rules specifically for healthcare facilities, imposing mandatory third-party audits or higher fines for repeated violations.
• Employee Whistleblowing: Workers who witness environmental mismanagement are key to uncovering wrongdoing. Strengthening whistleblower protections is crucial to enabling them to speak out without fear of retaliation.

Conclusion

The final message is straightforward: corporations—be they oil giants or hospitals—will not reliably “do the right thing” when profit motives dominate. The University of Maryland Baltimore Washington Medical Center’s RCRA violations are not the random failings of a single compliance officer; they are the tangible manifestation of a system that allows organizations to weigh minimal fines against the recurring expense of robust compliance.

Consumers advocacy, social justice movements, patient coalitions, and environmentally conscious groups all play vital roles in demanding accountability. By exposing these documents and explaining how the hospital “got away with it,” we highlight that corporate harm is, in fact, a choice—one that can be reversed when pressure is consistently applied. Just as outrage over the Ford Pinto scandal mandated new safety measures, so too can the revelation of UM BWMC’s hazardous waste practices spur better regulation and hospital accountability across Maryland and beyond.

In the end, the lesson from this scandal is that the interplay of corporate greed, weak enforcement, and a system that normalizes externalizing costs onto the public fosters repeated violations that harm workers and the environment. Until or unless the public insists on structural reforms, we will continue seeing the same pattern: small fines, big profits, and continuing disregard for health and safety. True corporate accountability demands more than apologies and token fines—it requires an overhaul of the neoliberal framework that allows such misconduct to flourish in the first place.

---

Evil Corporations neglecting safety protocols to cut costs, risking consumer harm for higher profits: https://evilcorporations.org/category/product-safety-violations/
Evil Corporations deliberately contaminating ecosystems to avoid expenses, prioritizing greed over sustainability: https://evilcorporations.org/category/environmental-violations/
Evil Corporations exploiting workers through unsafe conditions and unfair wages to maximize corporate gains: https://evilcorporations.org/category/labor-exploitation/
Evil Corporations recklessly mishandling or exploiting personal data, prioritizing profit over user security and consent, often exposing individuals to harm or manipulation: https://evilcorporations.org/category/data-breach-privacy/
Evil Corporations manipulating records to mislead stakeholders, enabling illicit wealth accumulation and systemic corruption: https://evilcorporations.org/category/financial-fraud/
Evil Corporations deceiving consumers with false claims to manipulate demand and conceal product risks: https://evilcorporations.org/category/misleading-marketing/
Evil Corporations doing corporate misconduct that doesn’t neatly fit into the earlier mentioned categories: https://evilcorporations.org/category/misc/