Environmental Quality Assurance and Compliance at Medical and Dental Treatment Facilities

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Environmental Quality Assurance and Compliance at
Medical and Dental Treatment Facilities

• ENVIRONMENTAL PROGRAMS DIRECTORATE
• BUMED ENVIRONMENTAL QUALITY

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INTRODUCTION

• Mr. Bill Rogers
  BUMED Environmental Manager
• [phone] or DSN 377-5558
• Fax [phone]
• E-mail rogersw_at_nehc.med.navy.mil
• 620 John Paul Jones Cir, Portsmouth, VA,
  23708-2103

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ENVIRONMENTAL PROGRAMSORGANIZATIONAL DIAGRAM
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BUMED ClaimancyEnvironmental Quality Department,

• Background
• This function was transferred from BUMED (MED 43)
  to NEHC in June 1995 per the headquarters
  reduction initiative.
• Personnel consists of
• 1 - GS-13 Environmental Program Manager
• 1 O-3 Civil Engineer Corps Officer

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ENVIRONMENTAL QUALITY DEPARTMENT

• DUTIES INCLUDE
• Assist the Chief of Naval Operations in
  establishing environmental policy
• Establish and disseminate environmental policy
  for the BUMED claimancy
• Develop environmental Program Objectives
  Memorandums, Program Reviews, and budgets for
  funding activity requirements

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ENVIRONMENTAL QUALITY DEPARTMENT

• Coordinate the Environmental Quality Assessment
  program at the claimant level
• Provide Environmental expertise and assistance to
  BUMED activities
• Assist Navy and Marine Corps activities with
  medically unique environmental matters
• Compile claimancy data for CNO (N45)
• Provide comments on proposed environmental
  legislation as it impacts our medical/dental
  treatment facilities

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MISSION

• BUMED is committed to environmental excellence in
  our pursuit of Force Health Protection.
• We accomplish this through commitment to the
  following principles
• Compliance
• Prevention
• Communication
• Continuous Improvement

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ENVIRONMENTAL LAWS

• State Infectious Waste Laws
• Resource Conservation and Recovery Act (RCRA)
• Hazardous and Solid Waste Amendments (HSWA)
• Toxic Substances Control Act (TSCA)
• Comprehensive Environmental Response,
  Compensation and Liability Act (CERCLA)
• Superfund Amendments and Reauthorization Act
  (SARA)
• Clean Air Act (CAA)
• Safe Drinking Water Act (SDWA)
• Clean Water Act (CWA)
• Executive Order 13148

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REASONS TO COMPLY

• Civil Charges
• Non-Compliance Penalties
• Economic Benefit Penalties
• Criminal Charges
• Willful Negligence
• Withholding or Falsifying Information
• Injunction to halt a project or process
• Other Reasons
• Bad Public Image
• Protect Human Health and the Environment

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ENVIRONMENTAL PROGRAM(OPNAVINST 5090.1B)

• Pollution Prevention
• Air Permits
• Waste Water Discharge Permits
• Hazardous Waste/Hazardous Material
• Drinking Water - Distribution and Lead
• Polychlorinated Biphenyls (PCBs)
• Underground Storage Tanks
• Oil/HM Spill Control and Countermeasures and
  Contingency Plans
• Recycling
• Emergency Planning and Community Right to Know
  (EPCRA)
• Asbestos
• Ozone Depleting Substances (ODS)

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PROGRAM ORGANIZATION

• HEADQUARTERS
• HEALTHCARE SUPPORT OFFICES
• ACTIVITIES

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ENVIRONMENTAL QUALITY ASSESSMENT (EQA) Program

• Federal Facilities must comply with Federal,
  State, and local laws and are subject to
  enforcement action by regulatory agencies.
• DOD and Navy policy require compliance
• OPNAVINST 5090.1B Chapter 20 - The EQA program
  provides means to monitor, achieve and maintain
  compliance with environmental and natural
  resources regulations.
• 2 TIERED PROGRAM

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Who is Conducting the Program?

• I. Activity Annual Self EQAs by Base Staff
• Format Established by Activity
• Includes Tenants
• Developed from Activity Internal Assessment Plan
  (IAP)
• II. Major Claimant EQAs
• Performed by Major Claimant Staff (Includes
  Tenants) (For Most, EFD/As Provide Technical
  Team Members)
• Schedule and Scope determined by Major Claimant
  after review of IAPs and Self-Assessments (Host
  and Tenant Claimants Coordinate to perfomr
  External assessments)
• Report Issued by Major Claimant (Internal
  Document)

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MOST COMMON EQA FINDINGS

• HAZARDOUS WASTE
• Hazardous Waste Management Plan that is not
  current.
• Improper labeling, storage and manifesting of
  containers.
• Inadequate training and/or training records.
• Inadequate Silver Recovery program

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MOST COMMON EQA FINDINGS(CONTINUED)

• INFECTIOUS WASTE
• Not operating in accordance with state/local
  plans and permits.
• Improperly mixing infectious waste with
  non-bio-hazardous waste. (RMW .22-.50/lb vs.
  .10-.18/lbs solid waste for disposal)
• No medical waste management plan.
• Improper labeling of containers.

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MOST COMMON EQA FINDINGS(CONTINUED)

• POTABLE WATER
• Priority sampling for lead and copper.
• Inadequate Backflow Prevention Program.
• Sampling Siting Plan is not developed.

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MOST COMMON EQA FINDINGS(CONTINUED)

• POLICY
• Not performing Self-Environmental Quality
  Assessments (EQAs).
• Out of date or ambiguous statements in
  host/tenant agreements.
• No host/tenant agreement or inter-service support
  agreement (ISSA).
• Insufficient training of environmental staff.
  (Asbestos/ODS/HW)

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MOST COMMON EQA FINDINGS(CONTINUED)

• SPILL PREVENTION CONTROL COUNTERMEASURES (SPCC)
• No SPCC plan prepared or not being implemented.
• Inadequate host/tenant coordination (i.e. Base
  performs modifications and no revision to SPCC
  plan, Base does not provide a copy of SPCC plan
  to Naval Hospital).

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MOST COMMON EQA FINDINGS(CONTINUED)

• ASBESTOS
• Inadequate Asbestos Operations and Maintenance
  Plan.
• Insufficient training of personnel.
• HAZARDOUS MATERIAL CONTROL AND MANAGEMENT
• Inadequate Hazardous Material Control and
  Management Program. (No centralized purchase and
  issue point) (CHRIMP)
• Improper authorized use list/inventory.
• Improper labeling and storage of containers.
• Purchase non-AUL products or products with no
  Material Safety Data Sheets (MSDSs).

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MOST COMMON EQA FINDINGS(CONTINUED)

• AIR
• Inadequate inventory of ODS equipment, and thus
  no ODS phase-out plans.
• Improper training and records for equipment
  and personnel working with ODS materials.
• Improper disposal of ODS

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What does all this mean?

• The trends indicate that most violations are
  operational or administrative in nature
• We must develop a better management system to
  correct these problems

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The Answer

• Environmental Management System
• Quality Assurance for an activities environmental
  program
• Identify and manage potential environmental
  impacts
• Proactive approach to environmental security
• Internal Assessment Plans (31MAR02)

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EMS Components

• A Generic EMS contains the following 5
  components
• Policy Statement
• Planning
• Implementation
• Evaluation
• Continual Improvement

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Navy EMS Process
The Planning Loop
Policy

• Identify and track requirements
• Identify vulnerable assets and practices that
  impact them
• Identify and document impacts
• Identify training needs
• Identify Pollution Prevention Opportunities
• Rank Impacts
• Develop objectives and Targets

Planning
Implementation
Implementation
-Establish programs -Provide resources
(funding/personnel) -Provide Training -Develop
and control EMS documentation Develop and
Document SOPs Develop, document, and test
emergency procedures
Evaluation
Corrective Action Loop
-Identify/Characterize/document problems -Develop
corrective /preventive actions -Secure management
approval Implement solutions
Management Review
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FUNDING SOURCESfor Environmental Projects

• Major Claimant
• Activity
• Centrally Managed NAVFAC Funds

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TYPES OF BUMED FACILITIES

• STAND ALONE
• BUMED OWNS PROPERTY
• BUMED PERFOMS MAINTENANCE
• i.e. BETHESDA, PORTSMOUTH, BEAUFORT
• QUASI-TENANT - on a military base
• BUMED OWNS PROPERTY
• BUMED PERFORMS MAINTENANCE
• i.e. JACKSONVILLE, CHERRY POINT, ROTA
• TENANT
• BASE OWNS PROPERTY
• BASE PERFORMS MAINTENANCE
• i.e. PAX RIVER, LEMOORE, PORTSMOUTH NH

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UNIQUE MTF ISSUES

• SILVER DISCHARGE TO SANITARY SEWER SYSTEM
• MERCURY DISCHARGE TO SANITARY SEWER SYSTEM
• DISPOSAL OF INFECTIOUS MEDICAL WASTE
• PARTNERING (AHA, H2E, EPA, JACHO)
• POLLUTION PREVENTION

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POLLUTION PREVENTION (P2)

• Pollution reduced at source
• Pollution not prevented should be recycled
• Pollution that cannot be recycled should be
  treated
• Disposal is the last resort

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SAMPLE ACTION ITEMS FOR P2 PLANS

• Hospital CHRIMP Program
• Photo Processing alternatives
• Replacement of ETO Sterilizers-may or may not be
  feasible
• Replacement of ODS Class I/ II
• Xylene and Formaldehyde stills
• Collecting aluminum, paper, glass, and plastic
  for recycling
• Infectious Waste Reduction Initiatives
• Cleaning Material and Solvent Substitution

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ENVIRONMENTAL INFORMATION WEBSITES

• DENIX
• http//denix.osd.mil
• Environmental Protection Agency
• http//www.epa.gov
• NATO
• http//echs.ida.org
• Navy Facilities Engineering Command
• http//www.ncts.navy.mil/homepages/navfac_es/shore
  g2.htm
• http//clean.rti.org/larry/haz9.htm
• BUMED Environmental Management System (EMS)
  Program
• http//www-nehc.med.navy.mil/ep/bumed_ems.htm

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FUTURE INITIATIVES

• ENVIRONMENTAL MANAGEMENT SYSTEM (EMS)
• POLLUTION PREVENTION
• WATER PROGRAMS
• IMPROVED COMMUNICATION
• ON-LINE SUPPORT
• HOSPITALS FOR A HEALTHY ENVIRONMENT (H2E)

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QUESTIONS?