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WASTE MANAGEMENT ISSUES FOR NEW ENGLAND HOSPITALS

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Title: WASTE MANAGEMENT ISSUES FOR NEW ENGLAND HOSPITALS


1
WASTE MANAGEMENT ISSUES FOR NEW ENGLAND HOSPITALS
HELATHCARE FACILITIES
  • Presented by
  • Larry Doucet, P.E., DEE
  • To The
  • ENVIRONMENTAL BUSINESS COUNCIL OF NEW ENGLAND

2
WASTE MANAGEMENT ISSUES CONCERNS FACING
TODAYS HOSPITALSCONTROLS, COSTS COMPLIANCE
3
WASTE MANAGEMENT, TREATMENT DISPOSAL
  • KEY ISSUES CONCERNS FACING TODAYS HOSPITALS
  • Higher Rising Costs
  • Fewer Shrinking Options
  • Increasing Compliance Difficulties

4
WASTE MANAGEMENT, TREATMENT DISPOSAL
  • 1. HIGHER RISING COSTS
  • Uncontrolled Limitless
  • Major Bottom-line Impacts
  • No Capital Dollars for a Solution

5
WASTE MANAGEMENT, TREATMENT DISPOSAL
  • 2. FEWER SHRINKING OPTIONS
  • a. Fewer Viable Treatment Technologies
  • b. Fewer Off-site Disposal Vendors
  • -- State Regional Monopolies
  • -- Longer Transport Distances

6
WASTE MANAGEMENT, TREATMENT DISPOSAL
  • 3. INCREASING COMPLIANCE DIFFICULTIES
  • a. Expanded EPA Compliance Audits
  • b. JCAHO Environment Of Care Compliance
  • c. On-going Off-site Disposal Liabilities
  • d. Image Relations to Public, Patients Staff

7
HOW AND WHEN DID THESE ISSUES CONCERNS ARISE?
8
  • 2005 MARKS THE 35 ANNIVERSARY
  • OF MEDICAL WASTE EMERGENCE
  • AS AN
  • IMPORTANT ISSUE
  • FOR HOSPITALS
  • HEALTHCARE FACILITIES

9
WASTE MANAGEMENT, TREATMENT DISPOSAL
  • HOW DID THESE ISSUES EVOLVE?
  • PRE-1970 MINIMAL REGULATIONS COSTS
  • 1970 EPA ESTABLISHED CHANGES START
  • 1970 - EARLY 80s
  • Arab Oil Embargos (74 78)
  • Infectious Waste As Hazardous (76,78
    80-rcra)
  • APC Regulations (77-CAAA)
  • Infectious Waste Guidelines (82 EPA Draft)

10
WASTE MANAGEMENT, TREATMENT DISPOSAL
  • HOW DID THESE ISSUES EVOLVE?
  • EARLY 1980s MID-90s
  • AIDS BECOMES THE MAIN FOCUS OF CONCERN
    UNIVERSAL PRECAUTIONS BLOODBORNE PATHOGENS,
    MED WASTE TRACKING ACT, ETC.
  • JCAHA STANDARDS DEFINE INFECTIOUS WASTE AS
    HAZARDOUS WASTE (85)
  • BEACH WASHUPS DISPOSAL INCIDENCES (86-86)
  • MED WASTE DISPOSAL INDUSTRY DEVELOPED
  • DEVELOPMENT OF ALTERNATE TREATMENT TECHNOLOGIES

11
WASTE MANAGEMENT, TREATMENT DISPOSAL
  • HOW DID THESE ISSUES EVOLVE?
  • MID-1990s 2005
  • CLEAN AIR ACT AMENDMENTS SHUT INCINERATORS
  • MED WASTE DISPOSAL INDUSTRY CONSOLIDATES
  • ALTERNATE TREATMENT TECHNOLOGIES FADE OUT

12
WASTE MANAGEMENT, TREATMENT DISPOSAL
  • WHAT DOES THE FUTURE HOLD?
  • OFF-SITE DISPOSAL MONOPOLIES?
  • Seem to be Occurring
  • If So, Cost Escalations Certain
  • How High How Fast?
  • VIABLE TREATMENT ALTERNATIVES?
  • Hugh Decline in Numbers
  • More than 190 of about 210 firms out of business
  • Very few have as many as 5 years experience
  • Questionable Long-Range Vendor Survivability?

13
WASTE MANAGEMENT, TREATMENT DISPOSAL
  • WHAT HAPPENS FROM HERE?
  • Disposal Costs Increasingly Dominate
  • Disposal Options Continually Decline
  • Future Changes Remain Uncertain
  • Continued Financial Difficulties For Many
    Hospitals

14
WASTE MANAGEMENT, TREATMENT DISPOSAL
  • PRIMARY COST REDUCTION OPPORTUNITIES
  • WASTE MANAGEMENT PROGRAM IMPROVEMENTS
  • ON-SITE MEDICAL WASTE TREATMENT
  • SHARED SERVICE, CENTRALIZED OR REGIONAL TREATMENT
    FACILITY

15
WASTE MANAGEMENT PROGRAM IMPROVEMENTS
OPTIMIZATION
  • COST SAVINGS OPPORTUNITIES-
  • REDUCED MEDICAL WASTE GENERATION RATES
  • 50 or More Reduction Achievable
  • REDUCED OFF-SITE DISPOSAL COSTS
  • Reduced Volumes and/or On-Site Treatment
  • INCREASED RECYCLING BENEFITS
  • Increased Recycled Volumes Reduced General
    Waste Volumes
  • OTHER COST SAVING AREAS
  • -- Reduced Hazardous Waste Disposal Costs
  • -- Reduced Overall OM Costs
  • -- Averted Fines Citations
  • -- Reduced Insurance Premiums

16
WASTE MANAGEMENT PROGRAM IMPROVEMENTS
OPTIMIZATION
  • OTHER BENEFITS-
  • Reduced Hazardous Material Use/Disposal
  • Liability Containment Averted Fines
  • Increased Operational Efficiencies
  • Demonstrated Corporate Responsibility
  • Positive Public Image
  • Continuous Quality Improvements

17
WASTE MANAGEMENT PROGRAM IMPROVEMENTS
OPTIMIZATION
  • IMPLEMENTATION STEPS-
  • 1. WASTE MANAGEMENT PROGRAM SURVEY ASSESSMENTS
  • All Waste Streams, Practices Procedures
  • Generation Rates Segregation Efficiencies
    Adherence to PP
  • 2. IDENTIFY IMPROVEMENTS COST SAVINGS
    OPPORTUNITIES
  • Identify/Evaluate Options Alternatives
  • Volume/Generation Reduction Recycling/Reuse Haz
    Waste/Material Reduction Etc.
  • Set Goals Establish Milestone Progress Targets
  • 3. IMPLEMENT PROGRAM IMPROVEMENTS
  • New/Revised Policies, Procedure Program Manuals
  • Employee/Staff Training
  • 4. PROGRAM ADMINISTRATION OVERSIGHT
  • 5. MONITORING FOLLOW-UP

18
WASTE MANAGEMENT PROGRAM IMPROVEMENTS
OPTIMIZATION
  • HOW MUCH MEDICAL WASTE IS GENERATED
  • IN A TYPICAL HOSPITAL?
  • SURVEY DATA
  • SURVEYED FACILITIES
  • 129 Hospitals Nationwide _at_ 43,000 Beds (Randomly
    Selected)
  • 240 Million Lb/Yr Total Waste 46 Million Lb/Yr
    Red Bag Waste
  • SURVEY RESULT SUMMARY
  • Red Bag Waste Generation Range 0.10 to 92.7
  • Red Bag Waste Generation Average 19.5
  • 77 of Facilities Outside of 10 to 15 Range

19
WASTE MANAGEMENT PROGRAM IMPROVEMENTS
OPTIMIZATION
  • WHY SUCH A LARGE DEVIATION?
  • UNINTENTIONAL
  • Mismanagement
  • Regulatory Misinterpretations
  • Unfamiliarity of Alternatives
  • INTENTIONAL
  • Rational Analyses
  • Comparison of On-Site vs. Off-Site Options

20
WASTE MANAGEMENT PROGRAM IMPROVEMENTS
OPTIMIZATION
  • FACTORS AFFECTING INDIVIDUAL HOSPITAL WASTE
    GENERATION RATES-
  • 1. Regulatory Definitions
  • 2. Regulatory Interpretations
  • 3. Waste Management Policies Protocols
  • 4. Waste Management Practices Efficiencies
  • 5. Hauler/Disposal Restrictions

21
MEDICAL WASTE TREATMENT DISPOSAL ALTERNATIVES
  • TREATMENT DISPOSAL OPTIONS
  • Off-Site Contract Disposal
  • On-Site Treatment
  • Shared-Service, Centralized or Regional Facility
  • ALTERNATIVE TREATMENT TECHNOLOGIES
  • Thermal
  • Chemical
  • Irradiation
  • Biological

22
MEDICAL WASTE TREATMENT DISPOSAL ALTERNATIVES
  • OFF-SITE DISPOSAL VS. ON-SITE TREATMENT
  • OFF-SITE CONTRACT DISPOSAL
  • Medical waste picked up treated/disposed
    off-site via vendor
  • Facilities responsible for packaging
    manifesting
  • Costs vary widely Locations facility sizes
    are main factors
  • Liabilities risk remain with facilities
  • ON-SITE TREATMENT
  • Medical waste converted to general waste
  • Much lower costs Typically 0.10 to 0.20/lb vs.
    0.25 to 2.00/lb
  • Costs are controlled well know vendor
    independence
  • Risk liability reductions short long-term

23
ON-SITE MEDICAL WASTE TREATMENT TECHNOLOGIES
  • THERMAL TECHNOLOGIES
  • TEMPERATURES 205?F TO 20,000?F
  • Low-Heat Processes
  • Hot Air Oil
  • Infrared Radiation
  • Microwaves Macrowaves
  • Hot Water
  • Steam Direct Indirect Low High
    Temperature Chemical
  • High-Heat Processes
  • Incineration
  • Pyrolysis
  • Plasma Plasma Pyrolysis

24
ON-SITE MEDICAL WASTE TREATMENT TECHNOLOGIES
  • OTHER TECHNOLOGIES
  • Chemical (Disinfection) Technologies
  • Shredding Required
  • Must Use Chlorine Compounds
  • Once-Through Recirculation Systems
  • Irradiation Technologies
  • Electron Beam Radiation
  • Cobalt 60
  • Biological Process
  • Shredding With Enzymes
  • Single Demonstration Process

25
EVALUATING ALTERNATE TREATMENT TECHNOLOGIES
  • EVALUATION/SELECTION DIFFICULTIES
  • Many technologies are new under development
  • Most vendors have no full-scale operational
    systems
  • DATA COLLECTION DIFFICULTIES
  • Potentially misleading limited data
  • Few facilities with limited experience
  • UNSTABLE DECLINING INDUSTRY

26
EVALUATING ALTERNATE TREATMENT TECHNOLOGIES
  • KEY EVALUATION CRITERIA
  • 1. Demonstrated Performance
  • 2. Technical Performance Criteria
  • 3. Vendor Qualifications
  • 4. Environmental Permitting Issues
  • 5. Occupational Health Safety Issues
  • 6. Facility Infrastructure Requirements
  • 7. Economics

27
EVALUATING ALTERNATE TREATMENT TECHNOLOGIES
  • WHAT SEEMS TO BE THE BEST ALTERNATIVE?
  • CONVENTIONAL STEAM AUTOCLAVE SYSTEM
  • Autoclave Processing Unit
  • Autoclave Bins
  • Bin Dumper
  • Optional Automation System
  • Optional Integrated Shredder
  • -- Treated Waste and/or Confidential Documents
  • ADVANTAGES
  • Long-proven widely recognized accepted in by
    most state agencies
  • Easy to permit negligible public opposition
  • Easy to operate maintain high degree of
    reliability
  • Small space requirements
  • Lowest capital operating costs
  • -- Financing options available (ECOS) No
    capital needed

28
CONVENTIONAL STEAM AUTOCLAVE
29
AUTOCLAVE WITH BINS IN FRONT OF LOADING DOOR
30
LOADING OF BINS INTO AUTOCLAVE TREATMENT CHAMBER
31
MOVING BIN TO COMPACTOR DUMPER
32
SHARED-SERVICE, CENTRALIZED REGIONAL TREATMENT
FACILITIES
  • COMBINED WASTE STREAMS SHARED OPERATIONS
  • SIGNIFICANT ADVANTAGES
  • Highly favorable economics
  • Minimum capital OM costs
  • "Automatic" off-site cost reductions
  • Enhanced off-site contractor negotiations
  • Divorces waste treatment from hospital operations
  • Accommodates affiliated small-quantity generators
  • VARYING DEVELOPMENT/IMPLEMENTATION OPTIONS
  • Participating hospitals only
  • Independent developer/investor only
  • Combination (depending on risks, control,
    profits)
  • Split/program components transport treatment

33
WASTE MANAGEMENT AS PART OF A COMPREHENSIVE
ENVIRONMENTAL COMPLIANCE PROGRAM
  • SHOULD HEALTHCARE
  • EXECUTIVES WORRY ABOUT ENVIRONMENTAL COMPLIANCE?

34
THE RISKS OF POOR ENVIRONMENTAL COMPLIANCE
  • VERY SIGNIFICANT FINES
  • BAD PUBLICITY LEADING TO -
  • -- Poor affect on hospitals reputation for
    quality care
  • -- Loss of patients financial revenues
  • -- Poor image projections on staff, patients
    general public
  • -- Increased community opposition to expansion
  • new projects

35
MAJOR ENVIRONMENTAL REGULATIONS AFFECTING
HOSPITALS
  • Clean Air Act (CAA)
  • Clean Water Act (CWA)
  • Comprehensive Environmental Response,
    Compensation
  • Liability Act (CERCLA)
  • Emergency planning Community Right-to-Know
    (EPCRA)
  • Federal Insecticide, Fungicide Rodenticide Act
    (FIFRA)
  • Resource Conservation Recovery Act (RCRA)
  • Safe Drinking Water Act (SDWA)
  • Toxic Substances Control Act (TSCA)
  • MORE THAN 40 PARTS WITH OVER 4,600 SECTIONS IN
    THE CFR

36
HOSPITAL ENVIRONMENTAL COMPLIANCE CHALLENGES
  • Environmental activities rarely controlled by one
    department
  • Lack awareness of spectrum of applicable
    environmental requirements
  • Recordkeeping documentation scattered not
    easily retrievable
  • JCAHO Standards only address limited
    environmental issues

37
EPAS AUDIT POLICY
  • Incentives for Self-Policing Discovery,
    Disclosure, Correction Prevention Of
    Violations
  • Effective May 2000

38
EPAS INITIATIVES ACTIONS
  • REGIONS 1 2 (New England States, NY, NJ, CT
    PR)
  • LAUNCHED COMPLIANCE INITIATIVES TARGETING
    HOSPITALS, HEALTHCARE FACILITIES,
  • COLLEGES UNIVERSITIES
  • Alerts
  • Self-Audit pacts
  • Random, unannounced inspections
  • Region 2- 44 facilities inspected
  • 22 enforcement actions 911,000 penalties

39
EPA REGION 1 INITIATIVE STATUS AS OF JULY 2005
  • Total of 480 Facilities
  • 44 Inspected 24 Enforcement Actions
  • 10 Formal Enforcement Actions Totaling 1.3 Mil
  • 8 Settlements Totaling 560 Thousand
  • 37 Audit Agreements
  • 128 Voluntary Disclosures Totaling 1.1 Mil
  • 1,000 Violations Corrected

40
SUMMARY OF EPA REGION 1 VIOLATIONS
  • IN JULY 2005
  • 697 VIOLATIONS FROM 128 FACILITIES
  • RCRA Violations 60
  • CWA Violations 17
  • EPCRA Violations 12
  • CAA Violations 7
  • TSCA Violations 4
  • SDWA Violations 1

41
SUMMARY OF EPA REGION 1 VIOLATIONS
  • TOP 9 VIOLATIONS FROM 59 RESOLVED VOLUNTARY
    DISCLOSURES
  • VIOLATIONS ACTS FREQUENCY
  • ID of HW RCRA 92
  • Universal Waste RCRA 66
  • Chemical Inventory EPCRA 48
  • SIP Requirements CAA 48
  • SPCC CWA 44
  • Labeling RCRA 35
  • CFC Leak Detection CAA 32
  • MSDA Records EPCRA 30
  • Manifests RCRA 30

42
SUMMARY OF EPA REGION 1 HEALTHCARE RCRA
VIOLATIONS
  • 409 REPORTED RCRA VIOLATIONS
  • ID of HW 23
  • Generator Requirements 18
  • Container Management 16
  • Universal Waste 16
  • General Facility Standards 16
  • Manifests 7
  • Accumulation Time 2
  • UST 1

43
TYPICAL RCRA VIOLATIONS IN THE HEALTHCARE
INDUSTRY
  • Improper labeling of HW containers
  • Inadequate, incomplete, or no HW manifests
  • Improper management of mercury wastes
  • -- Fluorescent lamps
  • -- Thermometers
  • Improper management of expired/discarded
    chemicals
  • Lack of or inadequate employee training on HW
  • No weekly inspections in HW accumulation areas

44
SUMMARY,QUESTION DISCUSSIONS
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