Region 2's Healthcare Compliance Initiative: Environmental Results From An Integrated Strategy

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Region 2's Healthcare Compliance Initiative
Environmental Results From An Integrated Strategy

• Leveraging Limited Resources To Obtain Better
  Compliance

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Goals For Compliance Initiative

• Improve environmental compliance and safety at
  main and off-site healthcare facilities.
• Change the culture to one in which environmental
  compliance is a priority.
• Ensure compliance of entire sector not just
  those reached through inspections.
• Ensure continued compliance by implementing
  permanent changes.

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Approach

• Region 2 combined the following strategies to
  address compliance issues in these sectors
• Compliance assistance
• Compliance incentives (voluntary
  audit/disclosure)
• Compliance monitoring
• Enforcement
• Pollution prevention
• Environmental management systems (EMS)

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Results Compliance Monitoring Incentives
Programs
Hospitals
Universe 480
Inspections 45
Enforcement Actions 33
Formal Enforcement Actions 10 (1,523,613)
Settlements 8 (642,612)
Audit Agreements 37
Voluntary Disclosures 129 covering 496 facilities (12,648,521 for 68 resolved)
Violations Corrected 1100
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ResultsEnvironmental Protection From Audits
Hospitals
Number of Beds 34,453
Number of Inpatients 1,112,914
Number of Outpatients 19.158,153
Number of Staff 150,613
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ResultsEnvironmental Benefits
Program Environmental Benefits from FY04 Disclosures
RCRA More than 42,576 lbs/year of hazardous waste is now being managed properly because hospitals have self-disclosed violations and corrected mismanagement.
SPCC At least 349,733 gallons of oil is now being managed properly.
TSCA At least 305 residential units now in compliance with lead-based paint rules.
CAA At least 153,850 pounds of chlorofluorocarbons now being appropriately managed.
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Root Causes Of Noncompliance

• Systemic violations appear to stem from
• Inadequate resources for people, equipment and
  training to carry out environmental activities
• Limited or no environmental compliance
  accountability for individual departments,
  laboratories, and staff
• Limited authority vested in environmental
  compliance officials

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Root Causes Of Noncompliance

• No clear environmental compliance
  chain-of-command
• Scattered, incomplete, and missing environmental
  compliance documentation
• Incomplete institutional knowledge regarding
  environmental regulatory requirements and
• Broad use of hazardous materials when effective
  substitutes exist

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Healthcare Violations
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Healthcare RCRA Violations
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Common Hazardous Waste Violations

• Laboratories
• Dental clinics
• X-rays units
• Nuclear medicine areas
• Pharmacy
• Maintenance areas
• Physical therapy
• Underground storage tanks

• Laundry
• Morgue
• Operating rooms
• Nursing units
• Hazardous waste storage areas
• Medical technology unit
• Construction areas
• Satellite accumulation points

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Healthcare CAA Violations
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Healthcare CWA Violations
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Healthcare TSCA Violations
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Healthcare EPCRA Violations
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Top 15 Violations From 68 Resolved Voluntary
Disclosures
Rank Violation Statute Frequency
1 ID of HW RCRA 146
2 Universal Waste RCRA 111
3 Labeling RCRA 80
4 SIP Requirements CAA 61
5 CFC Leak Detection Records CAA 58
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Top 15 Violations From 68 Resolved Voluntary
Disclosures
Rank Violation Statute Frequency
6 Chemical Inventory EPCRA 53
7 SPCC CWA 49
8 Container Management RCRA 46
9 Manifests RCRA 35
10 Personnel Training RCRA 33
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Top 15 Violations From 68 Resolved Voluntary
Disclosures
Rank Violation Statute Frequency
11 MSDS Records EPCRA 31
12 CESQG Requirements RCRA 27
13 Empty Containers RCRA 24
14 Lead Paint Disclosure TSCA 23
15 CFCs Use Certified Technicians CAA 22
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Survey Overview

• 38 hospitals completed and returned the audit
  survey
• 65,279 staff are reported to be working at these
  38 hospitals
• 10,691 beds are reported to be within these 38
  hospitals
• 282 facilities are reported to compose these 38
  hospitals

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Understanding Of Waste Management Regulations
Before And After Compliance Initiative (24 -
92)
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Understanding Of Above Ground Storage Tank
Regulations Before And After Compliance
Initiative (9 - 75)
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Understanding Of Under Ground Storage Tank
Regulations Before And After Compliance
Initiative (34 - 88)
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Understanding Of Clean Air Act Regulations
Before And AfterCompliance Initiative (27 -
76)
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Understanding Of Wastewater Discharge Regulations
Before And After Compliance Initiative (24 -
70)
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Understanding Of Spill Prevention Control
Countermeasure Plans Before And AfterCompliance
Initiative (14 - 83)
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Understanding Of Toxic Substances Control Act
Before And AfterCompliance Initiative (14 - 61)
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Understanding Of Pesticide Regulations Before And
AfterCompliance Initiative (36 - 76)
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Top Five Saving Activities
RMW management/segregation 350,000
Chemical, electronics, battery HW recycling/exchange programs 250,000
Installed high-efficiency motors, up-graded light fixtures to t-8s, and new electronic ballasts 136,000
Disposable RMW containers/bulb crushers 114,000
Changed to reusable sharps containers 30,000
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Top Five Pollutant Reductions
Battery Recycling 15 tons
RMW Segregation 475 tons
Electronics-EDP equipment recycling 75 tons
Sharps containers 10,500 units
Integrated pest management 80 reduction in pesticides
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Five Simple Waste Reduction Activities

• Install automatic light sensors
• Install water saver plumbing fixtures
• Send kitchen grease to a reclamation facility
• Switch from disposable to reusable plates, eating
  utensils, and cups for cafeteria services
• Reduce the use of disposable cleaning materials

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Most Common Mercury Reduction Activities

• Upgraded light fixtures to t-8s and installed
  new electronic ballasts
• Replaced mercury monometers thermometers
• Implemented computer monitor and electronics
  recycling program
• Collected and recycled amalgam at dentist and
  silver reclaimer installed at cancer treatment
  center
• Initiated a hospital-wide mercury reduction and
  recycling program

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Reported Hospital Audit Costs

• Average cost of audit is approximately 10,200
• Average cost of compliance is approximately
  29,300
• Average cost of compliance without two most
  expensive (gt100,000) is approximately 16,600

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Goals For Compliance Initiative

• Improve environmental compliance and safety at
  main and off-site healthcare facilities.
• Change the culture to one in which environmental
  compliance is a priority.
• Ensure compliance of entire sector not just
  those reached through inspections.
• Ensure continued compliance by implementing
  permanent changes.