WASTE MANAGEMENT
ISSUES FOR NEW
ENGLAND HOSPITALS &
HELATHCARE FACILITIES
Presented by
Larry Doucet, P.E., DEE
To The
ENVIRONMENTAL BUSINESS
COUNCIL OF NEW ENGLAND
ECOS
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WASTE MANAGEMENT
ISSUES & CONCERNS
FACING TODAY’S HOSPITALS:
CONTROLS, COSTS &
COMPLIANCE
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WASTE MANAGEMENT,
TREATMENT &
DISPOSAL
KEY ISSUES & CONCERNS
FACING TODAY’S
HOSPITALS
1. Higher & Rising Costs
2. Fewer & Shrinking Options
3. Increasing Compliance
Difficulties
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WASTE MANAGEMENT,
TREATMENT & DISPOSAL
1. HIGHER & RISING
COSTS
a.
Uncontrolled & Limitless
b. Major Bottom-line Impacts
c. No Capital Dollars for a
Solution
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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 5
ECOS
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
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HOW AND WHEN DID
THESE ISSUES & CONCERNS
ARISE?
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2005 MARKS THE 35
ANNIVERSARY
OF MEDICAL WASTE
EMERGENCE
AS AN
IMPORTANT ISSUE
FOR HOSPITALS
& HEALTHCARE FACILITIES
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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)
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“Infectious Waste Guidelines”
(’82 EPA Draft) 9
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
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TECHNOLOGIES
10
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
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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?
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WASTE MANAGEMENT,
TREATMENT & DISPOSAL
WHAT HAPPENS FROM
HERE?
• Disposal Costs Increasingly
Dominate
• Disposal Options Continually
Decline
• Future Changes Remain
Uncertain
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WASTE MANAGEMENT,
TREATMENT & DISPOSAL
PRIMARY COST REDUCTION
OPPORTUNITIES
•
WASTE MANAGEMENT PROGRAM
IMPROVEMENTS
•
ON-SITE MEDICAL WASTE
TREATMENT
•
SHARED SERVICE, CENTRALIZED
OR REGIONAL TREATMENT
FACILITY
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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 O&M Costs
-- Averted Fines & Citations
-- Reduced Insurance Premiums
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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
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WASTE MANAGEMENT
PROGRAM IMPROVEMENTS &
OPTIMIZATION
IMPLEMENTATION STEPS-
1. WASTE MANAGEMENT PROGRAM SURVEY &
ASSESSMENTS
•
•
All Waste Streams, Practices & Procedures
Generation Rates; Segregation Efficiencies; Adherence to P&P
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
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5. MONITORING & FOLLOW-UP
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WASTE MANAGEMENT
PROGRAM IMPROVEMENTS &
OPTIMIZATION
HOW MUCH MEDICAL WASTE IS
GENERATED
IN A “TYPICAL” HOSPITAL?
SURVEY DATA
SURVEYED FACILITIES
• 129 Hospitals Nationwide @ 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
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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
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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
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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
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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;
ECOS short & long-term
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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
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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
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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
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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
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Requirements
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
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needed
CONVENTIONAL STEAM
AUTOCLAVE
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AUTOCLAVE WITH BINS
IN FRONT OF LOADING DOOR
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LOADING OF BINS INTO
AUTOCLAVE TREATMENT
CHAMBER
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MOVING BIN TO
COMPACTOR DUMPER
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SHARED-SERVICE,
CENTRALIZED & REGIONAL
TREATMENT FACILITIES
COMBINED WASTE STREAMS & SHARED
OPERATIONS
SIGNIFICANT ADVANTAGES
• Highly favorable economics
• Minimum capital & O&M 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
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• Combination (depending on risks, control,
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WASTE MANAGEMENT AS PART
OF A COMPREHENSIVE
ENVIRONMENTAL COMPLIANCE
PROGRAM
SHOULD HEALTHCARE
EXECUTIVES WORRY ABOUT
ENVIRONMENTAL
COMPLIANCE?
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THE RISKS OF POOR
ENVIRONMENTAL
COMPLIANCE
• VERY SIGNIFICANT FINES
• BAD PUBLICITY LEADING TO Poor affect on hospital’s reputation for
quality care
--
-- Loss of patients & financial revenues
-- Poor image projections on staff, patients &
general public
-- Increased community opposition to
expansion &
new projects
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MAJOR ENVIRONMENTAL
REGULATIONS AFFECTING
HOSPITALS
• Clean Air Act (CAA)
• Clean Water Act (CWA)
• Comprehensive Environmental Response,
Compensation
• & Liability Act (CERCLA)
• Emergency planning & Community Right-toKnow (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
ECOS OVER 4,600 SECTIONS35
IN THE CFR
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
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limited environmental issues
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EPA’S “AUDIT POLICY”
“Incentives for SelfPolicing: Discovery,
Disclosure, Correction &
Prevention Of Violations”
Effective May 2000
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EPA’S INITIATIVES &
ACTIONS
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•
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;
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$911,000 penalties
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
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SUMMARY OF
EPA REGION 1 VIOLATIONS
IN JULY 2005 –
697 VIOLATIONS FROM 128
FACILITIES
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•
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RCRA Violations
CWA Violations
EPCRA Violations
CAA Violations
TSCA Violations
SDWA Violations
ECOS
60%
17%
12%
7%
4%
1%
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SUMMARY OF
EPA REGION 1 VIOLATIONS
TOP 9 VIOLATIONS FROM 59
RESOLVED VOLUNTARY
DISCLOSURES
VIOLATIONS
ACTS
1. ID of HW
2. Universal Waste
3. Chemical Inventory
4.
5.
6.
7.
8.
9.
FREQUENCY
RCRA
RCRA
EPCRA
48
SIP Requirements CAA
48
SPCC
CWA
44
Labeling
RCRA
CFC Leak Detection CAA
32
MSDA Records
EPCRA
30
Manifests
RCRA
ECOS
92
66
35
30
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SUMMARY OF EPA REGION 1
HEALTHCARE RCRA
VIOLATIONS
409 REPORTED RCRA
VIOLATIONS
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•
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ID of HW
23%
Generator Requirements
18%
Container Management
16%
Universal Waste
16%
General Facility Standards
16%
• Manifests
7%
• Accumulation Time
2%
• UST
1%
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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
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accumulation areas
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SUMMARY,
QUESTION &
DISCUSSIONS
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