ecos1 waste management issues for new england hospitals & helathcare facilities presented by...
TRANSCRIPT
ECOS 1
WASTE MANAGEMENT WASTE MANAGEMENT ISSUES FOR NEW ENGLAND ISSUES FOR NEW ENGLAND HOSPITALS & HELATHCARE HOSPITALS & HELATHCARE
FACILITIESFACILITIES
WASTE MANAGEMENT WASTE MANAGEMENT ISSUES FOR NEW ENGLAND ISSUES FOR NEW ENGLAND HOSPITALS & HELATHCARE HOSPITALS & HELATHCARE
FACILITIESFACILITIESPresented by
Larry Doucet, P.E., DEELarry Doucet, P.E., DEETo The
ENVIRONMENTAL BUSINESS COUNCIL OF NEW ENGLAND
Presented by
Larry Doucet, P.E., DEELarry Doucet, P.E., DEETo The
ENVIRONMENTAL BUSINESS COUNCIL OF NEW ENGLAND
ECOS 2
WASTE MANAGEMENT WASTE MANAGEMENT ISSUES & CONCERNS ISSUES & CONCERNS
FACING TODAY’S HOSPITALS:FACING TODAY’S HOSPITALS:
CONTROLS, COSTS & CONTROLS, COSTS & COMPLIANCECOMPLIANCE
WASTE MANAGEMENT WASTE MANAGEMENT ISSUES & CONCERNS ISSUES & CONCERNS
FACING TODAY’S HOSPITALS:FACING TODAY’S HOSPITALS:
CONTROLS, COSTS & CONTROLS, COSTS & COMPLIANCECOMPLIANCE
ECOS 3
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSAL
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSAL
KEY ISSUES & CONCERNS KEY ISSUES & CONCERNS FACING TODAY’S HOSPITALSFACING TODAY’S HOSPITALS
1.1. Higher & Rising CostsHigher & Rising Costs
2.2. Fewer & Shrinking OptionsFewer & Shrinking Options
3.3. Increasing Compliance DifficultiesIncreasing Compliance Difficulties
KEY ISSUES & CONCERNS KEY ISSUES & CONCERNS FACING TODAY’S HOSPITALSFACING TODAY’S HOSPITALS
1.1. Higher & Rising CostsHigher & Rising Costs
2.2. Fewer & Shrinking OptionsFewer & Shrinking Options
3.3. Increasing Compliance DifficultiesIncreasing Compliance Difficulties
ECOS 4
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSAL
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSAL
1. HIGHER & RISING COSTS1. HIGHER & RISING COSTS
a.a. Uncontrolled & LimitlessUncontrolled & Limitless
b.b. Major Bottom-line ImpactsMajor Bottom-line Impacts
c.c. No Capital Dollars for a SolutionNo Capital Dollars for a Solution
1. HIGHER & RISING COSTS1. HIGHER & RISING COSTS
a.a. Uncontrolled & LimitlessUncontrolled & Limitless
b.b. Major Bottom-line ImpactsMajor Bottom-line Impacts
c.c. No Capital Dollars for a SolutionNo Capital Dollars for a Solution
ECOS 5
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSAL
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSAL
2. FEWER & SHRINKING OPTIONS2. FEWER & SHRINKING OPTIONS
a.a. Fewer Viable Treatment TechnologiesFewer Viable Treatment Technologies
b.b. Fewer Off-site Disposal VendorsFewer Off-site Disposal Vendors
-- State & Regional Monopolies-- State & Regional Monopolies
-- Longer Transport Distances-- Longer Transport Distances
2. FEWER & SHRINKING OPTIONS2. FEWER & SHRINKING OPTIONS
a.a. Fewer Viable Treatment TechnologiesFewer Viable Treatment Technologies
b.b. Fewer Off-site Disposal VendorsFewer Off-site Disposal Vendors
-- State & Regional Monopolies-- State & Regional Monopolies
-- Longer Transport Distances-- Longer Transport Distances
ECOS 6
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSAL
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & 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
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
ECOS 7
HOW AND WHEN DID THESE HOW AND WHEN DID THESE ISSUES & CONCERNS ARISE?ISSUES & CONCERNS ARISE?HOW AND WHEN DID THESE HOW AND WHEN DID THESE ISSUES & CONCERNS ARISE?ISSUES & CONCERNS ARISE?
ECOS 8
2005 MARKS THE 35 2005 MARKS THE 35 ANNIVERSARY ANNIVERSARY
OF MEDICAL WASTE EMERGENCE OF MEDICAL WASTE EMERGENCE AS AN AS AN
IMPORTANT ISSUE IMPORTANT ISSUE FOR HOSPITALS FOR HOSPITALS
& HEALTHCARE FACILITIES& HEALTHCARE FACILITIES
2005 MARKS THE 35 2005 MARKS THE 35 ANNIVERSARY ANNIVERSARY
OF MEDICAL WASTE EMERGENCE OF MEDICAL WASTE EMERGENCE AS AN AS AN
IMPORTANT ISSUE IMPORTANT ISSUE FOR HOSPITALS FOR HOSPITALS
& HEALTHCARE FACILITIES& HEALTHCARE FACILITIES
ECOS 9
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSAL
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSAL
HOW DID THESE ISSUES EVOLVE?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)
HOW DID THESE ISSUES EVOLVE?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)
ECOS 10
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSAL
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSAL
HOW DID THESE ISSUES EVOLVE?HOW DID THESE ISSUES EVOLVE?EARLY 1980s – MID-’90s:EARLY 1980s – MID-’90s:
• AIDS BECOMES THE MAIN FOCUS OF CONCERN: AIDS BECOMES THE MAIN FOCUS OF CONCERN: “UNIVERSAL PRECAUTIONS;” “BLOODBORNE “UNIVERSAL PRECAUTIONS;” “BLOODBORNE PATHOGENS,” “MED WASTE TRACKING ACT,” ETC.PATHOGENS,” “MED WASTE TRACKING ACT,” ETC.
• JCAHAJCAHA STANDARDS STANDARDS DEFINE “INFECTIOUS WASTE” AS DEFINE “INFECTIOUS WASTE” AS “HAZARDOUS WASTE” (’85)“HAZARDOUS WASTE” (’85)
• BEACH WASHUPS & DISPOSAL INCIDENCES (’86-’86)BEACH WASHUPS & DISPOSAL INCIDENCES (’86-’86)
• MED WASTE DISPOSAL INDUSTRY DEVELOPEDMED WASTE DISPOSAL INDUSTRY DEVELOPED
• DEVELOPMENT OF ALTERNATE TREATMENT DEVELOPMENT OF ALTERNATE TREATMENT TECHNOLOGIES TECHNOLOGIES
HOW DID THESE ISSUES EVOLVE?HOW DID THESE ISSUES EVOLVE?EARLY 1980s – MID-’90s:EARLY 1980s – MID-’90s:
• AIDS BECOMES THE MAIN FOCUS OF CONCERN: AIDS BECOMES THE MAIN FOCUS OF CONCERN: “UNIVERSAL PRECAUTIONS;” “BLOODBORNE “UNIVERSAL PRECAUTIONS;” “BLOODBORNE PATHOGENS,” “MED WASTE TRACKING ACT,” ETC.PATHOGENS,” “MED WASTE TRACKING ACT,” ETC.
• JCAHAJCAHA STANDARDS STANDARDS DEFINE “INFECTIOUS WASTE” AS DEFINE “INFECTIOUS WASTE” AS “HAZARDOUS WASTE” (’85)“HAZARDOUS WASTE” (’85)
• BEACH WASHUPS & DISPOSAL INCIDENCES (’86-’86)BEACH WASHUPS & DISPOSAL INCIDENCES (’86-’86)
• MED WASTE DISPOSAL INDUSTRY DEVELOPEDMED WASTE DISPOSAL INDUSTRY DEVELOPED
• DEVELOPMENT OF ALTERNATE TREATMENT DEVELOPMENT OF ALTERNATE TREATMENT TECHNOLOGIES TECHNOLOGIES
ECOS 11
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSAL
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & 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
HOW DID THESE ISSUES EVOLVE?
MID-1990s – 2005:
• CLEAN AIR ACT AMENDMENTS SHUT INCINERATORS
• MED WASTE DISPOSAL INDUSTRY CONSOLIDATES
• ALTERNATE TREATMENT TECHNOLOGIES FADE OUT
ECOS 12
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSALWASTE MANAGEMENT, WASTE MANAGEMENT,
TREATMENT & DISPOSALTREATMENT & DISPOSALWHAT DOES THE FUTURE HOLD?WHAT DOES THE FUTURE HOLD?
OFF-SITE DISPOSAL MONOPOLIES?OFF-SITE DISPOSAL MONOPOLIES?• Seem to be OccurringSeem to be Occurring• If So, Cost Escalations CertainIf So, Cost Escalations Certain• How High & How Fast?How High & How Fast?
VIABLE TREATMENT ALTERNATIVES?VIABLE TREATMENT ALTERNATIVES?• Hugh Decline in NumbersHugh Decline in Numbers• More than 190 of about 210 firms out of businessMore than 190 of about 210 firms out of business• Very few have as many as 5 years experienceVery few have as many as 5 years experience• Questionable Long-Range Vendor Survivability?Questionable Long-Range Vendor Survivability?
WHAT DOES THE FUTURE HOLD?WHAT DOES THE FUTURE HOLD?OFF-SITE DISPOSAL MONOPOLIES?OFF-SITE DISPOSAL MONOPOLIES?• Seem to be OccurringSeem to be Occurring• If So, Cost Escalations CertainIf So, Cost Escalations Certain• How High & How Fast?How High & How Fast?
VIABLE TREATMENT ALTERNATIVES?VIABLE TREATMENT ALTERNATIVES?• Hugh Decline in NumbersHugh Decline in Numbers• More than 190 of about 210 firms out of businessMore than 190 of about 210 firms out of business• Very few have as many as 5 years experienceVery few have as many as 5 years experience• Questionable Long-Range Vendor Survivability?Questionable Long-Range Vendor Survivability?
ECOS 13
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSAL
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSAL
WHAT HAPPENS FROM HERE?WHAT HAPPENS FROM HERE?
• Disposal Costs Increasingly DominateDisposal Costs Increasingly Dominate
• Disposal Options Continually Decline Disposal Options Continually Decline
• Future Changes Remain UncertainFuture Changes Remain Uncertain
• Continued Financial Difficulties For Continued Financial Difficulties For Many HospitalsMany Hospitals
WHAT HAPPENS FROM HERE?WHAT HAPPENS FROM HERE?
• Disposal Costs Increasingly DominateDisposal Costs Increasingly Dominate
• Disposal Options Continually Decline Disposal Options Continually Decline
• Future Changes Remain UncertainFuture Changes Remain Uncertain
• Continued Financial Difficulties For Continued Financial Difficulties For Many HospitalsMany Hospitals
ECOS 14
WASTE MANAGEMENT, WASTE MANAGEMENT, TREATMENT & DISPOSALTREATMENT & DISPOSALWASTE MANAGEMENT, WASTE MANAGEMENT,
TREATMENT & DISPOSALTREATMENT & DISPOSAL PRIMARY COST REDUCTION
OPPORTUNITIES
• WASTE MANAGEMENT PROGRAM WASTE MANAGEMENT PROGRAM IMPROVEMENTSIMPROVEMENTS
• ON-SITE MEDICAL WASTE TREATMENT ON-SITE MEDICAL WASTE TREATMENT
• SHARED SERVICE, CENTRALIZED OR SHARED SERVICE, CENTRALIZED OR REGIONAL TREATMENT FACILITYREGIONAL TREATMENT FACILITY
PRIMARY COST REDUCTION OPPORTUNITIES
• WASTE MANAGEMENT PROGRAM WASTE MANAGEMENT PROGRAM IMPROVEMENTSIMPROVEMENTS
• ON-SITE MEDICAL WASTE TREATMENT ON-SITE MEDICAL WASTE TREATMENT
• SHARED SERVICE, CENTRALIZED OR SHARED SERVICE, CENTRALIZED OR REGIONAL TREATMENT FACILITYREGIONAL TREATMENT FACILITY
ECOS 15
WASTE MANAGEMENT PROGRAM WASTE MANAGEMENT PROGRAM IMPROVEMENTS & IMPROVEMENTS &
OPTIMIZATIONOPTIMIZATIONCOST SAVINGS OPPORTUNITIES-COST SAVINGS OPPORTUNITIES-
• REDUCED MEDICAL WASTE GENERATION RATES50% or More Reduction Achievable
• REDUCED OFF-SITE DISPOSAL COSTSReduced Volumes and/or On-Site Treatment
• INCREASED RECYCLING BENEFITSIncreased 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
COST SAVINGS OPPORTUNITIES-COST SAVINGS OPPORTUNITIES-
• REDUCED MEDICAL WASTE GENERATION RATES50% or More Reduction Achievable
• REDUCED OFF-SITE DISPOSAL COSTSReduced Volumes and/or On-Site Treatment
• INCREASED RECYCLING BENEFITSIncreased 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
ECOS 16
WASTE MANAGEMENT WASTE MANAGEMENT PROGRAM IMPROVEMENTS & PROGRAM IMPROVEMENTS &
OPTIMIZATIONOPTIMIZATION
WASTE MANAGEMENT WASTE MANAGEMENT PROGRAM IMPROVEMENTS & PROGRAM IMPROVEMENTS &
OPTIMIZATIONOPTIMIZATION
OTHER BENEFITS-
• Reduced Hazardous Material Use/Disposal
• Liability Containment & Averted Fines• Increased Operational Efficiencies• Demonstrated Corporate
Responsibility• Positive Public Image• Continuous Quality Improvements
OTHER BENEFITS-
• Reduced Hazardous Material Use/Disposal
• Liability Containment & Averted Fines• Increased Operational Efficiencies• Demonstrated Corporate
Responsibility• Positive Public Image• Continuous Quality Improvements
ECOS 17
WASTE MANAGEMENT PROGRAM WASTE MANAGEMENT PROGRAM IMPROVEMENTS & IMPROVEMENTS &
OPTIMIZATIONOPTIMIZATION
WASTE MANAGEMENT PROGRAM WASTE MANAGEMENT PROGRAM IMPROVEMENTS & IMPROVEMENTS &
OPTIMIZATIONOPTIMIZATIONIMPLEMENTATION STEPS-IMPLEMENTATION STEPS-11.. WASTE MANAGEMENT PROGRAM SURVEY & ASSESSMENTSWASTE MANAGEMENT PROGRAM SURVEY & ASSESSMENTS
• All Waste Streams, Practices & ProceduresAll Waste Streams, Practices & Procedures• Generation Rates; Segregation Efficiencies; Adherence to P&PGeneration Rates; Segregation Efficiencies; Adherence to P&P
2.2. IDENTIFY IMPROVEMENTS & COST SAVINGS OPPORTUNITIESIDENTIFY IMPROVEMENTS & COST SAVINGS OPPORTUNITIES• Identify/Evaluate Options & AlternativesIdentify/Evaluate Options & Alternatives• Volume/Generation Reduction; Recycling/Reuse; Haz Waste/Material Volume/Generation Reduction; Recycling/Reuse; Haz Waste/Material
Reduction; Etc.Reduction; Etc.• Set Goals & Establish Milestone Progress TargetsSet Goals & Establish Milestone Progress Targets
3.3. IMPLEMENT PROGRAM IMPROVEMENTSIMPLEMENT PROGRAM IMPROVEMENTS• New/Revised Policies, Procedure & Program ManualsNew/Revised Policies, Procedure & Program Manuals• Employee/Staff TrainingEmployee/Staff Training
4.4. PROGRAM ADMINISTRATION & OVERSIGHTPROGRAM ADMINISTRATION & OVERSIGHT
5.5. MONITORING & FOLLOW-UPMONITORING & FOLLOW-UP
IMPLEMENTATION STEPS-IMPLEMENTATION STEPS-11.. WASTE MANAGEMENT PROGRAM SURVEY & ASSESSMENTSWASTE MANAGEMENT PROGRAM SURVEY & ASSESSMENTS
• All Waste Streams, Practices & ProceduresAll Waste Streams, Practices & Procedures• Generation Rates; Segregation Efficiencies; Adherence to P&PGeneration Rates; Segregation Efficiencies; Adherence to P&P
2.2. IDENTIFY IMPROVEMENTS & COST SAVINGS OPPORTUNITIESIDENTIFY IMPROVEMENTS & COST SAVINGS OPPORTUNITIES• Identify/Evaluate Options & AlternativesIdentify/Evaluate Options & Alternatives• Volume/Generation Reduction; Recycling/Reuse; Haz Waste/Material Volume/Generation Reduction; Recycling/Reuse; Haz Waste/Material
Reduction; Etc.Reduction; Etc.• Set Goals & Establish Milestone Progress TargetsSet Goals & Establish Milestone Progress Targets
3.3. IMPLEMENT PROGRAM IMPROVEMENTSIMPLEMENT PROGRAM IMPROVEMENTS• New/Revised Policies, Procedure & Program ManualsNew/Revised Policies, Procedure & Program Manuals• Employee/Staff TrainingEmployee/Staff Training
4.4. PROGRAM ADMINISTRATION & OVERSIGHTPROGRAM ADMINISTRATION & OVERSIGHT
5.5. MONITORING & FOLLOW-UPMONITORING & FOLLOW-UP
ECOS 18
WASTE MANAGEMENT PROGRAM WASTE MANAGEMENT PROGRAM IMPROVEMENTS & IMPROVEMENTS &
OPTIMIZATIONOPTIMIZATION
WASTE MANAGEMENT PROGRAM WASTE MANAGEMENT PROGRAM IMPROVEMENTS & IMPROVEMENTS &
OPTIMIZATIONOPTIMIZATIONHOW MUCH MEDICAL WASTE IS GENERATEDHOW MUCH MEDICAL WASTE IS GENERATED
IN A “TYPICAL” HOSPITAL?IN A “TYPICAL” HOSPITAL?
SURVEY DATASURVEY DATA
SURVEYED FACILITIESSURVEYED FACILITIES• 129 Hospitals Nationwide @ 43,000 Beds (Randomly 129 Hospitals Nationwide @ 43,000 Beds (Randomly
Selected)Selected)• 240 Million Lb/Yr Total Waste; 46 Million Lb/Yr “Red 240 Million Lb/Yr Total Waste; 46 Million Lb/Yr “Red
Bag” WasteBag” Waste
SURVEY RESULT SUMMARYSURVEY RESULT SUMMARY• ““Red Bag” Waste Generation Range: 0.10% to 92.7%Red Bag” Waste Generation Range: 0.10% to 92.7%• ““Red Bag” Waste Generation Average: 19.5%Red Bag” Waste Generation Average: 19.5%• 77% of Facilities Outside of 10% to 15% Range77% of Facilities Outside of 10% to 15% Range
HOW MUCH MEDICAL WASTE IS GENERATEDHOW MUCH MEDICAL WASTE IS GENERATED IN A “TYPICAL” HOSPITAL?IN A “TYPICAL” HOSPITAL?
SURVEY DATASURVEY DATA
SURVEYED FACILITIESSURVEYED FACILITIES• 129 Hospitals Nationwide @ 43,000 Beds (Randomly 129 Hospitals Nationwide @ 43,000 Beds (Randomly
Selected)Selected)• 240 Million Lb/Yr Total Waste; 46 Million Lb/Yr “Red 240 Million Lb/Yr Total Waste; 46 Million Lb/Yr “Red
Bag” WasteBag” Waste
SURVEY RESULT SUMMARYSURVEY RESULT SUMMARY• ““Red Bag” Waste Generation Range: 0.10% to 92.7%Red Bag” Waste Generation Range: 0.10% to 92.7%• ““Red Bag” Waste Generation Average: 19.5%Red Bag” Waste Generation Average: 19.5%• 77% of Facilities Outside of 10% to 15% Range77% of Facilities Outside of 10% to 15% Range
ECOS 19
WASTE MANAGEMENT PROGRAM WASTE MANAGEMENT PROGRAM IMPROVEMENTS & OPTIMIZATIONIMPROVEMENTS & OPTIMIZATIONWASTE MANAGEMENT PROGRAM WASTE MANAGEMENT PROGRAM IMPROVEMENTS & OPTIMIZATIONIMPROVEMENTS & OPTIMIZATION
WHY SUCH A LARGE DEVIATION?WHY SUCH A LARGE DEVIATION?
UNINTENTIONALUNINTENTIONAL• MismanagementMismanagement• Regulatory MisinterpretationsRegulatory Misinterpretations• Unfamiliarity of AlternativesUnfamiliarity of Alternatives
INTENTIONALINTENTIONAL• Rational AnalysesRational Analyses• Comparison of On-Site vs. Off-Site OptionsComparison of On-Site vs. Off-Site Options
WHY SUCH A LARGE DEVIATION?WHY SUCH A LARGE DEVIATION?
UNINTENTIONALUNINTENTIONAL• MismanagementMismanagement• Regulatory MisinterpretationsRegulatory Misinterpretations• Unfamiliarity of AlternativesUnfamiliarity of Alternatives
INTENTIONALINTENTIONAL• Rational AnalysesRational Analyses• Comparison of On-Site vs. Off-Site OptionsComparison of On-Site vs. Off-Site Options
ECOS 20
WASTE MANAGEMENT PROGRAM WASTE MANAGEMENT PROGRAM IMPROVEMENTS & IMPROVEMENTS &
OPTIMIZATIONOPTIMIZATION
WASTE MANAGEMENT PROGRAM WASTE MANAGEMENT PROGRAM IMPROVEMENTS & IMPROVEMENTS &
OPTIMIZATIONOPTIMIZATIONFACTORS AFFECTING INDIVIDUAL HOSPITAL FACTORS AFFECTING INDIVIDUAL HOSPITAL
WASTE GENERATION RATES-WASTE GENERATION RATES-
1.1. Regulatory Definitions Regulatory Definitions
2.2. Regulatory Interpretations Regulatory Interpretations
3.3. Waste Management Policies & Waste Management Policies & ProtocolsProtocols
4.4. Waste Management Practices & Waste Management Practices & EfficienciesEfficiencies
5.5. Hauler/Disposal Restrictions Hauler/Disposal Restrictions
FACTORS AFFECTING INDIVIDUAL HOSPITAL FACTORS AFFECTING INDIVIDUAL HOSPITAL WASTE GENERATION RATES-WASTE GENERATION RATES-
1.1. Regulatory Definitions Regulatory Definitions
2.2. Regulatory Interpretations Regulatory Interpretations
3.3. Waste Management Policies & Waste Management Policies & ProtocolsProtocols
4.4. Waste Management Practices & Waste Management Practices & EfficienciesEfficiencies
5.5. Hauler/Disposal Restrictions Hauler/Disposal Restrictions
ECOS 21
MEDICAL WASTE TREATMENT & MEDICAL WASTE TREATMENT & DISPOSAL ALTERNATIVESDISPOSAL ALTERNATIVES
MEDICAL WASTE TREATMENT & MEDICAL WASTE TREATMENT & DISPOSAL ALTERNATIVESDISPOSAL ALTERNATIVES
TREATMENT & DISPOSAL OPTIONS• Off-Site Contract Disposal• On-Site Treatment• Shared-Service, Centralized or Regional
Facility
ALTERNATIVE TREATMENT TECHNOLOGIES• Thermal• Chemical• Irradiation• Biological
TREATMENT & DISPOSAL OPTIONS• Off-Site Contract Disposal• On-Site Treatment• Shared-Service, Centralized or Regional
Facility
ALTERNATIVE TREATMENT TECHNOLOGIES• Thermal• Chemical• Irradiation• Biological
ECOS 22
MEDICAL WASTE TREATMENT & MEDICAL WASTE TREATMENT & DISPOSAL ALTERNATIVESDISPOSAL ALTERNATIVES
MEDICAL WASTE TREATMENT & MEDICAL WASTE TREATMENT & DISPOSAL ALTERNATIVESDISPOSAL 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
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
ECOS 23
ON-SITE MEDICAL WASTE ON-SITE MEDICAL WASTE TREATMENT TECHNOLOGIESTREATMENT TECHNOLOGIES
ON-SITE MEDICAL WASTE ON-SITE MEDICAL WASTE TREATMENT TECHNOLOGIESTREATMENT TECHNOLOGIES
THERMAL TECHNOLOGIESTEMPERATURES 205F TO 20,000F
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
THERMAL TECHNOLOGIESTEMPERATURES 205F TO 20,000F
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
ECOS 24
ON-SITE MEDICAL WASTE ON-SITE MEDICAL WASTE TREATMENT TECHNOLOGIESTREATMENT TECHNOLOGIES
ON-SITE MEDICAL WASTE ON-SITE MEDICAL WASTE TREATMENT TECHNOLOGIESTREATMENT TECHNOLOGIES
OTHER TECHNOLOGIESChemical (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
OTHER TECHNOLOGIESChemical (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
ECOS 25
EVALUATING ALTERNATE EVALUATING ALTERNATE TREATMENT TECHNOLOGIESTREATMENT TECHNOLOGIESEVALUATING ALTERNATE EVALUATING ALTERNATE
TREATMENT TECHNOLOGIESTREATMENT 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
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
ECOS 26
EVALUATING ALTERNATE EVALUATING ALTERNATE TREATMENT TECHNOLOGIESTREATMENT TECHNOLOGIESEVALUATING ALTERNATE EVALUATING ALTERNATE
TREATMENT TECHNOLOGIESTREATMENT TECHNOLOGIES
KEY EVALUATION CRITERIA
1. Demonstrated Performance2. Technical & Performance Criteria3. Vendor Qualifications4. Environmental & Permitting Issues5. Occupational Health & Safety
Issues6. Facility & Infrastructure
Requirements7. Economics
KEY EVALUATION CRITERIA
1. Demonstrated Performance2. Technical & Performance Criteria3. Vendor Qualifications4. Environmental & Permitting Issues5. Occupational Health & Safety
Issues6. Facility & Infrastructure
Requirements7. Economics
ECOS 27
EVALUATING ALTERNATE EVALUATING ALTERNATE TREATMENT TECHNOLOGIESTREATMENT TECHNOLOGIESEVALUATING ALTERNATE EVALUATING ALTERNATE
TREATMENT TECHNOLOGIESTREATMENT TECHNOLOGIESWHAT 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
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
ECOS 30
LOADING OF BINS INTO AUTOCLAVE TREATMENT
CHAMBER
LOADING OF BINS INTO AUTOCLAVE TREATMENT
CHAMBER
ECOS 32
SHARED-SERVICE, CENTRALIZED & REGIONAL TREATMENT
FACILITIES
SHARED-SERVICE, CENTRALIZED & REGIONAL TREATMENT
FACILITIESCOMBINED 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• Combination (depending on risks, control, profits)• Split/program components: transport & treatment
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• Combination (depending on risks, control, profits)• Split/program components: transport & treatment
ECOS 33
WASTE MANAGEMENT AS PART OF WASTE MANAGEMENT AS PART OF A COMPREHENSIVE A COMPREHENSIVE
ENVIRONMENTAL COMPLIANCE ENVIRONMENTAL COMPLIANCE PROGRAMPROGRAM
WASTE MANAGEMENT AS PART OF WASTE MANAGEMENT AS PART OF A COMPREHENSIVE A COMPREHENSIVE
ENVIRONMENTAL COMPLIANCE ENVIRONMENTAL COMPLIANCE PROGRAMPROGRAM
SHOULD HEALTHCARE SHOULD HEALTHCARE
EXECUTIVES WORRY ABOUT EXECUTIVES WORRY ABOUT ENVIRONMENTAL COMPLIANCE?ENVIRONMENTAL COMPLIANCE?
SHOULD HEALTHCARE SHOULD HEALTHCARE
EXECUTIVES WORRY ABOUT EXECUTIVES WORRY ABOUT ENVIRONMENTAL COMPLIANCE?ENVIRONMENTAL COMPLIANCE?
ECOS 34
THE RISKS OF POOR THE RISKS OF POOR ENVIRONMENTAL COMPLIANCEENVIRONMENTAL COMPLIANCE
THE RISKS OF POOR THE RISKS OF POOR ENVIRONMENTAL COMPLIANCEENVIRONMENTAL 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
• 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
ECOS 35
MAJOR ENVIRONMENTAL MAJOR ENVIRONMENTAL REGULATIONS AFFECTING REGULATIONS AFFECTING
HOSPITALSHOSPITALS
MAJOR ENVIRONMENTAL MAJOR ENVIRONMENTAL REGULATIONS AFFECTING REGULATIONS AFFECTING
HOSPITALSHOSPITALS• 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
• 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
ECOS 36
HOSPITAL ENVIRONMENTAL COMPLIANCE CHALLENGES
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
• 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
ECOS 37
EPA’S “AUDIT POLICY”EPA’S “AUDIT POLICY”
“Incentives for Self-Policing: Discovery, Disclosure,
Correction & Prevention Of Violations”
Effective May 2000
“Incentives for Self-Policing: Discovery, Disclosure,
Correction & Prevention Of Violations”
Effective May 2000
ECOS 38
EPA’S INITIATIVES & ACTIONS
EPA’S 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
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
ECOS 39
EPA REGION 1 INITIATIVE STATUS AS OF JULY 2005EPA 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
• 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
ECOS 40
SUMMARY OF EPA REGION 1 VIOLATIONS
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%
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%
ECOS 41
SUMMARY OF EPA REGION 1 VIOLATIONS
SUMMARY OF EPA REGION 1 VIOLATIONS
TOP 9 VIOLATIONS FROM 59 RESOLVED VOLUNTARY
DISCLOSURES VIOLATIONS ACTS FREQUENCY
1. ID of HW RCRA 922. Universal Waste RCRA 663. Chemical Inventory EPCRA 484. SIP Requirements CAA 485. SPCC CWA 446. Labeling RCRA 357. CFC Leak Detection CAA 328. MSDA Records EPCRA 309. Manifests RCRA 30
TOP 9 VIOLATIONS FROM 59 RESOLVED VOLUNTARY
DISCLOSURES VIOLATIONS ACTS FREQUENCY
1. ID of HW RCRA 922. Universal Waste RCRA 663. Chemical Inventory EPCRA 484. SIP Requirements CAA 485. SPCC CWA 446. Labeling RCRA 357. CFC Leak Detection CAA 328. MSDA Records EPCRA 309. Manifests RCRA 30
ECOS 42
SUMMARY OF EPA REGION 1 HEALTHCARE RCRA VIOLATIONS
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%
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%
ECOS 43
TYPICAL RCRA VIOLATIONS IN THE HEALTHCARE
INDUSTRY
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
• 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