Environmental Quality Assurance and Compliance at Medical and Dental Treatment Facilities

1. Environmental Quality Assurance and Compliance at Medical and Dental Treatment Facilities ENVIRONMENTAL PROGRAMS DIRECTORATE BUMED ENVIRONMENTAL QUALITY

2. INTRODUCTION • Mr. Bill Rogers BUMED Environmental Manager • (757) 953-9035 or DSN 377-5558 • Fax: 757-953-0675 • E-mail: rogersw@nehc.med.navy.mil • 620 John Paul Jones Cir, Portsmouth, VA, 23708-2103

3. NAVY ENVIRONMENTAL HEALTH CENTER COMMANDING OFFICER CAPT S. SACK MC, USN ENVIRONMENTAL PROGRAMS DIRECTOR CAPT C. RENNIX MSC, USN PUBLIC HEALTH SUPPORT ENGINEERING SUPPORT HEALTH/RISK ASSESSMENT BUMED CLAIMANCY ENVIRONMENTAL QUALITY MR. W. R. ROGERS GS - 13 BRAC SUPPORT RISK ASSESSMENT ENVIRONMENTAL ENGINEER LT C. ZHANG CEC, USN TECHNICAL TRAINING HEALTH AND SAFETY ENVIRONMENTAL PROGRAMSORGANIZATIONAL DIAGRAM

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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)

11. PROGRAM ORGANIZATION • HEADQUARTERS • HEALTHCARE SUPPORT OFFICES • ACTIVITIES

12. 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

13. Who is Conducting the Program? I.Activity Annual Self EQA’s by Base Staff • Format Established by Activity • Includes Tenants • Developed from Activity Internal Assessment Plan (IAP) II.Major Claimant EQA’s • Performed by Major Claimant Staff (Includes Tenants) (For Most, EFD/A’s 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)

14. 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

15. 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.

16. MOST COMMON EQA FINDINGS(CONTINUED) • POTABLE WATER • Priority sampling for lead and copper. • Inadequate Backflow Prevention Program. • Sampling Siting Plan is not developed.

17. MOST COMMON EQA FINDINGS(CONTINUED) • POLICY • Not performing Self-Environmental Quality Assessments (EQA’s). • 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)

18. 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).

19. 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 (MSDS’s).

20. 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

21. 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

22. 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)

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

24. 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

25. FUNDING SOURCESfor Environmental Projects • Major Claimant • Activity • Centrally Managed NAVFAC Funds

26. 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

27. 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

28. 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

29. 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

30. 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/shoreg2.htm • http://clean.rti.org/larry/haz9.htm • BUMED Environmental Management System (EMS) Program • http://www-nehc.med.navy.mil/ep/bumed_ems.htm

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