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Multi-Year Integrated Strategy for Funeral Home Compliance with the Safe Drinking Water Act

Multi-Year Integrated Strategy for Funeral Home Compliance with the Safe Drinking Water Act. Presented by: Margaret Halley, EPA Region 2 Division of Enforcement and Compliance Assistance. Mandate of EPA’s UIC Program is to protect Underground Sources of Drinking Water. Suffolk County, NY.

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Multi-Year Integrated Strategy for Funeral Home Compliance with the Safe Drinking Water Act

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  1. Multi-Year Integrated Strategy for Funeral Home Compliancewith theSafe Drinking Water Act Presented by: Margaret Halley, EPA Region 2 Division of Enforcement and Compliance Assistance

  2. Mandate of EPA’s UIC Program is to protect Underground Sources of Drinking Water

  3. Suffolk County, NY • Population of nearly 1,500,000 • 912 square miles • All potable water from federally designated Sole Source Aquifer • Two-thirds (2/3) of the county with no sewer access • Primarily septic systems and cesspools • An estimated eighty funeral homes with on-site disposal systems

  4. Long Island, NY

  5. Exterior of Funeral Home

  6. Element 1: Develop a Statement of the Environmental Problem and Justification • Embalming waste fluids disposal to on-site waste system • Sampling and analysis results: • Embalming chemicals • chlorinated solvents • formaldehyde • phenol

  7. Element 2: Establish Goals and Measures • Bring funeral homes into compliance with UIC regulations in Suffolk County • Compliance Assistance • Voluntary Compliance • Inspections and Enforcement • Number with on-site embalming and injection • Voluntarily ceasing injection • Large Capacity Septic Systems • Seepage pits • Leachfields • Large Capacity Cesspools • Install septic system • Require soil clean-up in the seepage pit(s) • Set target dates for completion of goals

  8. Prep Room

  9. Element 3: Selecting and Sequencing Tools • Tools and Sequencing • Data • Compliance Assistance • Compliance Monitoring • Enforcement • Compliance • Compliance as Part of Doing Business

  10. Element 4: Establish roles and Assign Responsibilities • Internal strategy was to maximize UIC inspector resources • External strategy was to establish working relationships with local and state governments, and with national, state and local funeral home trade organizations

  11. Element 5: Develop an Implementation Plan, Schedule, and Milestones • Identify facilities with no sewer access – 61targeted • July, 2006, selected as three-day inspection initiative with overnight stay • Three teams of two inspectors, each to inspect at least 30 funeral homes (10 per day) • Hold meetings with inspectors • Clarify issues specific to funeral homes • Distribute inspection materials • Communicate how to follow-up • Determine: • Number with on-site injection of embalming fluids • Number with large capacity septic systems (over 20 uses per day),Number with large capacity cesspools (over 20 uses per day), banned as of April 5, 2005 • Number ceasing injection – 100 % because of innovative technology • Number requiring cesspool/seepage pit clean-up

  12. Remedial soil excavation of funeral home cesspool contaminated withchlorinated solvents, formaldehyde and phenol

  13. Element 6: Designing Resources/Workforce Deployment • 24 funeral homes remained to be inspected • Inspectors’ workloads deemed heavy • Individual inspectors, not teams • Day trips • No overnight stays because of funding reduction

  14. Element 7: Communicating the Strategy • EPA Region 2 website: www.epa.gov/region02/water/compliance • New York State Funeral Directors Association (NYSFDA) diligent in outreach to members to advocate use of new technology to assist UIC compliance • Encourage the NYSFDA in its efforts • Region 2 awarded NYSFDA with 2006 National Water Efficiency Leader Award and 2007 Region 2 Environmental Quality Award for their outreach efforts.

  15. Element 8: Monitoring and Evaluating the Strategy • Lab data = foundation • Good relationships with state and local governments critical as regulators & facilitators of EPA effort • Communicating with trade organizations a success • Increased UIC compliance • Implementation of innovative hold and haul technology, while concurrently reducing water consumption, from the traditional 120 gallons per embalming to only 5 gallons per embalming • Capacity building for compliance of funeral homes in rural areas of NYS obstacles because new technology not yet readily available

  16. Element 9: Exiting the Strategy • Inspections completed as of April 30, 2008 • Follow-up compliance orders to be completed by September 30, 2008

  17. Medical Waste Blood Storage Box Waterless Aspiration Utilized

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