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WASTE MANAGEMENT ISSUES FOR NEW ENGLAND HOSPITALS HELATHCARE FACILITIES

ECOS. 2. WASTE MANAGEMENT ISSUES

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WASTE MANAGEMENT ISSUES FOR NEW ENGLAND HOSPITALS HELATHCARE FACILITIES

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    1. ECOS 1 WASTE MANAGEMENT ISSUES FOR NEW ENGLAND HOSPITALS & HELATHCARE FACILITIES Presented by Larry Doucet, P.E., DEE To The ENVIRONMENTAL BUSINESS COUNCIL OF NEW ENGLAND

    2. ECOS 2 WASTE MANAGEMENT ISSUES & CONCERNS FACING TODAY’S HOSPITALS: CONTROLS, COSTS & COMPLIANCE

    3. ECOS 3 WASTE MANAGEMENT, TREATMENT & DISPOSAL KEY ISSUES & CONCERNS FACING TODAY’S HOSPITALS Higher & Rising Costs Fewer & Shrinking Options Increasing Compliance Difficulties

    4. ECOS 4 WASTE MANAGEMENT, TREATMENT & DISPOSAL 1. HIGHER & RISING COSTS Uncontrolled & Limitless Major Bottom-line Impacts No Capital Dollars for a Solution

    5. ECOS 5 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

    6. ECOS 6 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

    7. ECOS 7 HOW AND WHEN DID THESE ISSUES & CONCERNS ARISE?

    8. ECOS 8 2005 MARKS THE 35 ANNIVERSARY OF MEDICAL WASTE EMERGENCE AS AN IMPORTANT ISSUE FOR HOSPITALS & HEALTHCARE FACILITIES

    9. ECOS 9 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) “Infectious Waste Guidelines” (’82 EPA Draft)

    10. ECOS 10 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 TECHNOLOGIES

    11. ECOS 11 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

    12. ECOS 12 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?

    13. ECOS 13 WASTE MANAGEMENT, TREATMENT & DISPOSAL WHAT HAPPENS FROM HERE? Disposal Costs Increasingly Dominate Disposal Options Continually Decline Future Changes Remain Uncertain Continued Financial Difficulties For Many Hospitals

    14. ECOS 14 WASTE MANAGEMENT, TREATMENT & DISPOSAL PRIMARY COST REDUCTION OPPORTUNITIES WASTE MANAGEMENT PROGRAM IMPROVEMENTS ON-SITE MEDICAL WASTE TREATMENT SHARED SERVICE, CENTRALIZED OR REGIONAL TREATMENT FACILITY

    15. ECOS 15 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

    16. ECOS 16 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

    17. ECOS 17 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 5. MONITORING & FOLLOW-UP

    18. ECOS 18 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

    19. ECOS 19 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

    20. ECOS 20 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

    21. ECOS 21 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

    22. ECOS 22 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; short & long-term

    23. ECOS 23 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

    24. ECOS 24 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

    25. ECOS 25 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

    26. ECOS 26 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 Requirements 7. Economics

    27. ECOS 27 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 needed

    28. ECOS 28 CONVENTIONAL STEAM AUTOCLAVE

    29. ECOS 29 AUTOCLAVE WITH BINS IN FRONT OF LOADING DOOR

    30. ECOS 30 LOADING OF BINS INTO AUTOCLAVE TREATMENT CHAMBER

    31. ECOS 31 MOVING BIN TO COMPACTOR DUMPER

    32. ECOS 32 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 Combination (depending on risks, control, profits) Split/program components: transport & treatment

    33. ECOS 33 WASTE MANAGEMENT AS PART OF A COMPREHENSIVE ENVIRONMENTAL COMPLIANCE PROGRAM SHOULD HEALTHCARE EXECUTIVES WORRY ABOUT ENVIRONMENTAL COMPLIANCE?

    34. ECOS 34 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

    35. ECOS 35 MAJOR ENVIRONMENTAL REGULATIONS AFFECTING HOSPITALS 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

    36. ECOS 36 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

    37. ECOS 37 EPA’S “AUDIT POLICY” “Incentives for Self-Policing: Discovery, Disclosure, Correction & Prevention Of Violations” Effective May 2000

    38. ECOS 38 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

    39. ECOS 39 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

    40. ECOS 40 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%

    41. ECOS 41 SUMMARY OF EPA REGION 1 VIOLATIONS TOP 9 VIOLATIONS FROM 59 RESOLVED VOLUNTARY DISCLOSURES VIOLATIONS ACTS FREQUENCY ID of HW RCRA 92 Universal Waste RCRA 66 Chemical Inventory EPCRA 48 SIP Requirements CAA 48 SPCC CWA 44 Labeling RCRA 35 CFC Leak Detection CAA 32 MSDA Records EPCRA 30 Manifests RCRA 30

    42. ECOS 42 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%

    43. ECOS 43 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

    44. ECOS 44 SUMMARY, QUESTION & DISCUSSIONS

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