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WASTE MANAGEMENT ISSUES FOR NEW ENGLAND HOSPITALS & HELATHCARE FACILITIES. Presented by Larry Doucet, P.E., DEE To The ENVIRONMENTAL BUSINESS COUNCIL OF NEW ENGLAND. WASTE MANAGEMENT ISSUES & CONCERNS FACING TODAY’S HOSPITALS: CONTROLS, COSTS & COMPLIANCE.
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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
WASTE MANAGEMENT ISSUES & CONCERNS FACING TODAY’S HOSPITALS:CONTROLS, COSTS & COMPLIANCE ECOS
WASTE MANAGEMENT, TREATMENT & DISPOSAL KEY ISSUES & CONCERNS FACING TODAY’S HOSPITALS • Higher & Rising Costs • Fewer & Shrinking Options • Increasing Compliance Difficulties ECOS
WASTE MANAGEMENT, TREATMENT & DISPOSAL 1. HIGHER & RISING COSTS • Uncontrolled & Limitless • Major Bottom-line Impacts • No Capital Dollars for a Solution ECOS
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 ECOS
WASTE MANAGEMENT, TREATMENT & DISPOSAL 3. INCREASING COMPLIANCE DIFFICULTIES a. Expanded EPA Compliance Audits b. JCAHO Environment Of CareCompliance c. On-going Off-site Disposal Liabilities d. Image & Relations to Public, Patients & Staff ECOS
2005 MARKS THE 35 ANNIVERSARY OF MEDICAL WASTE EMERGENCE AS AN IMPORTANT ISSUE FOR HOSPITALS & HEALTHCARE FACILITIES ECOS
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) ECOS
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 ECOS
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 ECOS
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? ECOS
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 ECOS
WASTE MANAGEMENT, TREATMENT & DISPOSAL PRIMARY COST REDUCTION OPPORTUNITIES • WASTE MANAGEMENT PROGRAM IMPROVEMENTS • ON-SITE MEDICAL WASTE TREATMENT • SHARED SERVICE, CENTRALIZED OR REGIONAL TREATMENT FACILITY ECOS
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 ECOS
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 ECOS
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 ECOS
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 ECOS
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 ECOS
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 ECOS
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 ECOS
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 ECOS
ON-SITE MEDICAL WASTE TREATMENT TECHNOLOGIES THERMAL TECHNOLOGIES TEMPERATURES 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
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 ECOS
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 ECOS
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 ECOS
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 ECOS
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 ECOS
WASTE MANAGEMENT AS PART OF A COMPREHENSIVE ENVIRONMENTAL COMPLIANCE PROGRAM SHOULD HEALTHCARE EXECUTIVES WORRY ABOUT ENVIRONMENTAL COMPLIANCE? ECOS
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 ECOS
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 ECOS
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 ECOS
EPA’S “AUDIT POLICY” “Incentives for Self-Policing: Discovery, Disclosure, Correction & Prevention Of Violations” Effective May 2000 ECOS
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 ECOS
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 ECOS
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% ECOS
SUMMARY OF EPA REGION 1 VIOLATIONS TOP 9 VIOLATIONS FROM 59 RESOLVED VOLUNTARY DISCLOSURES VIOLATIONSACTSFREQUENCY • 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 ECOS
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% ECOS
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 ECOS