ecos1 waste management issues for new england hospitals & helathcare facilities presented by...

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


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



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



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



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



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



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



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



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 &


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




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




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




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


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



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


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



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


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


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 28

CONVENTIONAL STEAM AUTOCLAVE

CONVENTIONAL STEAM AUTOCLAVE

ECOS 29

AUTOCLAVE WITH BINS IN FRONT OF LOADING DOOR

AUTOCLAVE WITH BINS IN FRONT OF LOADING DOOR

ECOS 30

LOADING OF BINS INTO AUTOCLAVE TREATMENT

CHAMBER

LOADING OF BINS INTO AUTOCLAVE TREATMENT

CHAMBER

ECOS 31

MOVING BIN TO COMPACTOR DUMPER

MOVING BIN TO COMPACTOR DUMPER

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


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



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

ECOS 44

SUMMARY,SUMMARY,QUESTION & QUESTION & DISCUSSIONSDISCUSSIONS

SUMMARY,SUMMARY,QUESTION & QUESTION & DISCUSSIONSDISCUSSIONS

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