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WASTE MANAGEMENT ISSUES FOR NEW ENGLAND HOSPITALS & HELATHCARE FACILITIES

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

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  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 ECOS

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

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

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

  6. 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

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

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

  28. CONVENTIONAL STEAM AUTOCLAVE ECOS

  29. AUTOCLAVE WITH BINS IN FRONT OF LOADING DOOR ECOS

  30. LOADING OF BINS INTO AUTOCLAVE TREATMENT CHAMBER ECOS

  31. MOVING BIN TO COMPACTOR DUMPER 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 ECOS

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

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

  41. 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

  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% 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 ECOS

  44. SUMMARY,QUESTION & DISCUSSIONS ECOS

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