New regulations to affect medical waste incinerations.
Hospitals will likely seek disposal option alternatives.
After more than two years of consideration and several mixed signals over potential regulatory outcomes, the U.S. Environmental Protection Agency Environmental Protection Agency (EPA), independent agency of the U.S. government, with headquarters in Washington, D.C. It was established in 1970 to reduce and control air and water pollution, noise pollution, and radiation and to ensure the safe handling and (EPA EPA eicosapentaenoic acid.
n.pr See acid, eicosapentaenoic.
n. ) has finalized See finalization. a regulation that will significantly alter the way that thousands of U.S. health care facilities dispose of their solid waste. The new regulation was signed into law by the EPA's administrator Carol Browner on August 15 and will force thousands of hospitals, clinics and other health care facilities around the country to either shut down their incinerators or add extremely expensive emission control The selective and controlled use of electromagnetic, acoustic, or other emitters to optimize command and control capabilities while minimizing, for operations security: a. detection by enemy sensors; b. mutual interference among friendly systems; and/or c. devices by the year 2002.
There are a few exemptions to these new requirements and certain small facilities that operate in rural areas of the country have been granted a bit of a break under the rules. But otherwise it is widely believed that the new regulation will ultimately result in the closure of at least 80% of the 2400 medical waste incinerators currently in operation. The rules will also make it very difficult - and very expensive - to open new medical waste incinerators in the future.
In addition to the expensive equipment requirements, the EPA will also now require that a "waste management plan" be developed by any health care facility that operates an incinerator incinerator, furnace for burning refuse. The older and simpler kind of incinerator was a brick-lined cell with a metal grate over a lower ash pit, with one opening in the top or side for loading and another opening in the side for removing incombustible masses called . These plans, which are to be submitted to the EPA as part of the permitting process, must outline efforts that these facilities will take to minimize the amount of solid waste that they generate.
Under provisions of the Federal Clean Air Act Amendments of 1990, Congress directed the EPA to regulate the emissions from virtually all incineration incineration
the act of burning to ashes. facilities and specifically required that the agency take early action on facilities that incinerate in·cin·er·ate
v. in·cin·er·at·ed, in·cin·er·at·ing, in·cin·er·ates
To cause to burn to ashes.
To burn completely. hospital, medical and infectious wastes. The EPA first proposed rules on the issue in 1995 (Capital Comments, NONWOVENS INDUSTRY, March 1995) that would have placed very restrictive emission control requirements on these facilities. In response to public comments received on that proposed rule, the agency changed course in mid-1996 and announced that it was considering significant changes to the proposal, which would have allowed most of these facilities to continue operations (Capital Comments, NONWOVENS INDUSTRY, April 1996).
In fact, the EPA noted on a June 20, 1996 Federal Register notice that information had been submitted indicating that the emission standards Emission standards are requirements that set specific limits to the amount of pollutants that can be released into the environment. Many emission standards focus on regulating pollutants released by automobiles (motor cars) and other powered vehicles but they can also regulate as originally proposed in 1995 might need to be revised and, consequently, many incinerators could likely continue operation with little or no add-on equipment requirements. In the same Federal Register notice, EPA also stated that it was "inclined" to adopt a fairly narrow definition of medical waste such that only 10-15% of the material typically incinerated in a health care facility would be subject to the new requirements. That is, if infectious or potentially infectious materials were segregated from the incinerator's waste stream, then the incinerator could continue to operate without having to meet the new standards. The EPA's logic was that "...noninfectious, municipal-type waste discarded dis·card
v. dis·card·ed, dis·card·ing, dis·cards
1. To throw away; reject.
a. To throw out (a playing card) from one's hand.
b. from healthcare facilities is considered part of the municipal waste stream and is covered by the regulations adopted for the burning of municipal waste." The EPA also made no specific mention of waste management plan requirements in either the 1995 or 1996 versions of the proposed rule.
Yet in the final version of the rule, the EPA disregarded its inclination inclination, in astronomy, the angle of intersection between two planes, one of which is an orbital plane. The inclination of the plane of the moon's orbit is 5°9' with respect to the plane of the ecliptic (the plane of the earth's orbit around the sun). to cover only infectious and potentially-infectious materials under the rule. Instead, the EPA adopted requirements that any incinerator operated by a health care facility - unless it meets one of the few exemptions listed under the regulation - must comply with stringent emission control standards, whether it is burning medical waste (i.e, infectious or potentially infectious), hospital waste (noninfectious materials such as those generated by administrative offices, cafeterias, etc.) or a combination of the two. According to according to
1. As stated or indicated by; on the authority of: according to historians.
2. In keeping with: according to instructions.
3. the EPA, this all-inclusive approach was put into the final rule in an effort to "avoid duplicative requirements" for municipal and medical waste incineration. But the practical result is that health care facilities will not be able to avoid the new requirements by diligently dil·i·gent
Marked by persevering, painstaking effort. See Synonyms at busy.
[Middle English, from Old French, from Latin d separating infectious materials from their incinerator waste streams.
As for equipment requirements, the final rule establishes emission control standards for all existing facilities that mandate the use of "good combustion practices" along with certain equipment. Facilities with a small burn capacity (i.e., 200 lbs/hour or less), for instance, will have to meet control standards that, based on current technology, can only be achieved through the use of a low efficiency wet scrubbing See data scrubbing, memory scrubbing and audio scrubbing. system. Existing facilities with a medium burn capacity (200-500 lbs/hour) will have to use a moderate efficiency wet scrubber Wet scrubber is a form of pollution control technology. The term describes a variety of devices that use pollutants from a furnace flue gas or from other gas streams. In a wet scrubber, the polluted gas stream is brought into contact with the scrubbing liquid, by spraying it with to meet these standards and existing facilities with a large burn capacity (more than 500 lbs/hour) will have to use a high efficiency wet scrubber. Good combustion practices basically require that materials be burned at high temperatures for long periods of time.
The EPA estimates that the cost of complying with these requirements by existing facilities will be somewhere between $59 and $120 million, but states that these facilities will likely adopt alternative waste disposal options as a less expensive means of complying with emission restrictions. Disposal alternatives cited by the EPA as being generally available to health care facilities include landfilling, autoclaving, microwave or macrowave irradiation irradiation /ir·ra·di·a·tion/ (i-ra?de-a´shun)
2. the dispersion of nervous impulse beyond the normal path of conduction.
3. , chemical treatment, thermal treatment Thermal treatment is a term given to any waste treatment technology that involves high temperatures in the processing of the waste feedstock. This commonly, although not exclusively involves the combustion of waste materials. or biological treatment. The agency also predicts that some health care facilities will find it more economical to divert di·vert
v. di·vert·ed, di·vert·ing, di·verts
1. To turn aside from a course or direction: Traffic was diverted around the scene of the accident.
2. their waste to large, commercial medical waste incinerators. For those facilities that decide to use alternative waste disposal techniques, the EPA estimates the average price increase will be less than 35 cents/patient day. This, of course, remains to be seen.
Exempt from the new emission control standards are "co-fired combusters" (those that burn 10% or less hospital and medical/infectious waste, by weight, along with other wastes) and incinerators that burn waste pharmaceuticals, pathological 1. pathological - [scientific computation] Used of a data set that is grossly atypical of normal expected input, especially one that exposes a weakness or bug in whatever algorithm one is using. wastes, chemotherapeutic wastes and low-level radioactive wastes Noun 1. low-level radioactive waste - (medicine) radioactive waste consisting of objects that have been briefly exposed to radioactivity (as in certain medical tests) . Cement kilns Cement kilns are used for the pyroprocessing stage of manufacture of Portland and other types of hydraulic cement, in which calcium carbonate reacts with silica-bearing minerals to form a mixture of calcium silicates. and pyrolysis py·rol·y·sis
Decomposition or transformation of a chemical compound caused by heat.
n treatment facilities that burn medical wastes are exempt as well. Also exempt from equipment requirements are facilities that burn no more than 2000 pounds per week and are located at least 50 miles from the nearest Standard Metropolitan Statistical Area boundary. These facilities, which the EPA estimates are responsible for the combustion of less than 1% of all hospital and medical waste, still must utilize good combustion practices and prepare a waste management plan.
This "small/rural" provision was included due to the EPA's concerns that these facilities might not have access to alternative means of waste disposal. The agency points out, however, that small/rural facilities will be subject to routine inspection and maintenance requirements and that good combustion practices alone will raise the cost of incineration such that other disposal alternatives, if available, are likely to be less expensive.
As for facilities built in the future, those that have a small burn capacity will have to meet emission control limits that require use of a moderate efficiency wet scrubber (equipment which, according to the EPA, is so expensive that it will make little economic sense to open any small facilities in the future). New facilities with a medium burn capacity will have to have a combined dry/wet control system without activated carbon and those with a large burn capacity will need a combined dry/wet scrubber system with activated carbon.
INDA filed comments with the EPA in 1995 and 1996 and is disappointed by a number of provisions contained in the final rule. Much of the economic impact on health care facilities predicted by the EPA is speculative and could turn out to be widely off the mark. Availability of alternative waste disposal options may not be as great as the EPA believes either.
But the waste management plan requirements contained in the final version of the rule are particularly troublesome because the EPA did not allow an opportunity for public comment on the issue. Drafting these plans will likely prove difficult for many health care facilities and may very well require that additional staff be hired. There is also the possibility that, as per the EPA's recommendation, these plans could be considered during the accreditation process. Yet even though the provision will be expensive and could potentially affect a hospital's accreditation, the EPA did not include the costs associated with these plans in its economic impact assessment of the final rule, nor did the agency provide a tremendous amount of detail on what it expects to be included in these. plans.
All in all, as the provisions of this new rule come into force, INDA will work with its member companies to help minimize any adverse impacts associated with its requirements. INDA's ultimate concern is that the safety of patients and health care providers is not compromised by the EPA's efforts to reduce incinerator emissions.
Peter Mayberry is the director of government affairs for INDA, Association of the Nonwoven non·wo·ven
Made by a process not involving weaving. Used of textiles.
Material or a fabric made by a process not involving weaving. Fabrics Industry. He works out of the law offices of Kutak Rock in Washington D.C. This Capital Comments column appears monthly in NONWOVENS INDUSTRY.