Hazardous waste disposal
is a matter of intense concern to hospitals. Rising costs, rising
volumes, regulatory compliance requirements, worker exposure potential
and associated liability costs create a ‘perfect storm’ of concern in
this area. Often, much of the burden of reducing these costs falls on
those contracting for hazardous waste hauling and treatment services.
To some degree, hazardous
waste costs can be approached like any other contracting
opportunity – through volume contracting and strategic negotiations with
multiple vendors. By enlisting appropriate staff to inventory hazardous
waste generation by area and substance involved, a facility may be able
to aggregate wastes more effectively, cancel duplicate pickups in
different areas, and ensure that pickups are scheduled only when waste
volumes and waste regulations require them. The larger volumes created
through aggregation may also rate a better per unit pricing agreement
with your hazardous waste hauler.
Similarly, if you can
coordinate hauls among numerous facilities within a specific system, or
even collaborate with local facilities outside your system to negotiate
group hauling schedules and rates, you may be able to use increased
volume and reduced hauler runs to obtain more favorable pricing. (Of
course in any of these scenarios, you must work with your waste manager,
E&HS staff person or other staff responsible for regulatory compliance,
to ensure that you are following all legal requirements regarding
storage, mixing, and other handling of hazardous wastes.)
But these measures only
partly address the issue of hazardous materials and hazardous waste
volume and handling in hospitals, since costs for disposing of hazardous
wastes will almost certainly continue to rise. Along with negotiation
and aggregation efforts, hospitals must focus on source reduction –
eliminating the generation of hazardous waste wherever possible - if
they wish to effectively address the hazardous waste issue.
In our work with
healthcare facilities across the country, the Hospitals for a Healthy
Environment (H2E) program, has found that an increased focus on up-front
source reduction can uncover multiple opportunities to reduce or
eliminate hazardous wastes. A few of the more common strategies are
listed below, by department
In general:
• Establishing systems to ensure you buy only the amount needed of any
chemical that will require hazardous waste disposal is the most
comprehensive way to avoid unnecessary disposal costs. Avoid purchasing
in bulk to get better unit pricing – the disposal of unused material
will negate any up-front savings. Establish a policy requiring personnel
to estimate how much material they will actually use in their operations
before simply purchasing the container that is easiest to find.
• Using total cost
assessment to evaluate less toxic alternatives. Environmentally
preferable alternative products may cost more initially (though not all
do); but if they reduce the need for worker protection, eliminate the
possibility of accidental exposures or environmental releases, and are
not subject to hazardous waste disposal regulations/costs at end of
life, they may be more economical in the long run.
• Replacing all mercury
clinical devices with non-mercury alternatives eliminates the danger of
a mercury spill in your facility and the resultant hazardous waste
disposal costs. A spill may be an infrequent occurrence but can run into
very high costs, so equipping your facility with mercury-free devices
not only protects occupant health and the environment, but can eliminate
the potential for such a spike in waste costs.
• Establishing a
mercury-free purchasing policy will prevent the renewed presence of
mercury in your facility. Alternatives are available for all
mercury-containing devices commonly used in healthcare, and many GPOs
are setting mercury-free policies for their clinical device contracts.
For an excellent list of mercury-free clinical products, see
http://www.informinc.org/
fsmerchealth.pdf.
• Eliminating unnecessary
use of aerosols will reduce the need to dispose of aerosol cans. If such
cans contain flammable propellant or listed hazardous wastes, they must
be treated as hazardous waste, and facilities often opt to simply send
all aerosols out as hazardous rather than evaluating each can. In most
instances pump dispensers can be substituted for aerosols with no
hardship, so establishing an aerosol-free purchasing policy (with
exemptions where a case can be made for the aerosol) can significantly
reduce this waste stream.
In the laboratory:
• Installing solvent recovery systems in laboratories can significantly
reduce the volume and costs of hazardous solvent disposal. This strategy
also reduces purchase of incoming solvents, typically alcohol and xylene,
which increases the cost savings.
• Adopting non-hazardous
reagent or fixative substitutes – for example, the substitution of
sodium laurel sulfate for cyanide in automated hemoglobin analysis, or
the use of glacial acetic acid instead of Bouins fixative for certain
biopsies - may allow lab technicians to make major reductions in their
hazardous waste generation.
• Purchasing analytical
devices that consume less (or no) hazardous reagent enables hazardous
waste reductions. When purchasing analytical equipment, require vendors
to provide information on the volume of reagent used and disposed per
sample, and whether used reagent qualifies as a hazardous waste. Where
performance characteristics are equal, purchasing equipment that
eliminates or reduces hazardous material use may result in significant
reductions in chemical purchase and disposal costs over the life of the
equipment. 1
• Establishing a
materials exchange for reagents, fixatives and other chemicals between
your labs can reduce the disposal of chemicals by allowing other labs to
make use of something a particular lab no longer needs. Especially in
research labs, the volume of chemicals disposed after a single procedure
or series of procedures can be substantial. Your materials exchange can
be as simple as an email list where staff can post their ‘leftovers’
information.
In sterile processing:
• Replacing the use of Ethylene Oxide (EtO) with other sterilization
methods.
The first step in
reducing EtO consumption and waste is to analyze whether specific
instruments need to be sterilized or whether they can be high level
disinfected instead. This may eliminate significant usage. Following
this process, consider adopting in-house sterilization methods that use
less hazardous chemicals (peracetic acid, hydrogen peroxide) or physical
methods (steam, dry heat) for sterilization. Together, these approaches
can reduce the potential for serious toxic chemical exposure for your
employees, and reduce the volume of any EtO waste as well. 2
In the maintenance department:
• Eliminating mercury in building supplies minimizes risks and disposal
costs. Thermostats, flow controls, tilt switches and other building
control devices can contain grams to pounds of mercury. If these devices
are broken in use, or upon removal, they can trigger mercury spill
procedures and high disposal costs. In addition, when such devices are
removed en masse for renovation, they may trigger hazardous waste
requirements. By establishing a mercury-free building supply policy to
be applied wherever possible, these costs can be avoided. (Some older
devices may require mercury components – by labeling all such devices,
you can ensure they are treated with care upon removal to avoid spills.)
• Eliminating or
significantly reducing pesticide use can shrink an entire category of
hazardous waste disposal. Many health care facilities now contract out
their pest control services, but if you still have staff treating your
buildings and grounds with pesticides, you probably have unused or
outdated pesticides on site which must be treated as hazardous or
universal waste. By adopting Integrated Pest Management (IPM), where the
focus is on pest prevention, and first line treatment focuses on
chemical-free management strategies, you can almost entirely eliminate
the disposal costs associated with pesticide use. (In addition, IPM can
eliminate considerable costs related to worker protection and training,
and special storage and mixing facilities for pesticides.)
• Preferring latex paints
over oil-based, since dried latex paint residues are not regulated as
hazardous, can reduce volumes of paint waste that have to be disposed
separately from solid waste.
• Eliminating use of
hazardous solvents for parts cleaning operations in fleet maintenance
can reduce the need for hazardous waste disposal in your garage. Steam
cleaning units can replace the halogenated solvents ordinarily used for
parts and surface cleaning and degreasing. Various other systems can
recycle solvents - some companies lease parts washing systems and take
back and recycle solvent for reuse in their equipment.
The overall principles
underlying all these options are clear, and can inform your general
approach to purchasing and materials management: Buy what you need, buy
the least toxic option available, judge pricing by total cost, and raise
awareness so that your facility staff understand their role in reducing
hazardous waste volumes BEFORE the waste is generated. By taking
advantage of even a few of these opportunities to avoid introducing
materials into your facility that will have to leave it as hazardous
waste, you will both reduce costs and improve the efficiency of your
operations. HPN
