that any new incinerators will probably be built by large commercial concerns
or regional hospital systems, and not individual healthcare institutions.
EPA expected the final standards and guidelines to result in a discontinued
use of as many as 50 to 80 percent of the almost 2,400 existing MWI's. Also,
due to the increased cost of on-site incineration under the final rules, few
health care facilities are likely to install new MWI's. Instead, they are
likely to switch to other methods of waste disposal such as off-site
commercial waste disposal or on-site disinfection technologies.
EPA based the emission limits for existing MWI on stringent air pollution
controls known as maximum achievable control technology. In order to meet the
new limits most existing MWI's will need to install add-on pollution control
systems, most likely scrubbers.
On June 24, 1998, the American Hospital Association (AHA) and the U.S.
Environmental Protection Agency (EPA) jointly signed a "Memorandum of
Understanding" (MOU) that calls for the elimination of hazardous chemical
mercury from the waste stream by the year 2005. In addition, the MOU calls
for initially reducing the total volume of all types of waste generated in
hospitals and health systems by one third by 2005 and ultimately by half by
the year 2010.
Under the collaboration, the EPA and AHA have agreed to:
Undertake collection of baseline data on hospitals' pollution prevention
Monitor hospitals' success in meeting goals of reducing waste;
Sponsor educational seminars about waste management and mercury
Participate in an Environmental Leadership Council, a group comprised of
hospital leaders, EPA officials, environmental groups, and others that
will provide recommendations to the AHA about educational and outreach
activities to hospitals, health systems and health care workers to help
reach these waste reduction goals; and
Develop Internet-based model waste minimization plans for hospitals
targeted at specific chemicals.
As a result of these kinds of initiatives undertaken by the government and
private institutions, any design criteria should take into account current
efforts to reduce medical waste. Obviously, the reduction of medical waste
could impact the required area needed for the processing of regulated medical
waste and hazardous waste such as mercury. Additionally, economic benefits of
the reduction of waste streams from hospitals not only affect operating costs
but could beneficially impact construction costs.
State guidelines generally provide generic guidelines for the training of
waste handling personnel, labeling, transport, treatment and policies and
procedures. However, California Health and Safety Code (Section 118275-
118320) outlines stringent standards for the storage of biohazardous waste or
regulated medical waste.
California guidelines require that "if a person generates 20 or more pounds of
biohazardous waste per month, the person shall not contain or store
biohazardous or sharps waste above 0o Centigrade (32o Fahrenheit) at any
onside location for more than seven days without obtaining prior written
approval of the enforcement agency."