By their very nature, hospitals are uniquely susceptible to environmental concerns. The combination of an already compromised patient group, the high volume of outside traffic, and the numerous procedures that are conducted at hospitals lend themselves to significant opportunities for environmental exposures. 

Hospitals consist of large facilities with various types of real estate, not only patient care facilities. They may include research, ambulatory care, and senior facilities as well as hospices and laboratories, among other types of facilities. Although most of the activities conducted at hospitals generate small amounts of hazardous materials, when those materials accumulate (ex. infectious or hazardous waste) or are dispersed in a hospital setting (ex. mold on construction dust), they can wreak havoc in all areas of a hospital.  According to the Environmental Protection Agency (EPA), there are numerous “key functions and major activities” that generate waste and may be a source of pollutants at healthcare entities. The most notable of the activities from which environmental exposures may stem include diagnostic services, laboratory services, facilities management, food services, pharmacies, research facilities, and during construction activities. This range of activities means more public awareness for safety measures and tighter regulations to keep hospitals accountable for their environmental impact. 

In the early 2000’s the Environmental Protection Agency (EPA) increased their focus on hospitals and instituted a number of programs to reduce and recycle waste, conserve water, conserve energy, and decrease air emissions. The reason for this was that, according to the EPA, many of the activities that are conducted at hospitals are at a higher risk for environmental violations. Some examples of these activities include improper handling of hazardous waste, exceedances of air emissions, and improper management of asbestos or lead-based paint, among others. One of the initiatives that came from this higher EPA focus was having hospitals conduct “self-audits” and report their findings to the EPA, while encouraging them to correct any violations that they found. This initiative has not prevented hospitals from getting violations for non-compliance (although the fines are often reduced), but it is now seen as common practice for hospital facilities to conduct an environmental compliance audit. In the same vein, hospitals historically have not purchased environmental insurance, however with increased regulatory scrutiny, a higher level of the public’s awareness of environmental concerns, and the role of hospital risk managers preparing for the unexpected, there has been an increase in the purchase of environmental insurance for hospitals within the last decade. In fact, environmental insurers have developed forms that address the specific exposures that hospitals face. Here are just some of the regulations affecting hospital operations:

• Clean Air Act (CAA) – regulates air emissions from area, stationary, and mobile sources, including HAVC systems, boilers, medical waste incinerators, ethylene oxide sterilizers, and generators.
• Clean Water Act (CWA) – protects the quality of surface waters and authorizes the EPA to regulate discharges of pollutants, including laboratories, photo processing centers, boilers, and maintenance shops.
• Resource Conservation and Recovery Act (RCRA) -provides “cradle to grave” regulation of solid and hazardous waste and mandates management requirements for generators and transporters of hazardous waste. In hospital settings these include (but are not limited to) solvents in pharmaceuticals, chemotherapy agents, bactericides, cancer research drugs, and anesthetics.
• The Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) – authorizes the EPA to oversee the registration, distribution, sale, and use of pesticides, including antimicrobials. There are specific requirements for personal protective equipment, application, storage areas/containers, and labeling of these materials.
• The Emergency Planning and Community Right-To-Know Act (EPCRA) require that any facility that has a chemical listed on the “extremely hazardous substances list” above a certain threshold has to provide information and participate in emergency planning with the State Emergency Response Commission and Local Emergency Planning Committee. 
• Hospital, Medical, and Infectious Waste Incinerators (HMIWI) -This suite of actions promulgate EPA’s new source performance standards (NSPS), emission guidelines (EG), and federal implementation plan (FIP) for hospital/medical/infectious waste incineration units (HMIWI).
• Hospital Ethylene Oxide Sterilizers: National Emission Standards for Hazardous Air Pollutants (NESHAP) - applies to any existing or new hospital ethylene oxide sterilization facility that is an area source of hazardous air pollutants (HAP). The owner or operator of an existing area source must comply with this area source.
• Medical waste - Medical waste is a subset of wastes generated at health care facilities, such as hospitals, physicians' offices, dental practices, blood banks, and veterinary hospitals/clinics, as well as medical research facilities and laboratories. Generally, medical waste is healthcare waste that that may be contaminated by blood, body fluids or other potentially infectious materials and is often referred to as regulated medical waste.  

Do you have questions about pollution exposures for hospitals or the regulations affecting this type of facility? Contact us today.