& EPA
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-453/R-97-008b
July 1997
Air
Hospital/Medical/Infectious
Waste Incinerators:
Background Information for
Promulgated Standards and
Guidelines -
Analysis of Economic Impacts
for New Sources
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EPA-453/R-97-008b
-/ Hospital/Medical/Infectious
£ Waste Incinerators: Background
£ Information for Promulgated Standards
^ and Guidelines - Analysis of Economic
Impacts for New Sources
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago. IL 60604-3590
U.S. EPA
OAQPS, AQSSD, ISEG
July 1997
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DISCLAIMER
This report is issued by the Office of Air Quality Planning and Standards, U.S. Environmental
Protection Agency. Mention of trade names and/or commercial products is not intended to
constitute endorsement or recommendation for use. Copies of this report are available free of
charge to Federal employees, current contractors and grantees, and non-profit organizations ~ as
supplies permit ~ from the Library Services Office (MD-35), U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina 27711 (919-541-2777) or, for a nominal fee,
from the National Technical Information Service, 5285 Port Royal Road, Springfield, Virginia
22161 (703-487-4650).
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I. INTRODUCTION
On February 27, 1995, the EPA published the proposed New Source Performance Standards
(NSPS) for new medical waste incinerators (MWIs). The proposal was the result of several years
of effort reviewing available information in light of the Clean Air Act requirements. Following
proposal, a large number of comment letters were received, some including new information and
some indicating that commenters were in the process of gathering information for the EPA to
consider. The large amount of new information that was ultimately submitted addressed every
aspect of the proposed standards and guidelines, including: the existing population of MWIs; the
performance capabilities of air pollution control systems; monitoring and testing; operator
training; alternative medical waste treatment technologies; and the definition of medical waste. In
almost every case, the new information has led to different conclusions. One change made to the
final rule as a result of comments regarding the definition of medical waste has been a change in
the title of the rulemaking. For reasons discussed in other documents, the official title of the
rulemaking is "Hospital/Medical/Infectious Waste Incinerators" or "HMTWI." However, for
purposes of this document, the terms "MWI" and "HMTWT should be viewed as interchangeable.
The purpose of this revised economic impact analysis (EIA) document is to reassess the economic
impacts of new regulatory options that have been developed for new MWIs. The potential
economic impacts of three control options for new MWIs were originally evaluated in Medical
Waste Incinerators - Background Information for Proposed Standards and Guidelines: Analysis
of Economic Impacts for New Sources.' An addendum was, subsequently prepared to estimate the
potential economic impacts of a fourth control option.2 The economic impacts presented in this
document should be viewed as a revision to the original economic impact documents.
H. EXECUTIVE SUMMARY
Industry-wide impacts presented in this analysis include estimates of the change in market price
for the services provided by the affected industries, the change in market output or production,
the change in industry revenue, and the change in affected labor markets in terms of the number of
employees lost. The impacts represent the combined, or cumulative, effects of both this NSPS for
new sources and the Emission Guidelines (EG) for existing sources. Control costs from the
NSPS and EG are accumulated in order to account for market adjustments that would first occur
after implementation of the EG. Industries that generate medical waste (hospitals, nursing homes,
etc.) are expected to experience average price increases in the range of 0 to 0.16 percent,
depending on the industry, regulatory option, and scenario analyzed. These industries are
expected to experience output and employment impacts in the range of 0 to -0.21 percent. In
addition, revenue impacts for these industries are expected to range from an increase of 0.05
percent to a decrease of 0.05 percent. An increase in industry revenue will occur if demand for
the industry's service is relatively price-inelastic, i.e., between -1 and 0. Such a price elasticity
indicates that output is not very responsive to a change in price, specifically that the percentage
decrease in output will be less than the percentage increase in price. Since revenue is the product
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of price and output, a less than proportional change in output compared to price means that total
revenue will increase.
The following example illustrates how the above price impacts could be interpreted for the
hospital industry. The estimated average industry-wide price increase for hospitals under
regulatory option three (the most stringent regulatory option) and scenario C, switching with no
waste segregation, is 0.03 percent. This can be expressed in terms of the increased cost of
hospitalization due to the regulation. Total nationwide adjusted patient days at hospitals in 1993
were an estimated 304.5 million days. ("Adjusted" patient days include both in-patient days and
the in-patient day equivalent of out-patient visits.) Annualized control costs under regulatory
option three and scenario C are $108,783,078, or $0.36 per adjusted patient day. This means that
the average price increase that an individual would experience for each hospital patient-day is
expected to equal 36 cents.
The estimated average price increase for the commercial medical waste incineration industry is 4.1
percent, regardless of the regulatory option (control requirements for commercial MWIs do not
vary by regulatory option). This price increase is considered achievable because of the cost
advantage (i.e., lower cost per ton of waste burned) - due to economies of scale - that
commercial MWIs have over smaller on-site MWIs.
Impacts were also estimated at the facility level by employing the concept of the model facility,
i.e., by defining key parameters to describe typical facilities in the affected industries. The vast
majority of facilities impacted by the regulation are those that send their medical waste off-site to
be incinerated and will have to pay more for commercial incineration. All impacts on these
facilities are minuscule. At the most, the increased cost of commercial incineration could be
recovered with a price increase of only 0.03 percent. For facilities that operate on-site MWIs
("MWI operators"), impacts are also generally insignificant. Either the cost of controls or the
cost of switching to an alternative medical waste treatment and disposal method could be
recovered with a price increase that does not significantly exceed the market price increase.
Two types of MWI operators may not be able to switch to an alternative, however: commercial
MWI operators, because their line of business is commercial incineration; and on-site MWIs that
burn a small amount of medical waste and are located far away from an urban area, because they
may not have access to waste hauling and/or commercial incineration services. However, only a
few, if any, of the projected 10 new commercial MWIs over the next five years, and, at the most,
only a few of the projected 85 new small on-site MWIs over the next five years, are likely to be
significantly impacted by the regulation (under all three regulatory options). A "significant
impact" does not necessarily imply closure or the need to cancel plans to open up, or expand, a
facility. For example, operators of small, remote on-site MWIs may still have switching
opportunities. As the commercial incineration industry continues to grow (with additional
impetus being provided by the EG and NSPS), it is possible that services will be extended to
remote, isolated areas that are currently not served. On-site autoclaving is another possible
treatment alternative. If a facility had planned to invest in a new MWI, it stands to reason that an
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on-site autoclave unit of comparable cost would be affordable. Additionally, a facility that had
planned - by virtue of operating an on-site MWI - to open in a remote area without access to
commercial incineration services, might be able to reconsider its location decision, and locate
instead in an area with such access.
This economic impact analysis examines industries that are directly impacted by the regulation,
namely industries that generate or treat medical waste. Secondary impacts such as those on air
pollution device vendors and MWI vendors were not evaluated due to data limitations. However,
it can be said that air pollution device vendors are expected to experience an increase in demand
for their products due to the regulation. The regulation is also expected to increase the demand
for commercial MWI services. Due to economies of scale, however, there is likely to be a
demand shift from smaller incinerators to larger incinerators. Therefore, vendors of small MWIs
may be adversely affected by the regulation.
In accordance with the Regulatory Flexibility Act of 1980 and its amendment in 1996 by the Small
Business Regulatory Enforcement Fairness Act (SBREFA), an analysis of impacts on small
"entities" - including small businesses, small nonprofit organizations, and small governmental
jurisdictions - was performed. This analysis indicates that the NSPS will not have a "significant
impact on a substantial number of small entities" under any regulatory option. Impacts are not
significant for the vast majority of medical waste generators that send their waste off-site to be
treated and disposed. Impacts are also not significant for the great majority of MWI operators
that would have the opportunity to switch to an alternative method of medical waste treatment
and disposal if control costs are prohibitive. Some significant impacts were found under all three
regulatory options for commercial MWI operators and for small on-site MWI operators that are
remote from an urban area. These facilities may not have the opportunity to switch to an
alternative treatment and disposal method - commercial MWI operators because medical waste
incineration is their line of business, and small, remote MWIs because they may not have access to
commercial incineration services. However, the number of such facilities that are both
significantly impacted and "small" would be, at the most, only a few, and would therefore not be
"substantial."
BACKGROUND INFORMATION
A. Regulatory Options
At proposal, the EPA concluded that all new MWIs would need good combustion and dry
scrubbers to meet the MACT floors for CO, PM, and HC1. Consequently, the EPA was left to
consider only two control options for MACT.
After proposal, the EPA received numerous comments containing substantially new information.
Review of this new information led to new conclusions hi a number of areas: the MWI inventory;
MWI subcategories; performance of emission control technologies; MACT floors; and monitoring
and testing options. As a result, the EPA examined several new regulatory options in selecting
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MACT for new MWIs. This section summarizes these new regulatory options and the EPA's
assessment of their merits.
The MACT "floor" defines the least stringent emission standards the EPA may adopt for new
MWIs. However, the Clean Air Act also requires EPA to examine alternative emission standards
(i.e., regulatory options) more stringent than the MACT floor.
Based on the new information submitted to the EPA following proposal of the MACT emission
standards for new MWIs, new MACT floor emission levels were developed for new small,
medium, and large MWIs. Next, the EPA determined the emission control technologies new
MWIs would probably need to meet regulations based on these floor emission limits. The floor
for small new MWIs requires good combustion and moderate efficiency wet scrubbers. For
medium new MWIs, the MACT floor requires good combustion and a combined wet/dry
scrubbing system without activated carbon injection. The MACT floor for large new MWIs
requires good combustion and a combined wet/dry scrubbing system with activated carbon
injection.
Having identified the emission control technology most new MWIs would likely install to meet
the MACT floor emission limits, the EPA also reviewed the performance capabilities of other
emission control technologies that would reduce emissions by an amount greater than the MACT
floor level of control. This process enables the EPA to identify more stringent regulatory options
which could be selected as MACT. Table 1 summarizes the emission control technology that
would probably be required for new small, medium, and large MWIs to meet the emission limits
specified for each of the regulatory options. The regulatory options are a combination of the
various emission standards the EPA believes merit consideration as MACT for new MWIs. This
table is constructed only for the purpose of organizing and structuring an analysis of the cost,
environmental, energy, and economic impacts associated with determining or selecting MACT for
new MWIs. These emission standards for new MWIs will not include requirements to use a
specific emission control system or technology; the standards will only include emission limits,
which may be met by any means or by any control system or technology of the MWI owner's or
operator's choice.
B. Analysis Scenarios
Health care facilities may choose from among a number of alternatives for treatment and disposal
of their medical waste. (It should be noted that these alternatives are generally more limited for
health care facilities located in rural areas than for those located in urban areas.) At the time of
proposal, inventory estimates indicated that fewer than half of all hospitals operated on-site
medical waste incinerators. The clear trend over the past several years has been for more and
more hospitals to turn to the use of alternative on-site medical waste treatment technologies or
the use of commercial off-site treatment and disposal services. Consequently, it is quite likely that
even fewer hospitals now operate on-site medical waste incinerators.
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Table 1
Regulatory Options For New MWIs
MWISize
Small
<200 Ib/hr
Medium
>200 Ib/hr and
<5001b/hr
Large
>500 Ib/hr
Regulatory Option
1
Good combustion
and moderate
efficiency wet
scrubber
Good combustion,
dry injection/fabric
filter system, and
high efficiency wet
scrubber
Good combustion,
dry injection/fabric
filter system with
carbon, and high
efficiency wet
scrubber
2
Good combustion and
moderate efficiency
wet scrubber
Good combustion, dry
injection/fabric filter
system with carbon,
and high efficiency wet
scrubber
Good combustion, dry
injection/fabric filter
system with carbon,
and high efficiency wet
scrubber
3
Good combustion and
high efficiency wet
scrubber
Good combustion,
dry injection/fabric
filter system with
carbon, and high
efficiency wet
scrubber
Good combustion,
dry injection/fabric
filter system with
carbon, and high
efficiency wet
scrubber
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Given the above data, it can be assumed that more than half of all hospitals today have chosen to
use other means of treatment and disposal of their medical waste rather than operate an on-site
incinerator. This indicates that alternatives to the use of on-site incinerators exist and that they
are readily available in many cases. For other health care facilities, such as nursing homes, etc.,
only a small number of facilities currently operate on-site MWIs. Therefore, for these types of
health care facilities, the percentage of such facilities using alternative means of treatment and
disposal of medical waste - particularly commercial treatment and disposal services - is much
higher, probably 95 percent or more. This further confirms the availability of alternatives to
on-site incineration for the treatment and disposal of medical waste.
A likely reaction and outcome associated with the adoption of the standards for new MWIs,
therefore, is an increase in the use of these alternatives by health care facilities for treatment and
disposal of their medical waste. It is not the objective of the EPA to encourage the use of
alternatives or to discourage the continued use of on-site medical waste incinerators; rather, it is
the objective of the EPA to adopt the emission standards for new MWIs that fulfill the
requirements of the Clean Air Act. In doing so, however, it is clear that one outcome associated
with adoption of these emission standards is likely to be an increase in the use of alternatives and
a decrease in the use of on-site medical waste incinerators in the future. Consequently, it is an
outcome the EPA should acknowledge and incorporate into the analysis of the costs and
economic impacts of the emission standards.
In this analysis of costs and economic impacts, selection of an alternative form of medical waste
treatment and disposal by a health care facility, rather than installing a new MWI, is referred to as
"switching." Switching was incorporated into the cost analysis at proposal and was the basis for
the conclusion at proposal that adoption of the proposed emission standards could lead to as
many as 80 percent of health care facilities that might have installed MWIs to choose an
alternative means of medical waste treatment and disposal. However, the economic impacts
presented with the proposed MACT for new sources were only evaluated using the costs under a
"no switching" scenario. Although the EIA presented a qualitative discussion of the likely
possibility of facilities that might have installed on-site MWIs deciding to switch to alternative
treatment and disposal methods, the economic impacts under a switching scenario were not
quantified due to time constraints.
Switching has now been incorporated into the cost and economic impact analysis. Three
scenarios are evaluated: one scenario which ignores switching, and two scenarios which consider
switching. Scenario A assumes that each new MWI will comply with the appropriate regulatory
option by having the appropriate emission control equipment installed. This scenario most likely
overstates national costs and economic impacts and therefore should not be viewed as
representative of the new source emission standards. It is included only to fulfill the goal of
providing a complete analysis.
Switching scenarios B and C are considered more representative of the cost and economic
impacts of the MACT for new MWIs. Both scenarios assume switching occurs when the cost
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associated with purchasing and installing the air pollution control technology or system necessary
to comply with the MACT emission standards (i.e., a regulatory option) is greater than the cost of
using an alternative means of treatment and disposal.*
The difference between the two scenarios is the assumption of whether or not the medical waste
stream is separated. Some facilities currently separate their medical waste into an infectious
stream and a non-infectious stream. Some commenters have stated it is a good assumption that
hospitals which currently operate on-site medical waste incinerators practice little separation of
medical waste into infectious and non-infectious streams; generally all the waste is incinerated.
Based on estimates in the literature that only 10 to 15 percent of medical waste is infectious and
the remaining 85 to 90 percent is non-infectious, scenario B assumes that only 15 percent of the
waste currently being burned at a health care facility operating an on-site incinerator is infectious
medical waste; the remaining 85 percent is non-infectious medical waste. This non-infectious
waste is municipal waste; it needs no special handling, treatment, transportation, or disposal, and
can be sent to a municipal landfill or a municipal combustor for disposal. Thus, under scenario B,
when choosing an alternative to operation of an on-site medical waste incinerator, in response to
adoption of the emission standards, a health care facility need only choose an alternative form of
medical waste treatment and disposal for 15 percent of the waste stream to be burned on-site and
may send the remaining 85 percent to a municipal landfill. This scenario results in the lowest
costs because 85 percent of the waste is disposed at the relatively inexpensive cost of municipal
waste disposal.
On the other hand, it is unlikely that all health care facilities will be able to, or will decide to,
segregate their waste stream. For example, a facility may decide that the cost and inconvenience
of training its staff to segregate waste is not acceptable. Scenario C, therefore, assumes that all
medical waste that would be burned at a health care facility with an on-site medical waste
incinerator is infectious medical waste and must be treated and disposed of accordingly. As a
result, scenario C leads to higher costs than scenario B.
Scenarios B and C represent the likely range of impacts associated with the MACT emission
standards for new MWIs. The actual impacts of a MACT emission standard (i.e., a regulatory
option) are most likely to fall somewhere within the range represented by scenarios B and C.
C. Industry Sectors
Similar to the original ELA, this analysis examines the economic impacts of the MACT emission
standards on industries that generate medical waste and will operate new on-site MWIs, new
commercial MWIs, and industries that generate medical waste but are not expected to operate
'Under both scenarios, however, switching may not be possible for some MWIs that burn a small
amount of medical waste and are located far away from an urban area. Such MWIs may, in some cases, have
difficulty attracting the services of waste haulers and/or commercial MWI operators. For some small, remote
MWIs, therefore, scenarios B and C may not apply. Only scenario A, no switching, may apply.
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new on-site MWIs. Facilities engaging in the above activities will generally fall into one of two
categories: directly affected facilities, and "off-site generators."
Facilities in industries that generate medical waste and will operate new on-site MWIs will be
directly affected by the MACT emission standards because they will need to initiate some action
to comply with the regulation (i.e., install emission control equipment or switch to an alternative).
Costs and economic impacts associated with these facilities and industries are referred to as direct
costs and economic impacts. Industries belonging to this category include hospitals, nursing
homes, and research laboratories. Also included in this category of directly affected industries are
commercial MWIs. Although the commercial MWI industry does not generate medical waste, it
will be required to comply with the emission standards by installing emission control equipment.
The analysis also examines the impacts of the emission standards on facilities that generate
medical waste but will not operate a new on-site MWI. Such facilities are termed "off-site
generators" in this analysis. These facilities will be indirectly affected by the regulation because
they must send their medical waste off-site to be treated and disposed. Commercial MWIs or
other waste treatment facilities that provide service to these types of facilities are expected to pass
on to their customers at least a portion of their cost increases. Off-site generators are therefore
expected to have to pay more for waste treatment service. Industries belonging to this off-site
generator category include hospitals, nursing homes, research laboratories, funeral homes,
physicians' offices, dentists' offices and clinics, outpatient care facilities, freestanding blood
banks, fire and rescue operations, and correctional facilities.
D. Five-Year Projections
This analysis attempts to estimate the impacts of these MACT emission standards over a five-year
time period between 1996 and 2000. This type of analysis is only possible if projections of key
analysis parameters are made. The parameters required to establish a future fifth-year baseline
include: the number of new MWI units that would have begun operation in the absence of these
emission standards for new sources, the costs of control technologies to enable the new MWI
units to meet these emission standards, the population of facilities expected to exist in each of the
industries (e.g., hospitals, etc.) and all relevant financial and economic data used in this analysis to
estimate the economic impacts of these emission standards.
Where possible, projections of some parameters are based on historical trends. For example, the
number of new commercial MWIs that would have begun operation in the absence of these
emission standards is estimated by examining the annual number of new commercial incinerators
that have begun operation in the past few years. This survey is possible because the MWI
inventory contains this information. An examination of the MWI inventory reveals that
approximately two new commercial incinerators have begun operation in each of the past few
years. Using this historical information, the cost and economic impact analyses project that in the
absence of these emission standards, two new commercial incinerators would begin operation in
each year of the five-year analysis time frame. Therefore, this analysis uses a future baseline of
ten new commercial MWIs that would potentially be affected by these emission standards by the
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fifth year of this analysis time frame. This methodology is applied to the projection of new MWI
units in each of the industry categories. Table 2 presents the number of new MWIs that are
projected to be constructed in the absence of these MACT emission standards for new MWIs.
Although these standards specify only an emission limit that must be met, rather than a specific
emission control technology that must be installed, costs are estimated by identifying the emission
control technology that most new MWIs would likely install given the current available
technology. Therefore, no projections are made regarding future innovations or future changes in
the price of these emission control technologies.
Time-series data were not readily available to estimate changes in the population of hospitals,
nursing homes, etc. over the next five years. The population of facilities in each affected industry
is therefore assumed to remain constant at the 1993 level, the most recent year for which facility
population data were available. This implicitly assumes that new MWIs in the next five years will
not be due to industry growth, but rather to the replacement of existing MWIs.
Also due to the lack of time-series data, future values are not estimated for financial and economic
inputs such as revenue and employment. Rather, the available 1993 data are assumed to apply
throughout the five-year period. While this does not account for possible growth within the
affected industries, it is consistent with control costs, which are stated in 1993 dollars.
IV. ECONOMIC IMPACTS
A. Methodology
This section briefly describes the analytical approach used to estimate industry-wide and facility-
specific economic impacts and to evaluate the economic feasibility of switching. All economic
impacts presented in this document were re-estimated using the methodology described in the
original EIA. Therefore, for a more detailed description of the methodology used to estimate
economic impacts, refer to the Background Information for Proposed Standards and Guidelines:
Analysis of Economic Impacts for New Sources. Although this analysis attempts to forecast
future events and reactions to the emission standards, the basis for the forecast is 1993 financial
and economic data. Therefore, all dollar figures (e.g., costs, prices) are stated at 1993 levels.
Economic impacts for new MWIs are calculated under a couple of assumptions. First, the costs
that are used to estimate the economic impacts of these MACT emission standards include control
costs from both the emission guidelines (EG) for existing MWIs and these emission standards for
new MWIs (i.e., NSPS). This approach is used to account for market adjustments (e.g., price
impacts) that would first occur after implementation of the EG. This approach allows for the
establishment of a future baseline scenario. Second, due to lack of information, revenue data for
each of the affected industries were not adjusted for growth during the five-year time frame.
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Table 2
Number of New Medical Waste Incinerators
MWISize
Small
Medium
Large
Commercial
Total
Projected Number of New
MWIs Per Year
17
18
12
2
49
Projected Number of New
MWIs from 1996 to 2000
85
90
60
10
245
10
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The MACT "floor" defines the least stringent emission standards the EPA may adopt for new
MWIs. However, the Clean Air Act also requires EPA to examine alternative emission standards
(i.e., regulatory options) more stringent than the MACT floor.
Average industry-wide price increases are estimated by comparing annualized control costs to
annual revenue for each affected industry. The ratio of annualized control costs to revenue
represents the average industry-wide price increase necessary to recover control costs. Percent
changes in industry-wide output are estimated in turn using high and low estimates of the price
elasticity of demand. Resulting changes in industry revenue are estimated based on the price and
output calculations. Employment or labor market impacts are estimated assuming they are
proportional to the output impacts.
Facility-specific economic impacts are estimated using model facility information. Facility-specific
price impacts are compared to average industry-wide price impacts to determine if the difference
between the two is significant. A determination of significance - implying that the facility price
increase may not be achievable - is made for all but commercial MWI operators if the facility
price increase exceeds the average industry-wide, or "market," price increase by more than one
percentage point. For commercial MWI operators, the facility pri<5e increase is considered
significant if it exceeds the market price increase by more than two percentage points. More
pricing latitude is given to commercial MWI operators for two reasons: 1) commercial
incineration is not subject to the same institutional pricing constraints as the health care sector,
and 2) commercial incineration fees could actually get a boost from the regulation as a result of
switching from on-site incineration and an increase in the demand for commercial incineration
services. Where significance is found, the impact on net income (earnings) of absorbing control
costs is estimated and evaluated.
The assumption of no switching (scenario A) represents the highest cost and economic impact
scenario. (The exception is commercial MWIs, for which control costs do not vary by scenario.)
Scenario B, switching with waste segregation, represents the lowest cost and economic impact
scenario. As previously discussed, the EPA considers scenario A to be unlikely. Scenarios B and
C should be regarded as more representative of the impacts of the emission standards.
B. Industry-wide Impacts
1. Industry-wide Annualized Control Costs3
Tables 3 A, 3B, and 3C present national annualized control costs for those industries that operate
MWIs ("direct control costs"). Annualized control costs are highest under scenario A (Table
3 A). Total annualized costs under scenario A range from $230.2 million for regulatory option
one to $242.8 million for regulatory option three. As previously explained, scenario A impacts
are calculated under the unlikely assumption that all facilities operating, and expected to operate,
an MWI will purchase emission control equipment. This scenario does not allow for the
possibility of switching to alternative methods of waste treatment and disposal.
11
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Table 3A
Industry-wide Annualized Control Costs for Industries Operating
On-site Medical Waste Incinerators: Existing and New Sources
Scenario A: No Switching
Industry
Hospitals
New
Existing
Total
Nursing homes
New
Existing
Total
Research labs
New
Existing
Total
Other
New
Existing
Total
Commercial incineration
New
Existing
Total
Total Existing and New
Annualized Costs
Regulatory
Option I1
$ 23,925,809
$138,533,521
$162,459,330
$ 3,786,349
$21,923,449
$ 25,709,798
$ 3,786,349
$ 21,923,449
$ 25,709,798
$ 1,142,432
$ 6,614,834
$ 7,757,266
$ 3,581,630
$ 4,971,523
$ 8,553,153
$230,189,345
Regulatory
Option 22
$ 24,295,241
$138,533,521
$162,828,762
$ 3,844,813
$21,923,449
$ 25,768,262
$ 3,844,813
$21,923,449
$ 25,768,262
$ 1,160,072
$ 6,614,834
$ 7,774,906
$ 3,581,630
$ 4,971,523
$ 8,553,153
$230,693,345
Regulatory
Option 33
$ 24,918,291
$146,776,634
$171,694,925
$ 3,943,413
$ 23,227,953
$27,171,366
$ 3,943,413
$ 23,227,953
$27,171,366
$ 1,189,822
$ 7,008,434
$ 8,198,256
$ 3,581,630
$ 4,971,523
$ 8,553,153
$242,789,066
1 Assumes Regulatory Option 5 for existing MWIs, the most stringent Emission Guidelines that would be
considered in combination with regulatory option 1 of the NSPS for new sources.
2 Assumes Regulatory Option 5 for existing MWIs, the most stringent Emission Guidelines that would be
considered in combination with regulatory option 2 of the NSPS for new sources.
3 Assumes Regulatory Option 6 for existing MWIs, the most stringent Emission Guidelines that would be
considered in combination with regulatory option 3 of the NSPS for new sources.
12
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Table 3B
Industry-wide Annualized Control Costs for Industries Operating
On-site Medical Waste Incinerators: Existing and New Sources
Scenario B: Switching With Waste Segregation
Industry
Hospitals
New
Existing
Total
Nursing homes
New
Existing
Total
Research labs
New
Existing
Total
Other
New
Existing
Total
Commercial incineration
New
Existing
Total
Total Existing and New
Annualized Costs
Regulatory
Option I1
$ 6,267,151
$44,157,613
$50,424,764
$ 991,800
$6,988,108
$ 7,979,908
$ 991,800
$6,988,108
$ 7,979,908
$ 299,251
$2,108,481
$ 2,407,732
$3,581,630
$ 4,971,523
$8,553,153
$77,345,465
Regulatory
Option 22
$ 6,267,151
$44,157,613
$50,424,764
$ 991,800
$6,988,108
$ 7,979,908
$ 991,800
$6,988,108
$ 7,979,908
$ 299,251
$2,108,481
$ 2,407,732
$3,581,630
$4,971,523
$8,553,153
$77,345,465
Regulatory
Option 33
$ 6,267,151
$44,973,911
$51,241,062
$ 991,800
$7,117,290
$8,109,090
$ 991,800
$7,117,290
$8,109,090
$ 299,251
$2,147,458
$ 2,446,709
$3,581,630
$4,971,523
$8,553,153
$78,459,104
1 Assumes Regulatory Option 5 for existing MWIs, the most stringent Emission Guidelines that would be
considered in combination with regulatory option 1 of the NSPS for new sources.
2 Assumes Regulatory Option 5 for existing MWIs, the most stringent Emission Guidelines that would be
considered in combination with regulatory option 2 of the NSPS for new sources.
3 Assumes Regulatory Option 6 for existing MWIs, the most stringent Emission Guidelines that would be
considered in combination with regulatory option 3 of the NSPS for new sources.
13
-------
Table 3C
Industry-wide Annualized Control Costs for Industries Operating
On-site Medical Waste Incinerators: Existing and New Sources
Scenario C: Switching With No Waste Segregation
Industry
Hospitals
New
Existing
Total
Nursing homes
New
Existing
Total
Research labs
New
Existing
Total
Other
New
Existing
Total
Commercial incineration
New
Existing
Total
Total Existing and New
Annualized Costs
Regulatory
Option I1
$ 16,596,792
$ 91,125,328
$107,722,120
$ 2,626,504
$ 14,420,925
$ 17,047,429
$ 2,626,504
$ 14,420,925
$ 17,047,429
$ 792,480
$ 4,351,142
$ 5,143,622
$ 3,581,630
$ 4,971,523
$ 8,553,153
$155,513,753
Regulatory
Option 21
$ 16,596,792
$ 91,125,328
$107,722,120
$ 2,626,504
$ 14,420,925
$ 17,047,429
$ 2,626,504
$ 14,420,925
$ 17,047,429
$ 792,480
$ 4,351,142
$ 5,143,622
$ 3,581,630
$ 4,971,523
$ 8,553,153
$155,513,753
Regulatory
Option 33
$ 16,596,792
$ 92,186,286
$108,783,078
$ 2,626,504
$ 14,588,825
$ 17,215,329
$ 2,626,504
$ 14,588,825
$ 17,215,329
$ 792,480
$ 4,401,801
$ 5,194,281
$ 3,581,630
$ 4,971,523
$ 8,553,153
$156,961,170
1 Assumes Regulatory Option 5 for existing MWIs, the most stringent Emission Guidelines that would be
considered in combination with regulatory option 1 of the NSPS for new sources.
2 Assumes Regulatory Option 5 for existing MWIs, the most stringent Emission Guidelines that would be
considered in combination with regulatory option 2 of the NSPS for new sources.
3 Assumes Regulatory Option 6 for existing MWIs, the most stringent Emission Guidelines that would be
considered in combination with regulatory option 3 of the NSPS for new sources.
14
-------
National costs are lowest under scenario B, which assumes that some facilities that would have
operated an on-site MWI will switch to an alternative method of waste treatment and disposal.
This scenario also assumes that those facilities deciding to switch will also segregate their waste.
Total annualized costs under scenario B range from $77.3 million for regulatory options one and
two to $78.5 million for regulatory option three. The range under scenario C, which assumes
switching with no waste segregation, is $155.5 million for regulatory options one and two to
$157.0 million for regulatory option three. In comparison to Scenario A, costs under scenarios B
and C do not vary significantly among the regulatory options because the cost of some alternative
methods (such as autoclaving) are unaffected by the emission limits imposed on MWIs. In
addition, control requirements for commercial MWIs (another alternative to on-site incineration)
do not vary by regulatory option. The small changes in national annualized costs observed among
the regulatory options reflect the different number of facilities expected to switch from on-site
incineration to an alternative method of waste treatment and disposal.
Table 4 presents annual costs for those industries not operating MWIs ("indirect control costs").
Annual costs for these "off-site generators," which are assumed to have their medical waste
incinerated off-site, were calculated by multiplying estimated medical waste generated annually by
the incremental cost for commercial incineration. The incremental cost was calculated by dividing
industry-wide annualized control costs for commercial incinerators, both existing and new, by
their throughput. The incremental cost of commercial incineration is calculated to be 0.99 cents
per pound under all regulatory options. Note in Tables 3 A through 3C that industry-wide
annualized control costs for commercial MWIs do not vary by regulatory option. This is because
control requirements do not vary by regulatory option for commercial MWIs.
2. Financial and Economic Inputs
The economic impact methodology used in this report is similar to the methodology used in the
original EIA. The types of data inputs needed are the same as in the original analysis. However,
all financial and economic data have been updated to 1993 where possible.
Table 5 presents the relevant financial and economic data for each of the regulated industries.
Specifically, the number of facilities for each industry is reported along with revenue and
employment. Also, where possible, the estimated price elasticity of demand is reported. These
price elasticities are the same as those estimated in the original EIA. Note that an elasticity
estimate is not presented for the commercial MWI industry. This omission is due to a lack of
relevant information about this industry and is further complicated by the uncertainty of the
regulation's impact on the demand for commercial waste incineration.
3. Market Price Increase
The market price increase is defined as the average industry-wide price increase necessary to
recover annualized control costs. It is calculated as the ratio of industry-wide annualized control
costs to revenue. Because most, if not all, of the regulated industries are characterized by local or
regional markets, actual price increases will vary from one location to another according to such
15
-------
Table 4
Industry-wide Annual Costs for Industries Not Operating
On-site Medical Waste Incinerators: Existing and New Sources
Industry
Medical / dental laboratories
Funeral homes
Physicians' offices
Dentists' offices & clinics
Outpatient care
Freestanding blood banks
Fire & rescue operations
Correctional facilities
Total
Medical Waste Generated
Annually (tons per year)
17,600
900
35,200
8,700
26,300
4,900
1,600
3,300
98,500
Annual Control Cost1
$348,067
$ 17,799
$696,134
$172,056
$520,123
$ 96,905
$ 31,642
$ 65,263
$1,947,989
1 Assumes that all medical waste is incinerated off-site at an incremental cost of 0.99 cents per pound, the average
annualized cost increase for commercial MWIs (existing and new).
16
-------
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-------
factors as: 1) the number of facilities in the market; 2) the number of facilities operating an MWI
3) the distribution of MWI sizes; and 4) market structure and pricing mechanisms. Ideally, the
average price increase in each local or regional market would be measured. However, it is not
possible to define and characterize literally hundreds of local and regional markets. Therefore, the
industry-wide price increase, which is an average price increase across all market areas, is used to
represent the average price increase in each individual local or regional market.
As an average, the market price increase does not reflect the range of price increases that all
facilities in an industry would require to recover control costs. The range of price increases
necessary to recover control costs should be particularly wide in industries consisting of both
MWI operators and off-site generators. On average, off-site generators will require a lower price
increase to recover control costs (passed along from commercial MWIs) than MWI operators.
This is because: 1) the average off-site generator is less dependent on off-site incineration than the
average MWI operator is dependent on on-site incineration; and 2) MWIs used for commercial
incineration are larger than average, and therefore have relatively low control costs per unit of
waste disposed. Among off-site generators, the price increase necessary to recover control costs
will vary with the degree of dependence on off-site incineration.
Market price increases are presented in Tables 6A, 6B, and 6C. As can be seen, scenario A
(Table 6A) produces the largest impacts. However, because this scenario is unlikely to occur,
attention should be focused on the impacts estimated under scenarios B and C. Scenario B, which
assumes switching with waste segregation, produces average industry-wide price increases of
0.02 percent under all three regulatory options for both hospitals and nursing homes. The
commercial research laboratory industry is expected to experience a price increase of 0.05
percent, regardless of the regulatory option.
Under scenario C, which assumes switching without waste segregation, the average industry-wide
price increase for both hospitals and nursing homes is 0.03 percent under all three regulatory
options. For commercial research labs, the price impact is 0.10 percent, regardless of the
regulatory option.
Under all three scenarios, the price impacts are negligible (not even registering at two decimal
places) for medical and dental laboratories, funeral homes, physicians' offices, dentists' offices
and clinics, outpatient care, fire and rescue operations, and correctional facilities. For
freestanding blood banks, the price impact under all three scenarios is only 0.01 percent for all
three regulatory options.
With the exception of the commercial MWI industry, all market price increases in Tables 6 A
through 6C are under one percent and are therefore considered achievable. The low values partly
reflect the fact that in each industry, the majority of facilities do not currently operate an MWI
and are not expected to operate a new MWI.
18
-------
Table 6A
Industry-wide Percent Price Impacts*: New and Existing Sources
Scenario A: No Switching
Industry
Hospitals
Nursing homes
Laboratories:
Research
Medical/dental
Funeral homes
Physicians' offices
Dentists' offices and
clinics
Outpatient care
Freestanding blood
banks
Fire and rescue
operations
Correctional facilities
Commercial
incineration
Regulatory
Option 1
0.05
0.05
0.15
0
0
0
0
0
0.01
0
0
4.12
Regulatory
Option 2
0.05
0.05
0.15
0
0
0
0
0
0.01
0
0
4.12
Regulatory
Option 3
0.05
0.05
0.16
0
0
0
0
0
0.01
0
0
4.12
* Percent price increases necessary to recover annualized control costs.
19
-------
Table 6B
Industry-wide Percent Price Impacts*: New and Existing Sources
Scenario B: Switching With Waste Segregation
Industry
Hospitals
Nursing homes
Laboratories:
Research
Medical/dental
Funeral homes
Physicians' offices
Dentists' offices and
clinics
Outpatient care
Freestanding blood
banks
Fire and rescue
operations
Correctional facilities
Commercial
incineration
Regulatory
Option 1
0.02
0.02
0.05
0
0
0
0
0
0.01
0
0
4.12
Regulatory
Option 2
0.02
0.02
0.05
0
0
0
0
0
0.01
0
0
4.12
Regulatory
Option 3
0.02
0.02
0.05
0
0
0
0
0
0.01
0
0
4.12
* Percent price increases necessary to recover annualized control costs.
20
-------
Table 6C
Industry-wide Percent Price Impacts": New and Existing Sources
Scenario C: Switching With No Waste Segregation
Industry
Hospitals
Nursing homes
Laboratories:
Research
Medical/dental
Funeral homes
Physicians' offices
Dentists' offices and
clinics
Outpatient care
Freestanding blood
banks
Fire and rescue
operations
Correctional facilities
Commercial
incineration
Regulatory
Option 1
0.03
0.03
0.10
0
0
0
0
0
0.01
0
0
4.12
Regulatory
Option 2
0.03
0.03
0.10
0
0
0
0
0
0.01
0
0
4.12
Regulatory
Option 3
0.03
0.03
0.10
0
0
0
0
0
0.01
0
0
4.12
* Percent price increases necessary to recover annualized control costs.
21
-------
Tables 6A through 6C also present average industry-wide price impacts for the commercial MWI
industry. The impact, 4.12 percent, is the same under each regulatory option because control
requirements for commercial MWIs do not vary by regulatory option. Also, the impacts are the
same under all three scenarios because switching is not an option for commercial MWIs.
Although the estimated price increase for this industry exceeds one percent, it is considered
achievable because of the cost advantage (i.e., lower cost per ton of waste burned) - due to
economies of scale - that commercial MWIs have over smaller on-site MWIs. This cost
advantage, which will be made even more pronounced by the NSPS, is a strong basis for the
argument that many facilities will switch from on-site incineration to off-site disposal in response
to the regulation.
4. Output. Employment, and Revenue Impacts
The market price increase will result in output, employment, and revenue impacts. This analysis
presents a range of output, employment, and revenue impacts due to the use of two price
elasticity of demand estimates for each industry. These impacts are not estimated for the
commercial MWI industry due to a lack of relevant financial and economic information for the
industry.
Since demand is not perfectly inelastic in any of the impacted industries, output will decline in
response to the market price increase. The relationship between price and output (or quantity
demanded) can be captured by the following constant-elasticity demand function:
QD=aP*
Where: QD = Quantity Demanded
a = a constant
P = Price
e = Price Elasticity of Demand
By also specifying time periods 0 and 1, the percent change in output (%AQ) can be solved in the
following way:
22
-------
Qo = <
Q, - <
aP,'-aPo'
Pe
ro
o
r> «
= (1 + %AP)e - 1
Output impacts can be calculated by setting %AP equal to the market price increase. These
impacts are presented in Tables 7A, 7B, and 1C. Due to a relatively small market price increase
and/or relatively inelastic demand, all of the output impacts are less than one percent. The
greatest output decreases are experienced by commercial research labs, but even these are
insignificant: up to 0.21 percent for regulatory option three under scenario A, up to 0.06 percent
for regulatory option three under scenario B, and up to 0.13 percent for regulatory option three
under scenario C.
The impact of the market price increase on industry-wide employment, assuming that employment
is proportional to output (i.e., fixed labor to output ratio), is also presented in Tables 7A through
7C. These impacts are presented in terms of estimated employment losses. As a percent of the
baseline (see Table 5), the employment losses are considered small. (In fact, by definition, the
percent decrease in employment is equal to the percent decrease in output, which has already been
seen to be insignificant.) At the most (regulatory option three) under scenario A, the number of
employees would decline by up to 772 at hospitals, 578 at nursing homes, and 336 at research
labs (all other industries have minuscule or undetectable impacts). However, because switching is
likely to occur, the impacts are more likely to fall between those shown under scenarios B and C.
At the most (regulatory option three) under scenario C, the number of employees would decline
by up to 489 at hospitals, 366 at nursing homes, and 213 at research labs. At the most (regulatory
option three) under scenario B, the number of employees would decline by up to 231 at hospitals,
172 at nursing homes, and 100 at research labs.
23
-------
Table 7 A
Industry-wide Output, Employment and Revenue Impacts: New and Existing Sources
Scenario A: No Switching
Industry
Hospitals
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Nursing homes
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Laboratories:
Commercial research
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Medical/dental
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Funeral homes
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Physicians1 offices
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Dentists' offices and clinics
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Outpatient care
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Freestanding blood banks
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Fire and rescue operations
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Correctional faculties
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Regulatory Option I
0-0.02
0-73 1
0.03-0.05
0.02-0.03
269-547
0.02-0.03
0.15-0.20
239-318
(0.05)-0
0
3-6
0
0
0
0
0
0-2
0
0
1-2
0
0
0-2
0
0
0
0-0.01
0
0
0
0
0
0
Regulatory Option 2
0-0.02
0-732
0.03-0.05
0.02-0.03
270-548
0.02-0.03
0.15-0.20
239-318
(0.05)-0
0
3-6
0
0
0
0
0
0-2
0
0
1-2
0
0
0-2
0
0
0
0-0.01
0
0
0
0
0
0
Regulatory Option 3
0-0.02
0-772
0.04-0.05
0.02-0.04
285-578
0.02-0.04
0.16-0.21
252-336
(0.05)-0
0
3-6
0
0
0
0
0
0-2
0
0
1-2
0
0
0-2
0
0
0
0-0.01
0
0
0
0
0
0
24
-------
Table 7B
Industry-wide Output, Employment and Revenue Impacts: New and Existing Sources
Scenario B: Switching With Waste Segregation
Industry
Hospitals
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Nursing homes
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Laboratories:
Commercial research
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Medical/dental
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Funeral homes
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Physicians' offices
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Dentists' offices and clinics
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Outpatient care
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Freestanding blood banks
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Fire and rescue operations
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Correctional facilities
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Regulatory
Option 1
0-0.01
0-227
0.01-0.02
0.01
84-170
0.01
0.05-0.06
74-99
(0.02)-0
0
3-6
0
0
0
0
0
0-2
0
0
1-2
0
0
0-2
0
0
0
0-0.01
0
0
0
0
0
0
Regulatory Option
2
0-0.01
0-227
0.01-0.02
0.01
84-170
0.01
0.05-0.06
74-99
(0.02MJ
0
3-6
0
0
0
0
0
0-2
0
0
1-2
0
0
0-2
0
0
0
0-0.01
0
0
0
0
0
0
Regulatory Option
3
0-0.01
0-231
0.01-0.02
0.01
85-172
0.01
0.05-0.06
75-100
(0.02)-0
0
3-6
0
0
0
0
0
0-2
0
0
1-2
0
0
0-2
0
0
0
0-0.01
0
0
0
0
0
0
25
-------
Table 7C
Industry-wide Output, Employment and Revenue Impacts: New and Existing Sources
Scenario C: Switching With No Waste Segregation
Industry
Hospitals
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Nursing homes
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Laboratories:
Commercial research
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Medical/dental
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Funeral homes
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Physicians' offices
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Dentists' offices and clinics
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Outpatient care
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Freestanding blood banks
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Fire and rescue operations
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Correctional facilities
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Regulatory
Option 1
0-0.01
0-485
0.02-0.03
0.01-0.02
179-363
0.01-0.02
0.10-0.13
158-211
(0.03>0
0
3-6
0
0
0
0
0
0-2
0
0
1-2
0
0
0-2
0
0
0
0-0.01
0
0
0
0
0
0
Regulatory Option
2
0-0.01
0-485
0.02-0.03
0.01-0.02
179-363
0.01-0.02
0.10-0.13
158-211
(0.03>0
0
3-6
0
0
0
0
0
0-2
0
0
1-2
0
0
0-2
0
0
0
0-0.01
0
0
0
0
0
0
Regulatory Option
3
0-0.01
0-489
0.02-0.03
0.01-0.02
180-366
001-0.02
0.10-0.13
160-213
(0.03)-0
0
3-6
0
0
0
0
0
0-2
0
0
1-2
0
0
0-2
0
0
0
0-0.01
0
0
0
0
0
0
26
-------
The employment impacts in Tables 7 A through 7C do not attempt to quantify some positive
employment impacts expected to occur as a result of the regulation. For example, employment
related to the production of pollution control equipment should increase. In addition, additional
people will be needed to provide training to MWI operators. Also, there should be an increase in
employment related to the production and operation of commercial MWIs and alternative medical
waste treatment and disposal systems.
Revenue will change in response to the market price increase. It will increase if demand is
relatively inelastic (i.e., -1 < e < o) and decrease if demand is relatively elastic (i.e., e < -1). For
example, if demand is relatively inelastic, the percent decrease in output in response to a price
increase will be less than the percent price increase. Since revenue is the product of price and
output, a less-than-proportionate decrease in output implies an increase in revenue. The
following equation can be used to measure the impact on revenue of the market price increase
(and resultant output decrease):
A Revenue = Baseline Revenue * [%AP + %A0 + (%AP * %A0]
Revenue impacts (percent increase or, in parentheses, percent decrease) are also presented in
Tables 7 A through 7C. Revenue decreases only for commercial research labs in the case of the
maximum elasticity (e = -1.33; see Table 5). In all other cases, revenue increases because demand
is relatively inelastic or does not change because demand is unitary-elastic (e = -1). Regardless,
all impacts are small and are not considered significant.
C. Model Facility Analysis
Facility-specific impacts were also estimated for the affected industries. These impacts were
calculated by employing the concept of the model facility. This technique allows an analysis to be
prepared on a more detailed level by defining key parameters to describe "typical" facilities in the
affected industries. The El A prepared for the proposed rule used cost estimates provided on a
model combustor (i.e., MWI) basis to estimate economic impacts for model facilities. The model
facility concept not only had to incorporate model MWI parameters, (e.g., amount of throughput
to determine size, etc.), but also key financial and economic parameters (e.g., revenue, etc.).
Therefore, a scheme to assign model MWIs to model facilities had to be developed in the original
EIA.
New information received after proposal made it possible for cost estimates to be developed on a
model facility basis, with key model MWI parameters already incorporated into the model facility
concept. Therefore, this document no longer needs to employ the "linking" scheme used to assign
model MWIs to model facilities in the earlier EIA. The model facilities defined in the cost
analysis are presented in Table 8. Note that hospitals are defined in terms of number of
27
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Table 8
Model Facility Definitions
Facility
Large Hospital
Medium Hospital
Small Hospital
Nursing Home
Commercial Research
Laboratory
Commercial Incineration
Facility
Definition
400 beds
140 beds
40 beds
150 employees
200 employees
N/A
MWI Assignment
Large MWI
Medium MWI
Small MWI
Small MWI
Medium MWI
Commercial MWI
(Large)
N/A - not available
28
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beds while nursing homes and commercial research laboratories are defined in terms of number of
employees. Note also that this type of information is not available for the commercial MWI
industry.
1. Model MWI Costs
Tables 9 and 10 present capital (for scenario A) and annualized (for scenarios A, B, and C) costs
for model MWIs. Scenario A has capital costs because it assumes that all facilities expected to
operate an MWI will have emission control equipment installed rather than decide to use an
alternative technology (i.e., switch). Scenarios B and C have no capital costs because switching
to an alternative technology precludes the need to invest in emission control equipment for an on-
site MWI.
For all MWIs other than commercial MWIs and small rural MWIs that are remote from an urban
area, scenario A is an unlikely representation of facility-specific impacts because the assumption
that some potentially new MWIs will not be replaced by alternative technologies is unrealistic.
The regulation will impose additional costs on new MWIs and, therefore, will make alternative
technologies more attractive - from a cost perspective - in comparison. In addition, the costs in
Table A are from a baseline of no controls. The table therefore overstates control costs for the no
doubt many new MWIs that, in the absence of the emission standards, would have been equipped
with at least some controls. Scenario A, on the other hand, may be the only scenario that applies
to commercial MWIs and small rural MWIs that are remote from an urban area if they are unable
to switch to an alternative technology.
Incremental annual costs for off-site generators are presented in Table 11. The costs reflect two
alternative estimates of the increase in the cost of off-site incineration. The low estimate is 0.99
cents per pound, the average annualized control cost for all commercial MWIs, existing and new.
The high estimate derives from a new large model commercial MWI estimated to have annualized
control costs of $358,163 and to burn 7,711,000 pounds of medical waste annually. Dividing cost
by throughput yields a cost of 4.64 cents per pound. The use of low and high cost estimates
allows for the consideration of uncertainty in the actual incremental cost that off-site generators
will face.
2. Financial and Economic Inputs
Model information for facilities that operate on-site MWIs (i.e., MWI operators) is presented in
Table 12. The information derives from the financial and economic input data in Tables 13 and
14. Interpolation was used to assign employment and revenue to the model hospitals of bed sizes
40 (small), 140 (medium), and 400 (large), and to assign revenue to the model nursing homes
with 150 employees and model research labs with 200 employees. For example, in Table 13 it is
seen that the average number of beds at a Federal government hospital is 34.8 in the 25-49 beds
category and 66.2 in the 50-99 beds category. The model small hospital has 40 beds, however.
Interpolating between average revenue of $16.5 million for a Federal hospital with 34.8 beds and
$29.6 million for a Federal hospital with 66.2 beds, revenue of $18.7 million for the model small
hospital, shown in Table 12, is obtained.
29
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Table 9
Control Costs for Model MWIs: New Sources
Scenario A: No Switching
Model M\VI
Small
Urban
Annualized cost
Capital cost
Small
Rural
Annualized cost
Capital cost
Medium
Annualized cost
Capital cost
Large on-site
Annualized cost
Capital cost
Large commercial
Annualized cost
Capital cost
Regulatory Option
One
$ 68,194
$220,386
$ 68,194
$220,386
$159,563
$652,194
$208,063
$652,894
$358,163
$758,494
Two
$ 68,194
$220,386
$ 68,194
$220,386
$165,163
$655,394
$208,063
$652,894
$358,163
$758,494
Three
$ 78,194
$268,786
$ 78,194
$268,786
$165,163
$655,394
$208,063
$652,894
$358,163
$758,494
30
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Table 10
Annual Costs of Switching for Model MWIs '
Model MWI
Scenario B - Switching
With Waste Segregation
Scenario C - Switching
Without Waste Segregation
Small
Urban
Rural2
$5,260
$7,400
$19,200
$31,200
Medium
Urban
Rural
$19,944
$28,058
$72,800
$118,300
Large
Urban
Rural
$93,584
$131,658
$341,600
$555,100
1 Switching costs do not vary by regulatory option.
2 May not apply to some facilities that burn a small amount of medical waste and are remote from an urban area.
Such facilities may not have switching opportunities if they have difficulty attracting the services of waste haulers
and/or commercial MWI operators.
31
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Table 11
Annual Costs for Model Facilities Not Operating On site MWls: New Sources
Industry/Model Facility
Hospitals
<50Beds
50-99 Beds
100-299 Beds
300+ Beds
Nursing Homes
0-19 Employees
Tax-paying
Tax-exempt
20-99 Employees
Tax-paying
Tax-exempt
100+ Employees
Tax-exempt
Tax-paying
Commercial Research Labs
Tax-paying
0-19 Employees
20-99 Employees
100+ Employees
Tax-exempt
Outpatient Care
Physicians' clinics (amb. care)
Tax-paying
Tax-exempt
Freestanding kidney dialysis facilities
Tax-paying
Tax-exempt
Physicians' Offices
Dentists' Offices and Clinics
Offices
Clinics
Tax-paying
Tax-exempt
Medical & Dental Labs
Medical
Dental
Freestanding Blood Banks
Funeral Homes
Fire & Rescue
Corrections
Federal Government
State Government
Local Government
Medical Waste
Per Facility
(tons)
9.75
17.10
52.08
167.28
0.14
0.17
1.14
1.04
2.70
3.44
028
2.19
24.50
7.28
2.26
4.19
1.62
2.31
0.18
0.08
0.14
0.19
1.63
0.51
22.48
0.04
0.05
1.64
1.70
0.34
Incremental Annual Cost Per Facility
Low1
$193
$338
$1,030
$3,308
$3
S3
S23
$21
$53
$68
$6
$43
$485
$144
$45
$83
$32
$46
$4
$2
$3
$4
$32
$10
$445
$1
$1
$32
$34
$7
High1
$906
$1,589
$4,838
$15,539
$13
$16
$106
$97
$250
$320
$26
$204
$2,276
$676
$210
$389
$150
$215
$17
$7
$13
$18
$151
$48
$2,088
$4
$5
$152
$158
$31
1 Based on $0.010 per pound, the average annualized control cost for all commercial MWIs (existing and new).
2Based on $0.046 per pound, the annualized control cost for a new large model commercial MWI.
32
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Table 12
MWI Operators: Model Facilities
(Year =1993)
Industry/Model Facility
Short-term hospitals, excluding psychiatric:
Federal government
Small
Medium
Large
State government
Small
Medium
Large
Local government
Small
Medium
Large
Not-for-profit
Small
Medium
Large
For-profit
Small
Medium
Large
Psychiatric hospitals, short-term and long-term
Small
Medium
Large
Nursing homes
Tax-paying
Tax-exempt
Commercial research laboratories
Tax-paying
Tax-exempt
Commercial incineration facilities
Employment1
393
674
1,738
133
617
2,753
112
432
1,987
139
522
1,725
112
399
1,156
87
259
719
150
150
200
200
N/A
Annual Revenue/Budget2
$18.7
$43.2
$117.0
$8.7
$41.3
$207.3
$5.6
$27.1
$155.0
$8.3
$36.8
$134.6
$7.3
$34.7
$106.7
$5.3
$15.1
$32.6
$4.9
$4.8
$21.2
$21.2
$1.9
1 For hospitals, full-time-equivalent
2 Millions of dollars
N/A - not available
33
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Table 13
Hospitals: Financial/Economic Inputs
(Year =1993)
Short-term hoipiUU,
excluding psychiatric:
Federal government
6-24 Beds
25-49 Beds
50-99 Beds
100-199 Beds
200-299 Beds
300-399 Beds
400-499 Beds
500+ Beds
State government
6-24 Beds
25-49 Beds
50-99 Beds
100-199 Beds
200-299 Beds
300-399 Beds
400-499 Beds
500+ Beds
Local government
6-24 Beds
25-49 Beds
50-99 Beds
100-199 Beds
200-299 Beds
300-399 Beds
40
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Table 14
Other MWI Operators: Financial/Economic Inputs
(Year = 1993)
Other MWI Operators
Average Employment Per
Facility
Average Revenue Per
Facility
Nursing homes
Tax-paying
100+ employees
Tax-exempt
50-99 employees
100+ employees
148.2
74.3
189.3
$4,846,944
$2,063,489
$6,210,832
Commercial research
laboratories
Tax-paying
50-99 employees
100+ employees
Tax-exempt
68.3
469.7
139.5
$7,299,521
$49,670,443
14,761,754
Commercial incineration
N/A
$1,850,640'
'Based on 7,711,000 pounds per year @ 24 cents per pound
N/A - not available
35
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3. Model Facility Impacts
The facility-specific price increase is defined as the price increase necessary for an individual
facility to fully recover control costs. It is calculated as the ratio of model facility annualized
control costs to annual revenue. This provides an indication of the impact of the regulation on
"typical" facilities in each industry. This calculation is then compared to the market price increase
(i.e., the average industry-wide price increase). To the extent that an industry is competitive,
individual firms are constrained to institute price increases that do not significantly exceed the
market price increase. For all but commercial MWIs, the analysis assumes that the facility-
specific price increase may not be achievable if it exceeds the market price increase by more than
one percentage point. For commercial MWIs, it is assumed that the facility-specific price increase
may not be achievable if it exceeds the market price increase by more than two percentage points.
More pricing latitude is given to commercial MWI operators for two reasons: 1) commercial
incineration is not subject to the same institutional pricing constraints as the health care sector,
and 2) commercial incineration fees could actually get a boost from the regulation as a result of
switching from on-site incineration and an increase in the demand for commercial incineration
services.
The price increases necessary for model facilities to recover annualized control costs under
scenario A, no switching, are shown in Table ISA. For all but commercial incineration facilities,
these price increases are considered achievable if they do not exceed the market price increase
(see Table 6A) by more than one percentage point. Where the difference is more than one
percentage point (e.g., small local government hospitals), Table 15B shows that the price increase
necessary to recover annual switching costs, whether under Scenario B or Scenario C, is
achievable, in no case exceeding the market price increase (see Tables 6B and 6C) by more than
one percentage point. It can therefore be concluded that where switching to an alternative
method of medical waste disposal (e.g., off-site incineration) is an option, the regulation does not
have any significant price impacts. (The lower price impacts in Table 15B compared to Table
15 A also suggest - as is already incorporated into scenarios B and C - that many facilities may
find switching cost-attractive regardless of whether the price impacts of installing controls are
significant.)
Not all facilities may have switching as an option, however. Recall that switching may not be
possible for some MWIs that burn a small amount of medical waste and are located far away from
an urban area. A comparison of Table ISA with Table 6A reveals that the facility-specific price
increase for small rural MWIs exceeds the market price increase by more than one percentage
point in the following instances: local government hospitals under regulatory options one through
three, for-profit hospitals under regulatory option three, psychiatric hospitals under regulatory
options one through three, and both tax-paying and tax-exempt nursing homes under regulatory
options one through three. In the original EIA, the ratio of annualized control costs to before-tax
net income - indicating the percent reduction in before-tax net income if control costs are fully
absorbed - was calculated. Repeating this calculation for the above cases of small rural MWIs
36
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Table ISA
Price Impacts for Model Facilities Operating On-site MWIs: New Sources
Scenario A: No Switching
Model Facility
Short-term hospitals, excluding psychiatric:
Federal government
Small
Urban
Rural
Medium
Large
State government
Small
Urban
Rural
Medium
Large
Local government
Small
Urban
Rural
Medium
Large
Not-for-profit
Small
Urban
Rural
Medium
Large
For-profit
Small
Urban
Rural
Medium
Large
Psychiatric hospitals, short-term and long-term
Small
Urban
Rural
Medium
Large
Nursing homes
Tax-paying
Urban
Rural
Tax-exempt
Urban
Rural
Commercial research labs
Tax-paying
Tax-exempt
Commercial incineration facilities*
Annualized Control Costs as a Percent of Revenue/Budget
Regulatory
Option 1
0.37
0.37
0.37
0.18
0.78
0.78
0.39
0.10
1.22
1.22
0.59
0.13
0.83
0.83
0.43
0.15
0.93
0.93
0.46
0.19
1.28
1.28
1.06
0.64
1.39
1.39
1.42
1.42
0.75
0.75
19.35
Regulatory
Option 2
0.37
0.37
0.38
0.18
0.78
0.78
0.40
0.10
1.22
1.22
0.16
0.13
0.83
0.83
0.45
0.15
0.93
0.93
0.48
0.19
1.28
1.28
1.10
0.64
1.39
1.39
1.42
1.42
0.78
0.78
19.35
Regulatory
Option 3
0.42
0.42
0.38
0.18
0.90
0.90
0.40
0.10
1.40
1.40
0.61
0.13
0.95
0.95
0.45
0.15
1.07
1.07
0.48
0.19
1.47
1.47
1.10
0.64
1.59
1.59
1.63
1.63
0.78
0.78
19.35
' Assumes a new commercial incinerator facility is completely uncontrolled in the baseline.
37
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Table 1SB
Price Impacts of Switching for Model Facilities Operating On-site MWb: New Sources
Scenarios B and C
Model Facility
Short-term hospitals, excluding psychiatric:
Federal government
Small - Urban
Rural'
Medium - Urban
Rural
Large- Urban
Rural
State government
Small - Urban
Rural'
Medium - Urban
Rural
Large- Urban
Rural
Local government
Small - Urban
Rural'
Medium - Urban
Rural
Large - Urban
Rural
Not-for-profit
Small - Urban
Rural1
Medium - Urban
Rural
Large- Urban
Rural
For-profit
Small - Urban
Rural'
Medium - Urban
Rural
Large- Urban
Rural
Psychiatric hospitals, short-term and long-term
Small - Urban
Rural'
Medium - Urban
Rural
Large- Urban
Rural
Nursing homes
Tax-paying - Urban
Rural1
Tax-exempt- Urban
Rural'
Commercial research bibs
Tax-paying - Urban
Rural
Tax-exempt - Urban
Rural
Annual Switching Costs as a Percent of Revenue/Budget
Scenario B - Switching With Waste
Segregation
003
004
005
006
008
on
006
008
005
007
005
006
009
013
007
010
006
008
006
009
005
008
007
0.10
0.07
010
006
008
009
012
010
014
0.13
019
029
040
0.11
0.15
Oil
0.15
0.09
0.13
009
013
Scenario C - Switching Without
Waste Segregation
010
017
017
027
029
047
022
036
018
029
016
027
034
056
0.27
044
022
0.36
023
038
020
032
025
041
0.26
043
021
034
032
052
0.36
0.59
0.48
078
105
170
0.39
0.64
040
065
034
0.56
0.34
0.56
'Does not apply to facilities that are remote (i e., more than 50 miles from an SMSA) and bum less than 2,000 pounds of medical waste per week.
38
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(using earnings data updated to 1993), impacts ranging from 16.03 percent for for-profit hospitals
under regulatory option three to 46.61 percent for tax-exempt nursing homes under regulatory
option three were found. All of these impacts can be considered significant.
Such facilities may therefore be prevented from installing a new MWI. If switching is also not
possible, a prospective new facility could be prevented from going into business, or an existing
facility that needs to replace an existing MWI with a new MWI could have to shut down.
However, this is likely to apply, at the most, to only a few of the projected 85 new small MWIs
from 1996 to 2000. Only a few of these 85 new MWIs are likely to be located far away from an
urban area. Moreover, such MWIs may still have switching opportunities. As the commercial
incineration industry continues to grow (with additional impetus being provided by the EG and
NSPS), it is possible that services will be extended to remote, isolated areas that are currently not
served. On-site autoclaving is another possible treatment alternative. If a facility had planned to
invest in a new MWI, it stands to reason that an on-site autoclave unit of comparable cost would
be affordable. Additionally, a facility that had planned - by virtue of operating an on-site MWI -
to open in a remote area without access to commercial incineration services, might be able to
reconsider its location decision, and locate instead in an area with such access.
Switching may also not be an option for commercial MWIs. (While commercial autoclaving can
treat medical waste, it may not be a viable switching option for all commercial MWI operators.)
Table ISA shows that the facility-specific price impact for commercial MWIs is 19.35 percent
under all three regulatory options. This is the price increase that a new large model commercial
MWI that would otherwise (i.e., in the absence of the NSPS) have been "uncontrolled" will
require to recoup control costs. Because it deviates significantly from the market price increase
(4.12%), it may not be achievable. The impact, in turn, on net income of absorbing a significant
portion of control costs is liable to be prohibitive. However, these impacts apply only to new
commercial MWIs that would otherwise have been completely uncontrolled. This may not be a
realistic assumption. To wit, only several of the 79 commercial MWIs in the existing MWI
inventory are completely uncontrolled. To the extent that new commercial MWIs would
otherwise have had at least some controls, the impacts would not be as great.
Consequently, just as only several of the 59 facilities operating the 79 commercial MWIs in the
existing MWI inventory were found to be significantly impacted by the Emission Guidelines (EG),
at the most only a few - if any - of the facilities that will operate, or would have operated, the
projected 10 new commercial MWIs over the next five years are likely to be significantly impacted
by the NSPS. (A "significant impact" could be construed as either shutting down instead of
replacing an existing commercial MWI, or canceling plans to go into business or expand by
building and putting into service a new commercial MWI.) Instead, most, if not all, of these
facilities are likely to either go ahead with their plans to build new MWIs or, if possible, find an
alternative such as commercial autoclaving.
39
-------
Price impacts for model facilities that do not operate an MWI (off-site generators) are shown in
Table 16. These facilities represent the vast majority of medical waste generators. All impacts
are very small and are not considered significant.
This economic impact analysis has examined industries that will be directly affected by the
regulation, namely industries that generate or treat medical waste. Secondary impacts such as
those on air pollution device vendors and MWI vendors were not estimated due to data
limitations. Air pollution device vendors are expected to experience an increase in demand for
their products due to the regulation. The regulation is also expected to increase the demand for
commercial MWI services. Due to economies of scale, however, there is likely to be a demand
shift from smaller incinerators to larger incinerators. Therefore, vendors of small MWIs may be
adversely affected by the regulation. Lack of data on the above effects prevents quantification of
economic impacts on these secondary sectors.
V. Small Entity Impacts
In accordance with the Regulatory Flexibility Act of 1980 and its amendment in 1996 by the Small
Business Regulatory Enforcement Fairness Act (SBREFA), it is necessary to determine if the
NSPS will have a "significant impact on a substantial number of small entities."4 As demonstrated
below, the NSPS are determined not to have a significant economic impact on a substantial
number of small entities under any regulatory option.
Three types of small "entities" are impacted by the regulation: small businesses, small nonprofit
organizations, and small governmental jurisdictions. Examples of impacted businesses include
for-profit hospitals and tax-paying nursing homes. Examples of impacted nonprofit organizations
include not-for-profit hospitals and, in many cases, tax-exempt nursing homes. Examples of
impacted governmental jurisdictions include those (e.g., municipalities, counties, states) that
operate hospitals and probably some tax-exempt nursing homes.
The NSPS will impact many facilities that generate medical waste - not only facilities that were
planning to purchase and install a new MWI over the next five years, but also facilities that would
have sent their medical waste off-site to be incinerated by a new MWI over the next five years.
MWI operators are directly impacted by having to meet the control requirements of the regulation
while "off-site generators" face the likelihood of higher fees for commercial incineration. Off-site
generators represent the vast majority of facilities impacted by the regulation. While perhaps half
of all hospitals operate on-site MWIs, the great majority of nursing homes and research labs do
not. Moreover, the following industries were defined to exist exclusively of facilities that do not
operate on-site MWIs: medical and dental labs, outpatient care, physicians' offices, dentists'
offices and clinics, blood banks, funeral homes, fire and rescue operations, and correctional
facilities. Table 16 shows that economic impacts of the EG and NSPS (cumulatively) on facilities
that have to pay more for commercial incineration are insignificant. The increase in fees could be
recovered with a price increase of, at the most, only 0.03 percent (freestanding blood banks).
40
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Table 16
Price Impacts for Model Facilities Not Operating On-site MWIs: New Sources
Hospitals
<50Beds
50-99 Beds
100-299 Beds
300+ Beds
Nursing Homes
0-1 9 Employees
Tax-paying
Tax-exempt
20-99 Employees
Tax-paying
Tax-exempt
1 00+ Employees
Tax-exempt
Tax-paying
Commercial Research Labs
Tax-paying
0-1 9 Employees
20-99 Employees
100+ Employees
Tax-exempt
Outpatient Care
Physicians' clinics (amb care)
Tax-paying
Tax-exempt
Freestanding kidney dialysis facilities
Tax-paying
Tax-«xempt
Physicians' Offices
Dentists' Offices and Clinics
Offices
Clinics
Tax-paying
Tax-exempt
Medical & Dental Labs
Medical
Dental
Freestanding Blood Banks
Funeral Homes
Fire & Rescue
Corrections
Federal Government
State Government
Local Government
Incremental Annual Cost as a Percent of Revenue/Budget
Low1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
001
0
0
0
0
0
High1
002
0.01
001
001
0
01
001
001
01
01
0
0
01
01
001
001
001
001
0
0
0
0
001
002
003
0
0
0
0
0
1 Based on S0.010 per pound, the average annualized control cost for all commercial MWIs (existing and new).
2Based on $0.046 per pound, the annualized control cost for a new large model commercial MWI.
41
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It remains, therefore, to look at MWI operators. Four industries have been defined as including
MWI operators: hospitals, nursing homes, research labs, and commercial incineration. The U.S.
Small Business Administration (SB A) definition of a small business for hospitals, nursing homes,
and commercial MWI operators is $5 million or less in annual revenue averaged over the past
three years. For research labs, the SB A definition is 500 employees or fewer.5 A nonprofit
organization is considered "small" if it is "independently owned and operated and not dominant in
its field." A governmental jurisdiction is considered "small" if its population is 50,000 or less.6
It has been seen in this revised EIA that - due to the widespread opportunity to switch to an
alternative method of medical waste treatment and disposal - the economic impacts of the NSPS
on MWI operators of all sizes are generally not significant. In general, the cost of controls or the
cost of switching can be recovered with a price increase that does not significantly exceed the
market price increase. This holds for small businesses, small nonprofit organizations, and, by
implication, small governmental jurisdictions (if a government facility is not significantly impacted,
it can be assumed that the jurisdiction is not significantly impacted).
There are two exceptions. Significant economic impacts were found under all three regulatory
options for 1) uncontrolled commercial MWIs, and 2) some small, rural, remote MWIs that may
not have switching opportunities.
However, not all of these significantly impacted MWIs are necessarily operated by a small entity.
For example, the small intermittent MWI for which significant impacts were found was assigned
to hospitals with 40 beds and nursing homes with 150 employees. Table 12 shows that hospitals
with 40 beds have average revenue ranging from $5.3 million (psychiatric hospitals) to $18.7
million (Federal hospitals). This exceeds the threshold for a small hospital, $5.0 million,
suggesting that most hospitals that will operate a new small MWI are not "small." Average
revenue for nursing homes in Table 12 is $4.8-4.9 million, just below the $5.0 million small-
business cutoff. Many nursing homes that will operate a new small MWI - perhaps close to half-
are therefore not "small." Furthermore, the majority of MWIs are not operated by a public, or
government, facility, suggesting that fewer than half of the small, rural, remote new MWIs would
be under the jurisdiction of a small government.
In any case, the number of significant impacts is not considered "substantial." Only a few - if any
- of the facilities that will operate, or would have operated, the projected 10 new commercial
MWIs over the next five years are likely to be significantly impacted. Similarly, only a few, at the
most, of the 85 new small MWIs projected for the next five years are likely to be precluded from
switching opportunities and would therefore be significantly impacted. These numbers are not
only independently small, but also small in relation to the total number of facilities that will be
impacted by the NSPS. (This total number is difficult to estimate without knowing approximately
how many facilities would, in the absence of the NSPS, have had their medical waste incinerated
off-site at a new commercial MWI.)
42
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Finally, it should be noted that in one important sense, the NSPS have differential impacts that
actually favor small entities. MWIs tend to be located at large facilities as opposed to small
facilities. (It takes certain economies of scale to be able to justify operating an on-site MWI.)
Tables ISA and 15B show that the price increase necessary for MWI operators to recover control
costs or switching costs ranges up to 1.70 percent (large rural psychiatric hospitals; scenario C,
switching without waste segregation). In contrast, Table 16 shows that impacts of the EG and
NSPS (cumulatively) on the generally smaller facilities that send their medical waste off-site to be
incinerated are minimal. The estimated increase in the cost of off-site incineration, 1.0-4.6 cents
per pound, could be recovered with a price increase of, at the most, only 0.03 percent
(freestanding blood banks).
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References
1. U.S. Environmental Protection Agency. Medical Waste Incinerators - Background
Information for Proposed Standards and Guidelines: Analysis of Economic Impacts for New
Sources. EPA-453/R-94-048a. July 1994.
2. U.S. Environmental Protection Agency. Addendum to Analysis of Economic Impacts for New
Sources. EPA-453/R-94-048a. July 1994.
3. "Cost Information for New MWI's." Memorandum submitted by Brian Strong, Midwest
Research Institute, to Linda Chappell, U.S. Environmental Protection Agency. February 21,
1997.
4. EPA SBREFA Task Force. "EPA Interim Guidance for Implementing the Small Business
Regulatory Enforcement Fairness Act and Related Provisions of the Regulatory Flexibility Act."
February 1997.
5. Small Business Administration. "Small Business Size Standards." 13 Code of Federal
Register, Part 121. January 31, 1996 (Volume 61, Number 21).
6. Office of Regulatory Management and Evaluation. "EPA Guidelines for Implementing the
Regulatory Flexibility Act." April 1992.
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1. REPORT NO.
EPA-453/R-97-008b
TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
2.
4. TITLE AND SUBTITLE
Hospital/Medical/Infectious Waste Incinerators: Background
Information for Promulgated Standards and Guidelines -
Analysis of Economic Impacts for New Sources
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Air Quality Strategies and Standards Division (Mail Drop 15)
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
12. SPONSORING AGENCY NAME AND ADDRESS
Director
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
July 1997
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
Published in conjunction with promulgated air emission standards and guidelines for
hospital/medical/infectious waste incinerators
16. ABSTRACT
The economic impact analysis uses annualized control costs in conjunction with economic and financial
parameters to estimate potential economic impacts that may be experienced by existing facilities in
industries that generate hospital waste or medical/infectious waste. Economic impacts such as price,
output, and employment changes are examined for industries such as hospitals, nursing homes, and
veterinary facilities.
17.
KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Air Pollution
Pollution Control
Standards of Performance
Emission Guidelines
Medical Waste Incinerators
Hospital/Medical/Infectious Waste
Incinerators
18. DISTRIBUTION STATEMENT
Release Unlimited
b. IDENTIFIERS/OPEN ENDED TERMS
Air Pollution Control
Solid Waste
Medical Waste
Incineration
Hospital Waste
Infectious Waste
19. SECURITY CLASS (Report)
Unclassified
20. SECURITY CLASS (Page)
Unclassified
c. COSATI Field/Group
21. NO. OF PAGES
44
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
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