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Table 6 presents annual costs for those industries not operating HMIWI ("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 by their throughput. The
incremental cost of commercial incineration is calculated to be 0.63 cents per pound under all
regulatory options. Note in Tables 5A through 5C that industry-wide annualized control costs for
commercial HMIWI vary insignificantly by regulatory option, increasing only slightly from
regulatory option 4 and regulatory option 5. This is because control requirements do not vary by
regulatory option for commercial HMIWI.
Table 6
Industry-wide Annual Costs for Industries Not Operating
On-site Medical Waste Incinerators: Existing 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
$222,115
$ 11,358
$444,230
$109,795
$331,910
$ 61,839
$ 20,192
$ 41,647
$1,243,087
1 Assumes that all medical waste is incinerated off-site at an incremental cost of 0.63 cents per pound, the average cost
increase for commercial HMIWI
25
-------
5.4 Industry-wide Annualized Control Costs - New Sources
Tables 7A, 7B, and 7C present national annualized control costs for those industries that operate
HMIWI ("direct control costs").7 Annualized control costs are highest under scenario A (Table
7A). 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 HMIWI will purchase emission control equipment. This scenario does not allow for the
possibility of switching to alternative methods of waste treatment and disposal.
Scenario B 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 HMIWI. In addition,
control requirements for commercial HMIWI (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 8 presents annual costs for those industries not operating HMTWI ("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.
5.5 Industry-Wide Economic Impacts - Existing Sources
Industry wide impacts 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 impact on affected labor markets in terms of employment losses or workers lost. These
impacts are summarized in Tables 9 and 10.
As can be seen in Table 9, industries that generate hospital waste and/or medical/infectious waste
and operate onsite incinerators (i.e., hospitals, nursing homes, etc.) are expected to experience
average price increases in the range of 0% to 0.14%, depending on the industry, regulatory
option, and scenario analyzed. Table 10 shows that these industries are expected to experience
output and employment impacts in the range of 0% to 0.18%. In addition, the revenue impacts
26
-------
Table 7 A
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
' Assumes Regulatory Option 5 for existing HMIWI, 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 HMIWl, 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 HMIWI, the most stringent Emission Guidelines that
would be considered in combination with regulatory option 3 of the NSPS for new sources.
27
-------
Table 7B
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 3*
$ 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 HMIWI, 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 HMIWI, 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 HMIWI, the most stringent Emission Guidelines that
would be considered in combination with regulatory option 3 of the NSPS for new sources
28
-------
Table 7C
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 22
$ 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 HMIWI, 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 HMIWI, 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 HMIWI, the most stringent Emission Guidelines that
would be considered in combination with regulatory option 3 of the NSPS for new sources
29
-------
Table 8
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 HMIWI (existing and new).
30
-------
Table 9
Hospital/Medical/Infectious Waste Incineration
Industry-wide Price* Impacts - Existing Sources
Percent Increase (%)
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
Range for Regulatory Options 1-6
Scenario A
No Switching
0.02-0.05
0.02-0.05
0.05-0 14
0
0
0
0
0
0
0
0
2.6
Scenario B
Switching with Waste
Segregation
0.01
0.01
0.03-0 04
0
0
0
0
0
0
0
0
2.6
Scenario C
Switching with No
Waste Segregation
0.02-0.03
0.02-0.03
0.05-0 09
0
0
0
0
0
0
0
0
2.6
* The price increase percentages reported represent the pnce increase necessary to recover annualized emission control
costs for each industry
31
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Table 10
Hospital/Medical/Infectious Waste Incineration
Industry-wide Output, Employment and Revenue Impacts - Existing Sources
Industry
Hospitals
Output decrease (%)
Employment loss (# of jobs)
Revenue increase or (decrease) (%)
Nursing homes
Output decrease (%)
Employment loss (# of jobs)
Revenue increase or (decrease) (%)
Laboratories:
Research
Output decrease (%)
Employment loss (# of jobs)
Revenue increase or (decrease) (%)
Medical/dental
Output decrease (%)
Employment loss (# of jobs)
Revenue increase or (decrease) (%)
Funeral homes
Output decrease (%)
Employment loss (# of jobs)
Revenue increase or (decrease) (%)
Physicians offices
Output decrease (%)
Employment loss (# of jobs)
Revenue increase or (decrease) (%)
Dentists offices and clinics
Output decrease (%)
Employment loss (# of jobs)
Revenue increase or (decrease) (%)
Outpatient care
Output decrease (%)
Employment loss (# of jobs)
Revenue increase or (decrease) (%)
Freestanding blood banks
Output decrease (%)
Employment loss (# of jobs)
Revenue increase or (decrease) (%)
Fire and rescue operations
Output decrease (%)
Employment loss (# of jobs)
Revenue increase or (decrease) (%)
Correctional facilities
Output decrease (%)
Employment loss (# of jobs)
Revenue increase or (decrease) (%)
Range for Regulatory Options 1-6
Scenario A
No Switching
0-0.02
0-660
0.01-0.05
0 01-0.03
97-494
0.01-003
0.05-0.18
87-287
(0.04)-0
0
2-4
0
0
0
0
0
0-1
0
0
1
0
0
0-1
0
0
0
0
0
0
0
0
0
0
Scenario B
Switching with Waste
Segregation
0-0.01
0-202
0.01
0-0.01
61-151
0-0.01
0.03-0.06
54-88
(O.Ol)-O
0
2-4
0
0
0
0
0
0-1
0
0
1
0
0
0-1
0
0
0
0
0
0
0
0
0
0
Scenario C
Switching with No Waste
Segregation
0-0.01
0-415
0.01-0.03
0.01-002
94-310
001-0.02
0.05-0.11
83-180
(0.03)-0
0
2-4
0
0
0
0
0
0-1
0
0
1
0
0
0-1
0
0
0
0
0
0
0
0
0
0
32
-------
for these industries are expected to range from an increase of 0.05% to a decrease of 0.04%. An
increase in industry revenue is expected to occur in cases where the price elasticity of demand for
an industry's product is inelastic or between 0 and -1. Such a price elasticity indicates that output
changes are 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 a product of price and
output, a less than proportional change in output compared to price means that total revenue
should increase.
The following example illustrates how the above price impacts could be interpreted for the
hospital industry. Table 9 shows that for hospitals, 0.03% is estimated as the price increase
necessary to recover annual control costs assuming regulatory option 6 (the most stringent
regulatory option) and scenario C, switching with no waste segregation. This change in price 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 equivalent of out-patient
days at hospitals.) The total annualized control cost under regulatory option 6, scenario C for the
hospital industry is $92.2 million, or $.30 per adjusted patient day. This means the average price
increase that an individual would experience for each hospital patient-day is expected to equal 30
cents.
Table 9 also shows that the average price impact for the commercial HMIWI industry is
approximately a 2.6% increase in price. Cost and economic impact estimates are the same for the
commercial HMIWI industry regardless of the regulatory option analyzed because all six
regulatory options specify identical regulatory requirements. Average Industry wide output,
employment, and revenue impacts were not estimated for this sector because data such as price
elasticity estimates and employment levels were not available.
5.6 Industry-wide Impacts -Existing and New Sources
Industry wide impacts 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 impact on affected labor markets in terms of number of jobs lost. These impacts are
summarized for existing and new sources on Tables 11 and 12.
As can be seen on Table 11, industries that generate hospital waste and/or medical/infectious
waste (i.e., hospitals, nursing homes, etc.) are expected to experience average price increases in
the range of 0% to 0.16%, depending on the industry, regulatory option, and scenario analyzed.
Table 12 shows that these industries are expected to experience output and employment impacts
in the range of 0% to 0.21%. In addition, the revenue impacts for these industries are expected to
range from an increase of 0.05% to a decrease of 0.05%. An increase in industry revenue is
expected to occur in cases where the price elasticity of demand for an industry's product is
inelastic or between 0 and -1. Such a price elasticity indicates that output changes are not very
33
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Table 11
Hospital/Medical/Infectious Waste Incineration
Industry-wide Price* Impacts - New and Existing Sources
Percent Increase (%)
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
Range for Regulatory Options 1-3
Scenario A
No Switching
0.05
005
0 15-0.16
0
0.00
0.00
000
0.00
0.01
0.00
0.00
4.1
Scenario B Switching
with Waste Segregation
0.02
0.02
0.05
0
0.00
0.00
0.00
0.00
0.01
0.00
0.00
4.1
Scenario C
Switching with No
Waste Segregation
0.03
0.03
0.10
0
0.00
0.00
0.00
0.00
0.01
0.00
0.00
4.1
* The price increase percentages reported represent the price increase necessary to recover annualized emission control
costs for each industry.
34
-------
Table 12
Hospital/Medical/Infectious Waste Incineration
Industry
Hospitals
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Nursing homes
Output decrease (%)
Employment loss
Revenue increase or (decrease) (%)
Laboratories:
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) (%)
Range for Regulatory Options 1-6
Scenario A
No Switching
0-0.02
0-772
0.03-0 05
0.02-0.04
269-578
0.02-0 04
0.15-0.21
239-336
(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
0.00
Scenario B Switching with Waste
Segregation
0-0.01
0-231
0.01-0.02
0.01
84-172
001
0.05-0.06
74-100
(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
Scenario C
Switching with No Waste
Segregation
0-0.01
0-489
0 02-0.03
0.01-002
179-366
001-0.02
0.10-0.13
158-213
(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
35
-------
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 a product of price and output, a less than
proportional change in output compared to price means that total revenue should 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 3 for the NSPS coupled with regulatory option 6 for the EG (the most stringent
regulatory options) and scenario C, switching with no waste segregation, is 0.03 percent as shown
in Table 11. 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.) The total annualized control cost under regulatory option 3
(NSPS), regulatory option 6 (EG), and scenario C for the hospital industry is $108.8 million, 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.
Table 11 also shows that the average price impact for the commercial HMIWI industry is
approximately a 4.1% increase in price. Cost and economic impact estimates are the same for the
commercial HMIWI industry regardless of the regulatory option analyzed because all three
regulatory options specify identical regulatory requirements. Average industry-wide output,
employment, and revenue impacts were not estimated for this sector because data such as price
elasticity estimates and employment levels were not available.
5.7 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 RIA prepared for the proposed rule used cost estimates provided on a
model combustor (i.e., HMIWI) basis to estimate economic impacts for model facilities. The
model facility concept not only had to incorporate model HMIWI 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 HMIWI to model facilities had to be developed in the
original RIA.
New information received after proposal made it possible for cost estimates to be developed on a
model facility basis, with key model HMTWI parameters already incorporated into the model
facility concept. Therefore, this document no longer needs to employ the "linking" scheme used
to assign model HMIWI to model facilities in the earlier RIA. The model facilities defined in the
cost analysis are presented in Table 13. Note that hospitals are defined in terms of number of
beds while nursing homes and commercial research laboratories are defined in terms of number of
employees. Note also that commercial incineration facilities are not included in the table. This is
36
-------
Table 13
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
1 50 employees
200 employees
N/A
HMIWI Assignment
Large HMIWI
Medium HMIWI
Small HMIWI
Small HMIWI
Medium HMIWI
Commercial HMIWI
(large)
N/A - not available
because an exception to the model facility approach is made for commercial HMIWI. Instead,
facility-specific impacts are calculated for each of the 59 facilities operating the 79 commercial
HMtWI in the HMIWI inventory. (Costs and impacts for commercial HMIWI will be presented
in the tables that follow as ranges representing all 59 of the commercial HMIWI facilities in the
inventory.)
5.7.1 Model Plant Costs - Existing Sources
Tables 14 and 15 present capital (for scenario A) and annualized (for scenarios A, B, and C) costs
for model HMIWI - existing sources. Scenario A has capital costs because it assumes that all
facilities currently operating an HMIWI will have emission control equipment installed rather than
switch to an alternative technology. 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
HMIWI.
For all HMIWI other than commercial HMIWI and small, rural, remote HMIWI (defined as more
than 50 miles away from an SMS A and burning less than 2,000 pounds of medical waste per
year), scenario A is an unlikely representation of facility-specific impacts for a couple of reasons.
First, the assumption that some currently operated HMIWI will not be replaced by alternative
technologies is unrealistic. The regulation will impose additional costs on HMIWI and, therefore,
will make alternative technologies more attractive - from a cost perspective - in comparison.
Second, the model facility analysis under scenario A examines the cost of imposing emission
37
-------
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-------
Table 15
Annual Costs of Switching for Model HMTWF
Scenarios B and C
Model HMIWI
Small
Urban
Rural2
Medium
Urban
Rural
Large
Urban
Rural
Scenario B - Switching With
Waste Segregation
$5,260
$7,400
$19,944
$28,058
$ 93,584
$131,658
Scenario C - Switching Without
Waste Segregation
$19,200
$31,200
$72,800
$118,300
$341,600
$555,100
1 Switching costs do not vary by regulatory option
2 Does not apply to facilities that are remote (i.e , more than 50 miles from an SMSA) and burn
less than 2,000 pounds of medical waste per week Such facilities are assumed to generally not
have switching opportunities.
control costs on "uncontrolled" HMIWI in the baseline. Many currently operated HMIWI already
have some emission control equipment installed. The costs of meeting any of the regulatory
options would not be from a baseline of "no controls" for these facilities. Therefore, scenario A
represents only the extreme case of HMIWI having no emission controls in the baseline.
Scenario A, on the other hand, is the only scenario that applies to commercial HMIWI and small,
rural, remote HMIWI because they are assumed to not be able to switch to an alternative
technology.
Incremental annual costs for off-site generators are presented in Table 16. The costs reflect two
alternative estimates of the increase in the cost of off-site incineration. The low estimate is 0.63
cents per pound, the average annualized control cost for all commercial HMIWI. The high
estimate derives from an uncontrolled large model commercial HMTWI estimated to have
annualized control costs of $193,694 and to burn 7,711,000 pounds of medical waste annually.
Dividing cost by throughput yields a cost of 2.51 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.
39
-------
Table 16
Annual Costs for Model Facilities Not Operating On-site HMIWI: Existing 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 Laboratories
Tax-paying
0-19 Employees
20-99 Employees
100+ Employees
Tax-exempt
Outpatient Care Clinics
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 Laboratories
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
0.28
2.19
2450
728
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
$123
$216
$657
$2,111
$2
$2
$14
$13
$34
$43
$4
$28
$309
$92
$29
$53
$20
$29
$2
$1
$2
$2
$21
$6
$284
$1
$1
$21
$21
$4
High2
$490
$859
$2,616
$8,404
$7
$9
$57
$52
$135
$173
$14
$110
$1,231
$366
$113
$210
$81
$116
$9
$4
$7
$10
$82
$26
$1,129
$2
$3
$82
$85
$17
1 Based on $0 006 per pound, the average annualized control cost for all commercial HMIWI.
2 Based on $0 025 per pound, the annualized control cost for a large model commercial HMIWI that is uncontrolled in the baseline.
40
-------
5.7.2 Model Plant Costs - New Sources
Tables 17 and 18 present capital (for scenario A) and annualized (for scenarios A, B, and C) costs
for new model HMIWI. Scenario A has capital costs because it assumes that all facilities
expected to operate an HMIWI 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 HMIWI.
For all HMIWI other than commercial HMIWI and small rural HMIWI that are remote from an
urban area, scenario A is an unlikely representation of facility-specific impacts because the
assumption that some potentially new HMIWI will not be replaced by alternative technologies is
unrealistic. The regulation will impose additional costs on new HMIWI 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 HMIWI 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 HMIWI and small rural HMTWI 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 19. 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 HMIWI, existing and
new. The high estimate derives from a new large model commercial HMTWI 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.
5.8 Facility Specific Impacts - Existing Sources
Facility-specific impacts were also estimated for the affected industries. The facility specific price
increase is the price increase necessary for an individual facility to fully recover control costs and
it is calculated as the ratio of model facility annualized control costs to annual revenue. These
estimates, presented in Tables 20 and 21, were calculated for the three switching scenarios. A
cost as a percent of revenue/budget ratio was calculated to provide an indication of the magnitude
of the impact of the regulation on an uncontrolled facility in each industry sector. The facility-
specific cost to revenue/budget ratio was compared to the Industry wide price impact to
determine if the facility's impacts differ significantly from the average Industry wide impacts. This
calculation was then compared to the Industry wide price impact to determine if the facility's
impacts differ significantly from the average Industry wide impacts. A determination of
41
-------
Table 17
Control Costs for Model HMIWI: New Sources
Scenario A; No Switching
Model HMIWI
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
Table 18
Annual Costs of Switching for Model HMIWI'
Model HMIWI
Small
Urban
Rural2
Medium
Urban
Rural
Large
Urban
Rural
Scenario B - Switching With
Waste Segregation
$5,260
$7,400
$19,944
$28,058
$93,584
$131,658
Scenario C - Switching Without
Waste Segregation
$19,200
$3 1 ,200
$72.800
$118,300
$341,600
$555,100
' 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 HMIWI operators.
42
-------
Table 19
Annual Costs for Model Facilities Not Operating On-site HMIWI: New Sources
Industry/Model Facility
Hospitals
<50 Beds
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
0.28
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 CostTer Facility
Low1
$193
$338
$1,030
$3,308
$3
$3
$23
$21
$53
$68
$6
$43
$485
$144
$45
$83
$32
$46
$4
$2
$3
$4
$32
$10
$445
$1
$1
$32
$34
$7
High2
$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 HMIWI (existing and new)
2Based on $0.046 per pound, the annualized control cost for a new large model commercial HMIWI
43
-------
Table 20
Hospital/Medical/Infectious Waste Incineration
Per Facility Impacts Assuming No Switching and Onsite Incineration - Existing Sources
Annualized Control Cost as a Percent of Revenue/Budget (%)
Industry
Hospitals - Short term, excluding psychiatric:
Federal Government
Small
Urban and rural, not remote or ^ 2000 Ibs./week
Rural, remote and • 2000 Ibs./week
Medium
Large
State Government
Small
Urban and rural, not remote or ^ 2000 Ibs./week
Rural, remote and • 2000 Ibs./week
Medium
Large
Local Government
Small
Urban and rural, not remote or <; 2000 Ibs /week
Rural, remote and - 2000 Ibs /week
Medium
Large
Not-for-profit
Small
Urban and rural, not remote or <; 2000 Ibs /week
Rural, remote and < 2000 Ibs./week
Medium
Large
For-profit
Small
Urban and rural, not remote or i 2000 Ibs /week
Rural
Medium
Large
Hospitals - Psychiatric, short term and long term:
Small
Urban and rural, not remote or 2 2000 Ibs /week
Rural, remote and < 2000 Ibs./week
Medium
Large
Nursing Homes:
Tax-Paying
Urban and rural, not remote or ^ 2000 Ibs./week
Rural, remote and < 2000 Ibs./week
Tax-exempt
Urban
Rural
Commercial research labs
Tax-paying
Tax-exempt
Commercial Incineration Facilities*
Scenario A - No Switching
Option 1
0.11
0 11
0.20
0.13
0.23
0.23
0.21
007
036
036
0.32
0.10
0.25
0.25
0.24
0.11
0.28
0.28
0.25
0.14
0.38
0.38
058
047
0.41
0.41
0.42
0.42
0.41
0.41
0-18.36
Option 2
0.38
0.11
0.20
013
0.82
023
0.21
0.07
1.27
036
0.32
0 10
0.86
025
024
0 11
0.97
0.28
0.25
0.14
1.34
0.38
058
0.47
1 45
0.41
1.49
0.42
0.41
041
0-18.36
Option 3
0.38
0.38
0.20
0.13
0.82
082
0.21
0.07
1.27
1.27
0.32
0.10
0.86
0.86
0.24
0.11
0.97
0.97
0.25
0 14
1.34
1.34
0.58
047
1.45
1.45
1.49
1.49
0.41
0.41
0-18.36
Option 4
0.42
0.42
0.20
0.13
0.89
0.89
0.21
0.07
1 39
1 39
0.32
.010
0.94
0.94
024
0 11
1.06
1.06
0.25
0.14
1 46
1.46
0.58
0.47
1.59
1 59
1.62
1.62
0.47
047
0-18.36
Option 5
0.42
0.42
0.23
0.13
0.89
089
0.24
007
1.39
1.39
0.36
0.10
0.94
0.94
0.27
0 11
1.06
1.06
0.28
0.14
1.46
1.46
0.66
0.47
1.59
1.59
1.62
1.62
0.47
0.47
0-20 69
Option 6
047
047 ;
023
0 13
1
1
1 01 I
1 01 1
0.24 1
007 1
" JU £
0 10
0.11 |
j
1.20
1.20
028
0 14
1 65
1 65
0.66
047 ;
1
',
1.79
1.79
1.83
1.83 i
§
047 I
0.47 "•
0-20.69 ':
*This is the range of impacts for all 59 facilities operating commercial incinerators. Only three of these facilities are anticipated to experience cost to
revenue/budget ratios exceeding the significance criteria of 4.6 percent.
44
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Table 21
Hospital/Medical/Infectious Waste Incineration
Per Facility Impacts Assuming Switching from Onsite Incineration to Commercial Disposal Alternatives - Existing Sources
Alternative Waste Disposal Cost as a Percent of Revenue/Budget (%)
Industry
Hospitals - Short term, 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
Rural
Medium - Urban
Rural
Large - Urban
Rural
For-profit
Small - Urban
Rural
Medium - Urban
Rural
Large - Urban
Rural
Hospitals - Psychiatric, short term and long term: Small - Urban
Rural
Medium - Urban
Rural
Large - Urban
Rural
Nursing Homes: Tax-Paying - Urban
Rural
Tax-exempt- Urban
Rural
Commercial research labs: Tax-paying - Urban
Rural
Tax-exempt- Urban
Rural
Scenario B - Switching With
Waste Segregation
0.03
0.04
0.05
0.06
0.08
0.11
0.06
008
005
0.07
0.05
0.06
" 0.09
0.13
0.07
0.08
0.06
0.08
0.06
0.09
0.05
0.08
0.07
0.10
0.07
0.10
0.06
0.08
~ 0.09
0.12
0.10
0.14
0.13
0.19
0.29
0.40
0.11
0.15
0.11
0.15
0.09
0.13
0.09
0.13
Scenario C - Switching
Without Waste Segregation
0.10
0.17
017
0.27
0.29
0.47
0.22
0.36
0.18
0.29
0.16
0.27
0.34
056
0.27
0.44
0.22
0.36
0.23
0.38
0.20
0.32
0.25
0.41
0.26
0.43
0.21
034
0.32
052
0.36
0.59
0.48
0.78
1.05
1.70
0.39
0.64
0.40
0.65
0.34
0.56
0.34
0.56
45
-------
significance - implying that the facility price increase may not be achievable - is made for all but
commercial HMTWI operators if the facility price increase exceeds the average industry-wide, or
"market" price increase by more than one percentage point. For commercial HMIWI operators,
the facility price increase is considered significant if it exceeds the market price increase by more
than two percentage points. More pricing latitude is given to commercial HMIWI 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.
Excluding commercial incineration, Tables 20 and 21 show that facilities with onsite HMIWI that
are currently uncontrolled may experience impacts ranging from 0.03% to 1.83%, depending on
the industry, regulatory option, and scenario analyzed. Commercial incinerator impacts range
from 0% to 20.69%. A comparison of the facility-specific economic impacts expected to occur
under the three switching scenarios to market price increases indicates that the impacts for
facilities that operate on-site HMIWI are generally insignificant. Either the cost of controls or the
cost of switching to an alternative waste treatment and disposal method could be recovered with a
price increase that does not significantly exceed the market price increase. For many firms
currently operating onsite HMIWI the option of switching will be attractive because the economic
impacts of switching to an alternative method of waste disposal are much lower than the
economic impacts from installing emission control equipment for facilities that are currently
uncontrolled.
Two types of HMIWI operators may not be able to switch to an alternative, however:
commercial HMIWI operators, because their line of business is commercial incineration; and
small, rural, remote HMTWI (defined as more than 50 miles away from an SMSA and burning less
than 2,000 pounds of waste per week), which may not have access to waste hauling and/or
commercial incineration services. For commercial HMIWI operators, three of the 59 facilities
operating the 79 commercial HMIWI in the HMIWI inventory were found to be significantly
impacted by the regulation (under all six regulatory options). These facilities may not have to
shut down, since they are completely uncontrolled in the baseline and therefore may currently
enjoy a cost advantage over their competitors (most of which are at least partially controlled in
the baseline), and that the regulation will bring about - due to switching away from on-site
incineration - an increase in the demand for commercial incineration services. Impacts are not
significant for small, rural, remote HMIWI operators under regulatory options one and two.
Under regulatory options three through six, on the other hand, some of these facilities are
significantly impacted and might therefore have to shut down.
Table 22 shows the impacts that would be incurred by medical waste generators that currently use
an offsite waste incineration service. These impacts range from 0% to 0.02% and are considered
negligible impacts. These results indicate that the incremental costs for the vast majority of
medical waste generators are expected to be small.
46
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Table 22
Hospital/Medical/Infectious Waste Incineration
Per Facility Impacts For Firms that Utilize Oflsite Waste Incineration - Existing Sources
Incremental Annual Cost as a Percent of Revenue/Budget (*/«)
Industry
Hospitals
<50 Beds
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 Clinics
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
Incremental Annual Cost as a Percent of Revenue
0-0.01
0-0.01
0-0.01
0-0.01
0
0
0
0
0
0
0
0
0
0
0
0
0
0-0.01
0
0
0
0
0-0.01
0-0.01
0-0.02
0
0
0
0
0
47
-------
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 HMIWI 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 HMIWI 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
HMIWI potentially may be adversely affected by the regulation.
5.9 Facility Specific Impacts - New Sources
Facility-specific impacts were also estimated for the affected industries for new sources. These
estimates, presented in Tables 23 and 24, were calculated for the three switching scenarios. A
cost as a percent of revenue/budget ratio was calculated to provide an indication of the magnitude
of the impact of the regulation on an uncontrolled facility in each industry sector. This calculation
was then compared to the Industry wide price impact to determine if the facility's impacts differ
significantly from the average Industry wide impacts. A determination of significance - implying
that the facility price increase may not be achievable - is made for all but commercial HMTWI
operators if the facility price increase exceeds the average industry-wide, or "market" price
increase by more than one percentage point. For commercial HMIWI operators, the facility price
increase is considered significant if it exceeds the market price increase by more than two
percentage points. More pricing latitude is given to commercial HMIWI 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.
For industries other than commercial incineration, Tables 23 and 24 show that facilities with
onsite HMTWI that are currently uncontrolled may experience impacts ranging from 0.03% to
1.70%, depending on the industry, regulatory option, and scenario analyzed.
For commercial incineration the cost to revenue/budget ratio is 19.35%. A comparison of the
facility-specific economic impacts expected to occur under the three switching scenarios,
presented in Tables 23 and 24, to the anticipated market price increases indicates the impacts for
facilities that operate on-site HMTWI are generally insignificant. For many of the uncontrolled
model facilities, the economic impacts from switching to an alternative method of waste disposal
are much lower than the economic impacts from installing emission control equipment. These
results indicate that the option of switching to a lower cost alternative for waste disposal will be
48
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Table 23
Hospital/Medical/Infectious Waste Incineration
Per Facility Impacts Assuming No Switching and Onsite Incineration - New Sources
Control Cost as a Percent of Revenue/Budget (%)
Industry
Hospitals - Short term, 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
Hospitals - Psychiatric, 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*
Option 1
0.37
0.37
0.37
0.18
0.78
078
0.39
0.10
1.22
1.22
0.59
0.13
083
0.83
0.43
0.15
0.93
0.93
0.46
0.19
1.28
1.28
1.06
064
1.39
1.39
1.42
1.42
0.75
0.75
19.35
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
064
1 39
1 39
1 42
1.42
0.78
0.78
19.35
Option 3
0.42
0.42
0.38
0.18
0.90
0.90
0.40
0.10
1.40
140
0.61
0 13
0.95
0.95
045
0 15
1.07
1.07
0.48
0.19
1 47
1.47
1 10
064
1.59
1.59
1.63
1.63
0.78
0.78
19.35
"This cost to revenue ratio reflects the cost to new HMIWI that would otherwise have been completely uncontrolled.
49
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Table 24
Hospital/Medical/Infectious Waste Incineration
Per Facility Impacts Assuming Switching from Onsite Incineration to Commercial Disposal Alternatives - New Sources
Alternative Waste Disposal Cost as a Percent of Revenue/Budget (%)
Industry
Hospitals - Short term, 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
Rural
Medium - Urban
Rural
Large - Urban
Rural
For-profit
Small - Urban
Rural
Medium - Urban
Rural
Large - Urban
Rural
Hospitals - Psychiatric, short term and long term: Small - Urban
Rural
Medium - Urban
Rural
Large - Urban
Rural
Nursing Homes: Tax-Paying - Urban
Rural
Tax-exempt- Urban
Rural
Commercial research labs: Tax-paying - Urban
Rural
Tax-exempt- Urban
Rural
Scenario B - Switching With
Waste Segregation
0.03
0.03
0.05
0.05
0.08
0.11
0.06
0.08
0.05
0.07
0.05
0.06
0.09
0.13
0.07
0.10
0.06
0.08
0.06
0.09
0.05
0.08
0.07
0.10
0.07
0.10
0.06
0.08
0.09
012
0.10
0 14
013
0 19
029
0.40
0.11
0.15
0.11
0.15
0.09
0.13
0.09
0.13
Scenario C - Switching
Without Waste Segregation
0.10
0.17
0.17
027
0.29
047
022
036
0.18
029
0.16
0.27
034
0.56
0.27
0.44
022
036
0.23
0.38
0.20
0.32
0.25
0.41
026
0.43
0.21
0.34
0.32
052
0.36
0.59
048
078
1.05
1.70
0.39
0.64
0.40
0.65
0.34
0.56
0.34
0.56
50
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an attractive option for some facilities currently using an onsite HMTW1. The decision to switch
to an alternative method of waste disposal should preclude most facilities from experiencing a
significant economic impact. These results support our assertion that implementation of the
regulation will likely result in either scenarios B or C and that the costs and economic impacts of
scenario A are unlikely to occur.
Two types of HMIWI operators may not be able to switch to an alternative, however:
commercial HMIWI operators, because their line of business is commercial incineration; and on-
site HMIWI that burn a small amount of 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 HMIWI over the next five
years, and, at the most, only a few of the projected 85 new small on-site HMIWI 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 a facility closure or the need to cancel
plans to open up, or expand, a facility. For example, operators of small, remote on-site HMIWI
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 HMTWI, 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 HMTWI - 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.
Table 25 shows the impacts that would be incurred by medical waste generators that currently use
an offsite waste incineration service. These impacts range from 0% to 0.02% and are considered
negligible impacts. These results indicate that the incremental costs for the vast majority of
medical waste generators are expected to be small.
This economic impact section examines possible economic impacts that may occur in industries
that will be directly affected by this regulation. Therefore, the analysis includes an examination of
industries that generate medical waste or dispose medical waste. Secondary impacts such as
subsequent impacts on air pollution device vendors and HMTWI vendors are 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. This regulation is also expected to increase demand for
commercial HMIWI services. However, due to economies of scale, this regulation is expected to
shift demand from smaller incinerators to larger incinerators. Therefore, small HMTWI vendors
potentially may be adversely affected by the regulation. Lack of data on the above effects prevent
quantification of the economic impacts on these secondary sectors.
51
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Table 25
Hospital/Medical/Infectious Waste Incineration
Per Facility Impacts For Firms that Utilize Oflsite Incineration - New Sources
Incremental Annual Cost as a Percent of Revenue/Budget (%)
Industry
Hospitals
.50 Beds
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 Clinics
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
Incremental Annual Cost as a Percent of Revenue
0-0.02
0-0.01
0-0.01
0-0.01
0
0-0.1
0-0.01
0-0.01
0-0.1
0-0 1
0
0
0-0.1
0-0.1
0-0.01
0-0.01
0-0.01
0-0.01
0
0
0
0
0-0.01
0-0.02
0.01-0.03
0
0
0
0
0
52
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VI BENEFITS ANALYSIS
A benefit analysis of proposed guidelines and standards for new and existing hospital/ medical/
infectious waste incinerators was contained in Medical Waste Incinerators - Background
Information for Proposed Standards and Guidelines: Regulatory Impact Analysis for New and
Existing Facilities8 (the 1994 HMIWIRIA). Changes in the regulatory options being considered
and the resulting changes in pollutant emissions from new and existing HMIWI have necessitated
a revision to the 1994 benefits analysis. This section incorporates the updated estimates of the
emission changes to provide a revised benefit analysis of some of the regulatory options under
consideration for the final HMIWI rulemaking.
As is discussed in the 1994 HMIWI RIA and is discussed again below, the lack of data regarding
the quantitative relationship between ambient exposure to HAPs and health status prevented (and
still prevents) development of quantitative benefit estimates in the appropriate framework to
compare with cost estimates. As a result, quantifiable benefits are not expected to exceed
quantifiable costs for any of the regulatory options under consideration.
As discussed previously in developing the final HMIWI rule, six regulatory options were
considered for existing sources and three regulatory options were considered for new sources.
For each of these regulatory options, the costs and emission impacts were evaluated under the
three "switching" scenarios (A, B, and C). It is likely that actual conditions for "switching" will
lie between scenarios B and C. Qualitative benefits are discussed below for the various pollutants.
Quantitative benefits of the regulatory options under scenarios B and C are then presented, along
with a comparison of quantifiable benefits with costs.
6.1 Emission Changes
Each of the regulatory options under consideration are expected to reduce HMIWI emissions of
the following pollutants:
Hazardous Air Pollutants
• Cadmium (Cd)
Hydrochloric Acid (HC1)
Lead (Pb)
• Mercury (Hg)
Dioxins
• 2,3,7,8 - chlorinated dibenzodioxins (CDD)
• 2,3,7,8 - chlorinated dibenzofurans (CDF)
• Toxic Equivalent Quantity (TEQ)
53
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Criteria Air Pollutants
• Paniculate Matter (PM)
Sulfur Dioxide (SO2)
• Carbon Monoxide (CO)
• Nitrogen Oxides (NOJ
Each of these categories is discussed below.
6.2 Hazardous Air Pollutants
The 1994 HMIWI RIA summarized the health effects associated with exposure to
hazardous air pollutants (HAPs). The health effects include probable carcinogenic effects
associated with exposure to Cd and Pb, and respiratory effects associated with exposure to Cd,
HC1, and Hg. The HAPs emitted from HMTWI facilities have also been associated with effects on
the central nervous system, neurological system, gastrointestinal system, mucous membranes, and
kidneys.
Although the reductions in the emissions of HAPs are expected to reduce the adverse
health effects mentioned above, the lack of data regarding the quantitative relationship between
ambient exposure to HAPs and health status prevented the development of quantitative benefit
estimates in both the 1994 and the current benefit analyses. To provide some idea of the impact
of the promulgated HMTWI standards and guidelines, Tables 26 and 27 present estimates of the
baseline HAP emissions from HMTWI and the emission reductions associated with the regulatory
options under consideration for existing and new sources, respectively. All of the options under
consideration significantly reduce the HAP emissions from both new and existing HMIWI.
Without information on the quantitative relationship between ambient exposure to these pollutants
and human health, however, the magnitude of the improvement in health associated with these
emission reductions cannot be ascertained.
6.3 Dioxins
The regulatory options under consideration are expected to reduce emissions of CDD, CDF, and
TEQ. A detailed qualitative discussion of the health effects of CDD and CDF was contained in
the 1994 HMIWI RIA. Briefly, the 1994 RIA stated that exposure to CDD/CDF has been linked
to reproductive and developmental effects, changes in hormone levels, and chloracne. Since the
1994 HMTWI RIA, TEQ has been developed as a measure of the toxicity of dioxins. TEQ
measures the more chlorinated compounds of dioxin and thus provides a better indicator of the
part of dioxin that has been linked to the toxic effects associated with CDD/CDF. Unfortunately,
quantitative relationships between the toxic effects mentioned above and exposure to CDD/ CDF
and TEQ have not been developed. Therefore, quantitative estimates of the health effects of
dioxin emission reductions cannot be provided for the current benefit analysis.
54
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Table 26
HAP BASELINE AND EMISSION REDUCTION ESTIMATES
FOR EXISTING SOURCES
(tons/year)
SCENARIO B
Cd
HC1
Pb
Hg
SCENARIO C
Cd
HC1
Pb
Hg
Baseline
Emissions
1.33
6,300
11.9
16.0
1 33
6,300
11 9
160
EMISSION REDUCTIONS
Option 1
0.90
4,981
8.4
146
0.65
3,978
62
139
Option 2
1.12
6,156
10.4
15.2
1.00
6,147
95
148
Option 3
1.13
6,215
10.5
15.2
1 01
6,206
9.6
14.9
Option 4
1.13
6,215
10.5
15.2
1 01
6,206
96
14.9
Option 5
1.13
6,215
10.5
15.2
1 01
6,206
9.6
149
Option 6
1.13
6,215
105
152
1.01
6,206
96
149
Table 27
HAP BASELINE AND EMISSION REDUCTION ESTIMATES
FOR NEW SOURCES
(tons/year)
SCENARIO B
Cd
HC1
Pb
Hg
SCENARIO C
Cd
HC1
Pb
Hg
Baseline
Emissions
0.056
70.6
0.429
0.235
0.056
70.6
0.429
0.235
EMISSION REDUCTIONS
Option 1
0051
68.9
0.394
0.173
0.046
67.1
0.363
0.107
Option 2
0051
68.9
0.394
0.173
0.046
67.1
0.363
0.107
Option 3
0.051
68.9
0.394
0.173
0.046
67.1
0.363
0.107
55
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Table 28 and 29 summarize the impact of the regulatory options on HMTWI CDD/CDF and TEQ
emissions. All regulatory options under consideration will significantly reduce dioxin emissions
from HMIWI. Although it is probable that the adverse health risks associated with exposure to
CDD/CDF and TEQ will be reduced as a result of the final HMIWI regulation.
Table 28
DIOXIN BASELINE AND EMISSION REDUCTION ESTIMATES
FOR EXISTING SOURCES
(g/year)
SCENARIO B
CDD/CDF
TEQ
SCENARIO C
CDD/CDF
TEQ
Baseline
Emissions
7,219
148
7,219
148
EMISSION REDUCTIONS
Option 1
6,831
139
6,625
135
Option 2
7,007
143
6,910
141
Option 3
7,015
143
6,917
141
Option 4
7,015
143
6,917
141
Option 5
7,017
143
6,917
141
Option 6
7,017
143
6,917
141
Table 29
DIOXIN BASELINE AND EMISSION REDUCTION ESTIMATES
FOR NEW SOURCES
(g/year)
SCENARIO B
CDD/CDF
TEQ
SCENARIO C
CDD/CDF
TEQ
Baseline
Emissions
466
1.07
466
1.07
EMISSION REDUCTIONS
Option 1
40.7
1.0
35.0
10
Option 2
40.7
1.0
35.0
1.0
Option 3
40.7
1.0
407
1 0
56
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6.4 Criteria Air Pollutants
Several criteria pollutants will be impacted by the end of regulatory options under consideration.
Table 30 and 31 report the baseline HMIWI emissions of PM, SO2, CO, and NOX, and the
expected reductions in emissions resulting from the regulatory options for existing and new
sources.
The health and welfare effects of exposure to PM were qualitatively discussed in the 1994 HMIWI
RIA. The health effects associated with exposure to PM include premature mortality as well as
morbidity. The morbidity effects of PM exposure have been measured in terms of increased
hospital and emergency room visits, days of restricted activity or work loss, increased respiratory
symptoms, and reductions in lung function. The welfare effects of PM exposure include increased
soiling and visibility degradation.
SO2 has been associated with respiratory symptoms and pulmonary function changes in exercising
asthmatics and may also be associated with respiratory symptoms in non-asthmatics. In addition
to the effects on human health, SO2 has also been linked to adverse welfare effects, such as
materials damage, visibility degradation, and crop and forestry damage.
Table 30
CRITERIA POLLUTANT BASELINE AND EMISSION REDUCTION ESTIMATES
FOR EXISTING SOURCES
(tons/year)
SCENARIO B
PM
SO2
CO
NOX
SCENARIO C
PM
SO2
CO
NOX
Baseline
Emissions
1,036
271
506
1,277
1,036
271
506
1,277
EMISSION REDUCTIONS
Option 1
823
62
407
292
697
0
378
0
Option 2
957
81
416
383
907
0
378
0
Option 3
960
81
416
383
911
0
378
0
Option 4
962
81
416
383
915
0
378
0
Option 5
963
83
417
390
922
0
378
0
Option 6
964
83
417
390
923
0
378
0
57
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Table 31
CRITERIA POLLUTANT BASELINE AND EMISSION REDUCTION ESTIMATES
FOR NEW SOURCES
(tons/year)
SCENARIO B
PM
SO2
CO
NOX
SCENARIO C
PM
SO2
CO
NOX
Baseline
Emissions
30.4
31.3
14.9
148
30.4
31.3
14.9
148
EMISSION REDUCTIONS
Option 1
28.1
16
8
76
25.9
0
0
0
Option 2
28.1
16
8
76
25.9
0
0
0
Option 3
28.1
16
8
76
25.9
0
0
0
CO affects the oxygen-carrying capacity of hemoglobin and, at current ambient concentrations,
has been related to adverse health effects among persons with cardiovascular and chronic
respiratory disease. Both congestive heart failure and angina pectoris have been related to CO
exposure.
NOX has also been shown to have an adverse impact on both human health and welfare. The
effects associated with NOX include respiratory illness, damages to materials, crops, and forests,
and visibility degradation.
Concentration-response functions have been developed for the majority of the health and welfare
effects mentioned above. In these functions, a quantitative relationship between a specific health
or welfare end point and exposure is established. Exposure, however, is generally measured by
models in terms of ambient concentration of a pollutant. To do this, facility specific information is
needed to determine how changes in control technologies will impact pollutant concentrations in
the ambient air. Because such data is not available, a direct application of these concentration-
response functions to the present analysis is not possible.
An approximation of the magnitude of these effects can be obtained, however, using the results of
existing studies that have evaluated the health and welfare effects of reductions in pollutant
concentrations. The Benefit-Cost Analysis of Selected New Source Performance Standards for
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Paniculate Matter* (1985) is particularly useful to develop quantitative benefit estimates for the
PM emission reductions.13 Unfortunately, no studies are representative or available to
approximate the benefits associated with the SO2, CO, and NOX emission reductions.
The Benefit-Cost Analysis of Selected New Source Performance Standards for Paniculate Matter
considered a diverse set of sources located in 721 different counties in the United States to
develop estimates of the benefits per ton of PM reduced. The benefit categories considered in this
analysis included mortality, morbidity, household soiling and materials damage. The national
weighted average (weighted by tons reduced) of benefit per ton values estimated for 1995 was
$6,075 (1993 dollars). Wide variations exist in the amount of benefits obtained across different
areas. The value is dependent on the density of the exposed population, geographic and
meteorological conditions, and the ambient concentrations of PM. As a result, the county specific
benefits per ton ranged from $0 to over $100,000. This analysis assumes that the weighted value
of $6,075 per ton is representative on average. With this value, the PM benefit estimates of the
regulatory options for Scenarios B and C are displayed in Table 32.
Table 32
MONETIZED BENEFITS FOR HMIWI REGULATORY OPTIONS
(thousands of 1993 dollars)
SCENARIO B
Existing Sources
New Sources
SCENARIO C
Existing Sources
New Sources
Option 1
$4,999.7
$170.6
$4,234.3
$157.3
Option 2
$5,813.8
$170.6
$5,510.0
$1573
Option 3
$5,838.1
$170.6
$5,534.3
$157.3
Option 4
$5,844.2
-
$5,558.6
-
Option 5
$5,856.3
-
$5,601 1
-
Option 6
$5,856.3
-
$5,607.2
-
b Two more recent studies, The Benefits and Costs of the Clean Air Act, 1970 to 1990'°
and Regulatory Impact Analysis for Proposed Paniculate Matter National Ambient Air Quality
Standard" are expected to update these values. Since they are both currently in draft form, they
were not able to be used as of the completion of this analysis.
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6.5 Qualifications
This analysis considers a subset of the total benefits that will accrue from the HMIWI rulemaking.
The EPA is not currently able to quantitatively evaluate all human and environmental benefits
associated the rule's air quality improvements, and is even more limited in its ability to assign
monetary values to these benefit categories. Categories that are not evaluated include several
health and welfare endpoints (categories) as well as entire pollutant categories. Therefore, it is
likely that the monetary estimate of benefits is an underestimate of actual health and welfare
improvements that will result from the implementation of the rule.
There is also some uncertainty and variance in the values chosen to monetize benefits. Therefore,
the benefits reported in Table 32 should be viewed with respect to a number of qualifications.
First, the benefit per ton estimates implicitly assume that there is a linear relationship between
benefits and changes in emissions of pollutants from previous studies and the benefits associated
with emission reductions from the HMIWI rule. If the relationship is non-linear, the resulting
benefit estimates may be biased. This may be particularly important if a threshold exists below
which ambient concentrations of a pollutant do not contribute to adverse human health or the
environmental impacts.
Second, the use of benefit per ton estimates from existing studies assumes that the population
distributions in these studies is not too dissimilar from the population distributions of the areas
impacted by the HMIWI rule. Although the application of the benefit per ton estimates to any
one area impacted by the regulation may be inappropriate due to differences in population
distributions, the use of average benefit per ton estimates to develop aggregate benefit estimates
may be reasonable, since variations in these distributions are likely to balance out in the aggregate.
Third, this analysis implicitly assumes that the PM emitted from HMIWI is similar in size and
composition to the PM emitted from the sources upon which the underlying PM benefit per ton
numbers are based. If the PM emitted from HMTWI facilities is significantly different from the
PM emitted from other types of sources, the benefits reported in Tables 7 may be biased.
Finally, a 1995 baseline is used to calculate the number of facilities existing in the industry, and to
estimate the number of new sources that will develop in a five year period. From this baseline,
control technology is selected to facilitate the calculation of costs and emission reductions. The
actual date that benefits will begin to accrue as a result of the emission reductions is uncertain,
therefore, this analysis presents the PM benefits with a 1995 baseline (expressed in 1993 dollars).
Full implementation of the rule is not anticipated until the year 2002 for existing sources and the
year 2000 for new sources, although some sources will comply prior to these dates. The year in
which annual emission reductions begin to accrue could alter the value placed on PM benefits due
to changes in population densities. If reductions in exposures to PM from HMIWI facilities
begins as late as 2002, then population growth from 1995 to 2002 would result in more exposures
and thus a higher benefit per ton value for PM. Thus the value presented this analysis may be an
underestimate.
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6.6 Benefit-Cost Comparison
Benefit-cost comparison is another tool used to evaluate the reallocation of society's resources to
address the pollution problem created by HMTWI. The additional costs of pollution control is
compared to the improvement in society's well-being from a cleaner and healthier environment.
Typically, a net benefit analysis uses total "social"cost in the comparison to monetized benefits.
First, since a welfare analysis was not conducted for these rules, the social costs of the regulations
are not estimated. Engineering estimates of the costs of emission controls for the different
regulatory options are used as a proxy for the social costs of the regulations. Comparing benefits
of alternative control options to the costs imposed by the options identifies the strategy that
results in the highest net benefit to society. Secondly, the quantifiable benefits of this analysis are
limited by the data available on various health and welfare categories for the affected pollutants.
EPA is not able to assign monetary values to most of these benefit categories (both health and
welfare endpoints, as well as entire pollutant categories). Therefore, the monetized benefits are
significantly underestimated, which in this case results in quantifiable costs exceeding the
quantifiable benefits. Thus, this comparison of benefits to costs can be utilized to evaluate the
option that minimizes the net costs to society. Tables 33 and 34 display the monetized benefits,
annualized costs, and net costs (monetized benefits minus annualized costs) of the HMTWI rule.
Option 1 under both scenarios minimizes net cost for existing sources. The benefits that are
quantifiable for new sources have the same level of emission reductions across each option and
therefore, the same monetary value. Thus, the net cost presented in Table 34 is the same across
each regulatory option. For Scenario B, net cost is $11.9 million while Scenario C produces a net
cost of $26.0 million.
Table 33
NET BENEFITS (COSTS) FOR EXISTING SOURCES
(thousands of 1993 dollars)
SCENARIO B
Monetized Benefits
Annualized Costs
Net Benefit (Cost)
SCENARIO C
Monetized Benefits
Annualized Costs
Net Benefit (Cost)
Option 1
$4,999.7
$55,205.0
($50,205.3)
$4,234.3
$82,183.9
($77,949.6)
Option 2
$5,813.8
$59,155.3
($53,341.5)
$5,510.0
$119,726.9
($114,216.9)
Option 3
$5,838.1
$64,201.4
($58,363.3)
$5,534.3
$124,773.0
($119,238.7)
Option 4
$5,844.2
$64,961.2
($59,117.0)
$5,558.6
$126,394.0
($120,835.4)
Option 5
$5,856.3
$65,213.8
($59,357.5)
$5,601.1
$129,289.8
($123,688.7)
Option 6
$5,856.3
$66,327.5
($60,471.2)
$5,607.2
$130,737.2
($125,130.0)
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Table 34
NET BENEFITS (COSTS) FOR NEW SOURCES
(thousands of 1993 dollars)
SCENARIO B
Monetized Benefits
Annualized Costs
Net Benefit (Cost)
SCENARIO C
Monetized Benefits
Annualized Costs
Net Benefit (Cost)
Option 1
$170.6
$12,131.6
($11,961.0)
$157.3
$26,223.9
($26,066.6)
Option 2
$170.6
$12,131.6
($11,9610)
$157.3
$26,223.9
($26,066.6)
Option 3
$170.6
$12,131.6
($11,961.0)
$157.3
$26,223 9
($26,066.6)
VD SMALL ENTITY IMPACTS AND UNFUNDED MANDATES
7.1 Small Entity Impacts
Section 605 of the Regulatory Flexibility Act (RFA) (5 U.S.C. 601 et seq.) requires Federal
agencies to give special consideration to the impacts of regulations on small entities, which are
small businesses, small organizations, and small governments. The major purpose of the RFA is
to keep paperwork and regulatory requirements from getting out of proportion to the scale of the
entities being regulated without compromising the objectives of, in this case, the Clean Air Act.
The President signed the Small Business Regulatory Enforcement Fairness Act (SBREFA) into
law on March 29,1996. The SBREFA amended the RFA to strengthen the RFA's analytical and
procedural requirements. The SBREFA also made other changes to agency regulatory practices
as they affect small entities. Finally, SBREFA established a new mechanism for expedited
congressional review of virtually all agency rules.12
The RFA as amended by SBREFA requires the Agency to make a determination as to whether a
regulation will have "a significant economic impact on a substantial number of small entities "
The Administrator has determined that the EG and NSPS for HMIWI will not have a significant
impact on a substantial number of small entities.
The U.S. Small Business Administration (SBA) definitions pertaining to business size are either
specified by number of employees or sales revenue. For analysis of the EG and NSPS regulations
being promulgated for FIMIWI, the EPA considers a small business or small organization to be
62
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one with gross annual revenue less than $5 million or one with less than 500 employees.13 The
EPA considers a small government to be one that serves a population less than 50,000.14 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.
In accordance with the RFA as amended by the SBREFA and current EPA Guidance, an analysis
of impacts of the EG and NSPS on small "entities" - including small businesses, small nonprofit
organizations, and small governmental jurisdictions - was performed. The economic impact
analysis indicates that neither the EG nor the NSPS will 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 HMIWI 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 for commercial HMIWI operators and
for small on-site HMIWI operators that are remote from an urban area. These facilities might not
have the opportunity to switch to an alternative medical waste treatment and disposal method -
commercial HMIWI operators because medical waste incineration is their line of business, and
small, remote HMIWI because they may not have access to commercial incineration services
For the EG, only one commercial HMIWI operator that is a small business is significantly
impacted with a cost to sales ratio of 11.1 percent. For reasons stated in Hospital/
Medical/Infectious Waste Incinerators: Background Information for Promulgated Standards and
Guidelines - Analysis of Economic Impacts for Existing Sources'5, it is quite possible that the
economic impacts to this firm may not be significant. Only 10 new commercial HMIWI are
projected for the period 1996 through 2000 for the NSPS. The size of entities installing new
commercial HMIWI is not known, but based on the size distribution of existing commercial
HMIWI, the fraction of the 10 new commercial HMIWI that will be operated by a small business
is likely to be a small. Significant economic impacts may occur for new commercial HMTWI that
are completely uncontrolled in the baseline, but the number of small entities affected is likely to be
quite small. The Hospital/Medical/Infectious Waste Incinerators: Background Information for
Promulgated Standards and Guidelines - Analysis of Economic Impacts for New Source1^
provides more discussion of small entity impacts for new sources.
The number of small remote HMIWI operators that are small businesses is unknown. A total of
114 small remote HMIWI exist in the current inventory of HMIWI. Based on the analysis
conducted in the economic impact analysis for existing sources, it was concluded that up to 57 of
the total 114 could be owned or operated by a small entity, and that these small entities could
have signficant economic impacts under regulatory options 3 through 6. However, these firms
will not be significantly impacted under regulatory options 1 and 2 (i.e., these firms have cost to
63
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sales ratios less than one percent). The number of new HMIWI that will be operated by a small
entity and will be located in a remote area is unknown. The projections of new HMIWI indicated
that 85 small incinerators are expected to be purchased in the period 1996 through 2000. It is
possible that some portion of these new small incinerators will be owned and operated by a small
entity. Significant impacts are possible for these entities (i.e., cost to sales ratios more that one
percent but less than three percent). However, the EPA believes that the number of new small
HMIWI operated by small entities in remote locations even without consideration of the NSPS
would be quite small. The EPA believes that the availability of alternative methods of waste
disposal will increase in the future also and mitigate any significant impacts resulting from the
regulation.
Thus, the EPA concludes that the EG and the NSPS for HMIWI will not have a significant impact
on a substantial number of small entities. For further information concerning the analyses
conducted to meet the RFA and SBREFA requirements for the EG and NSPS, please refer to the
economic impact analyses for existing sources and new sources previously referenced.
7.2 Unfunded Mandate Issues
Under section 202 of the Unfunded Mandates Reform Act of 1995 ("Unfunded Mandates Act"),
signed into law on March 22, 1995, the EPA must prepare a statement to accompany any rule
where the estimated costs to State, local, or tribal governments, or to the private sector, will be
$100 million or more in any 1 year. Section 203 requires the EPA to establish a plan for
informing and advising any small governments that may be significantly impacted by the rule.
Under section 205(a), the EPA must select the "least costly, most cost-effective or least
burdensome alternative that achieves the objectives of the rule" and is consistent with statutory
requirements. The EPA has complied with section 205 of the Unfunded Mandates Act, by
promulgating a rule that is the most cost-effective alternative for regulation of these sources that
meets the statutory requirements under the Clean Air Act. Since this rule is estimated to impose
costs to the private sector and government entities in excess of $100 million per year, it is
considered a significant regulatory action. Therefore, EPA must consider issues relevant to the
Unfunded Mandates Act.
The unfunded mandates statement under section 202 must include among other things an
assessment of the costs and benefits of the rule including the effect of the mandate on health,
safety, and the environment. Chapters V and VI of this report discuss the costs and benefits of
the EG and NSPS for HMTWI.
64
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REFERENCES
1. U.S. Environmental Protection Agency. Medical Waste Incinerators - Background
Information for Proposed Standards and Guidelines: Regulatory Impact Analysis for New and
Existing Sources. EPA-453/R-94-063a. July 1994.
2. U.S. Environmental Protection Agency. Addendum to Analysis of Economic Impacts for
Existing Sources. EPA-453/R-94-048a. July 1994.
3. U.S. Environmental Protection Agency. Addendum to Analysis of Economic Impacts for New
Sources. EPA-453/R-94-048a. July 1994.
4. U.S. Environmental Protection Agency. Medical Waste Incinerators - Background Information
for Proposed Standards and Guidelines: Analysis of Economic Impacts for Existing Sources.
EPA-453/R-94-048a. July 1994.
5. 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.
6. "Cost Information for Existing HMIWI's." Memorandum submitted by Brian Strong, Midwest
Research Institute, to Linda Chappell, U.S. Environmental Protection Agency. March 17, 1997.
7. "Cost Information for New HMIWI's." Memorandum submitted by Brian Strong, Midwest
Research Institute, to Linda Chappell, U.S. Environmental Protection Agency. February 21, 1997.
8. U.S. Environmental Protection Agency. Medical Waste Incinerators - Background Information
for Proposed Standards and Guidelines Regulatory Impact Analysis for New and Existing
Facilities. EPA-453/R-94-063a, July 1994.
9. Horst, Robert L. Et al. Benefit-Cost Analysis of Selected New Source Performance Standards
for Particulate Matter, Contract No. 68-02-3553. Final Report to the U.S. Environmental
Protection Agency, July 1985.
10. U.S. Environmental Protection Agency. The Benefits and Costs of the Clean Air Act, 1970 to
1990. Draft Report prepared for U.S. Congress, October 1996.
11. U.S. Environmental Protection Agency. Regulatory Impact Analysis for Proposed Particulate
Matter National Ambient Air Quality Standard. Draft Report prepared by Innovative Strategies
and Economic Groups, Office of Air Quality Planning and Standards (Research Triangle Park,
NC), December 1996.
12. U.S. Environmental Protection Agency SBREFA Task Force. " EPA Guidance for
Implementing the Small Business Regulatory Enforcement Fairness Act and Related Provisions of
65
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the Regulatory Flexibility Act." February 5, 1997.
13. Small Business Administration. "Small Business Size Standards." 13 Code of Federal
Register, Part 121. January 31, 1996 (Volume 61, Number 21).
14. Office of Regulatory Management and Evaluation. "EPA Guidelines for Implementing the
Regulatory Flexibility Act." April 1992.
15. U.S. Environmental Protection Agency. Medical Waste Incinerators - Background
Information for Proposed Standards and Guidelines: Analysis of Economic Impacts for Existing
Sources. EPA-453/R-97-007b. July 1997.
16. 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-97-008b. July 1997.
66
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TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
1. REPORT NO.
EPA-453/R-97-009b
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Hospital/Medical/Infectious Waste Incinerators: Background
Information for Promulgated Standards and Guidelines -
Regulatory Impact Analysis for New and Existing Facilities
5. REPORT DATE
July 1997
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
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
11. CONTRACT/GRANT NO.
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
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 Regulatory Impact Analysis attempted to compare the costs to the benefits expected from the
implementation of standards and guidelines. The cost and economic impact discussion refers to two
"Ananysis of Economic Impacts" reports (EPA-453/R-97-007b and EPA-453/R-97-008b). A qualitative
discussion of relevant benefit categories is presented. Due to lack of data regarding the benefits
associated with reducing specific pollutants, only a few benefit categories were quantified. Therefore, a
direct comparison of costs to benefits was not possible.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Reid/Group
Air Pollution
Pollution Control
Standards of Performance
Emission Guidelines
Medical Waste Incinerators
Hospital/Medical/Infectious Waste
Incinerators
Air Pollution Control
Solid Waste
Medical Waste
Incineration
Hospital Waste
Infectious Waste
18. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (Report)
Unclassified
21. NO. OF PAGES
20. SECURITY CLASS (Page)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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U.S. Environmental Protection Agency
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