?,EPA
             United States
             Environmental Protection
             Agency
             RISK Reduction tngmeenng Laootaiory     cr^c^D -
             Center for Environmental Research Information  June 1990
             Cincinnati, Ohio 45268
             Technology Transfer
Guides to Pollution
Prevention
Selected Hospital Waste
Streams
                                             Printed on Recycled Paper

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                                      EPA/625/7-90/009
                                      June 1990
    GUIDES TO POLLUTION PREVENTION:
    SELECTED HOSPITAL WASTE STREAMS
    RISK REDUCTION ENGINEERING LABORATORY
CENTER FOR ENVIRONMENTAL RESEARCH INFORMATION
      OFFICE OF RESEARCH AND DEVELOPMENT
     U.S. ENVIRONMENTAL PROTECTION AGENCY
             CINCINNATI, OHIO 45268

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                                 NOTICE
This guide has been subjected to U.S. Environmental Protection Agency's peer and
administrative review, and approved for publication. Approval does not signify that
the contents necessarily reflect the views and policies of the U.S. Environmental
Protection Agency, nor does mention of trade names or commercial products
constitute endorsement or recommendation for use. This document is intended as
advisory guidance only to hospitals in developing approaches for pollution preven-
tion. Compliance with environmental and occupational safety and health laws is the
responsibility of each  individual medical institution  and is not the focus of this
document
Worksheets are provided for conducting waste minimization assessments of hospital
facilities. Users are encouraged to duplicate portions of this publication as needed
to implement a waste minimization program.
                                      u

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                               FOREWORD
This guide provides an overview of hospital waste generating  processes and
presents options for minimizing waste generation through source reduction and
recycling. Reducing the generation of these materials at the source, or recycling
the wastes on or off site, will benefit  hospitals by reducing disposal costs and
lowering the liabilities associated with hazardous waste disposal.
The hazardous wastes generated by general medical and surgical hospitals are small
in volume relative to those of industrial facilities; however, the wastes are of a wide
variety. Some of the hazardous materials used by hospitals that become part of their
waste streams  include chemotherapy and antineoplastic chemicals; solvents;
formaldehyde; photographic chemicals; radionuclides; mercury; waste anesthetic
gases; and other toxic, corrosive and miscellaneous chemicals. Additional wastes
such as infectious waste, incinerator exhaust, laundry-related waste, utility wastes,
and trash are not addressed in this guide.
                                      m

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                      ACKNOWLEDGMENTS
This guide is based in part on waste minimization assessments conducted by
Ecological and Environment, Inc. for the California Department of Health Services
(DHS).  Contributors  to these assessments include: Benjamin Fries, and Eric
Workman of the Alternative Technology Section of DHS.  Jacobs Engineering
Group Inc. edited and developed this version of the waste minimization assessment
guide, under subcontract to Radian Corporation (USEPA Contract 68-02-4286).
Jacobs personnel contributing to this guide include: Carl Fromm, project manager;
Michael Callahan, Sally Lawrence, and Andrew Nelson, project group members.
Lisa M. Brown of the U.S. Environmental Protection Agency, Office of Research
and Development,  Risk Reduction Engineering Laboraatory, was the project
officer responsible for the preparation and review of this guide. Other contributors
and reviewers include: MarkEllefson, Health and Safety, University of Washington;
M.C. Hull, Chemical Safety Officer, Research and Occupational Safety, University
of California- Los Angeles; and Michael Todd, Assistant Manager of Engineering,
Huntington Memorial Hospital, Pasadena.  Information about waste anesthesia
gases, ethylene oxide, and mercury recyclers was  provided by ECRI, publisher of
Hospital Hazardous Materials Managementcns>-
                                    IV

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                                          CONTENTS
SECTION
PAGE
Notice	ii
Foreword	Hi
Acknowledgments	iv
1.  Introduction	1
2.  Hospital Waste Profile	5
3.  Waste Minimization Options	9
4.  Guidelines for Using the Waste Minimization Worksheets	18
Appendix A:
    Facility Assessments of Three Hospitals	33
Appendix B:
    Where to Get Help: Further Information on Waste Minimization	41

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                                            SECTION 1
                                        INTRODUCTION
    This guide was prepared to provide general medical
and surgical hospitals with guidelines and options to
minimize hazardous waste in selected waste streams.
However, the waste minimization assessment approach
described here can be used in efforts to minimize all wastes
generated at a facility. The guide is intended primarily for
use by hospitals,  particularly administrators and
environmental compliance personnel.  Others who may
find this  document  useful  are  regulatory  agency
representatives, hospital service organizations,  and
consulting firms.

    The worksheets and the waste minimization options
were developed through assessments of three San Francisco
Bay Area hospitals commissioned by the California
Department of Health Services (Calif. DHS 1988).  The
hospitals' operations and waste generationand management
practices were surveyed and their existing and potential
hazardous waste minimization options characterized for
the following selected waste streams:

    •  solvents

    •  chemotherapy wastes

    •  photographic chemicals

     •  formaldehyde wastes

     •  radioactive wastes

     •  mercury

     •  other toxics and corrosives

     The scope of the assessments did not include infectious
 waste, incinerator exhaust, laundry-related waste, utility
 wastes, and trash.  Information about waste anesthetic
 gases  has been added for this EPA guide.

     Waste minimization is a policy specifically mandated
 by the U.S. Congress in the 1984 Hazardous and Solid
 Wastes Amendments to the Resource Conservation and
 Recovery Act (RCRA). As the federal agency responsible
 forimplementingRCRA,theU.S.EnvironmentalProtection
 Agency (EPA) has an interest in ensuring that new methods
 and approaches are developed for minimizing hazardous
 waste and that such information is made available to the
institutionsconcemed. Thisguideisoneoftheapproaches
EPA is using to provide institution-specific information
about hazardous waste minimization. The options and
procedures outlined can also be used in efforts to mini-
mize other wastes generated.

    EPA has also developed a general manual for waste
minimization.  The Waste Minimization Opportunity
Assessment Manual (USEPA1988) tells how to conduct
a waste minimization assessment and develop options
for reducing hazardous waste generation. It explains the
management strategies needed to incorporate waste
minimization into institutional policies and structure,
how to establish a facility-wide waste minimization
program, conduct assessments, implement options, and
make the program an on-going one. The elements of a
waste minimization assessment are explained in die
Overview, below.

    In the following sections of this manual you will
find:
    • An overview of general medical and surgical
      hospitals and the hazardous chemicals they
      employ (Section Two);

    • Waste minimization options for hospitals
      (Section Three);

     • Waste Minimization Assessment Guidelines
      and Worksheets (Section Four)

     • An Appendix, containing:

            Case studies of waste generation and
            waste minimization practices of the
            three hospitals studied; and

            Where to get help: Sources of useful
            technical and regulatory information.

 Overview of Waste Minimization
 Assessment
     In the working definition used by EPA,  waste
 minimization consists of source reduction andrecycling.
 Of the two approaches, source reduction  is usually

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considered preferable to recycling from an environmental
perspective.

    A Waste Minimization Opportunity Assessment
(WMOA), sometimes called a waste minimization audit, is
a systematic procedure for identifying ways to reduce or
eliminate waste. The steps Involved in conducting a waste
minimization assessment are outlined in  Figure 1 and
presented in more detail in the next paragraphs. Briefly, the
assessment consists of a careful review of an institution's
operations and waste streams and the selection of specific
areas to assess. After a particular waste stream or area is
established as the WMOA focus, a number of options with
thepotential to minimize waste are developed andscreened.
The technical and economic feasibility of the selected
options are then evaluated.  Finally, the most promising
options are selected for implementation.

    To determine whether a WMOA would be useful in
your circumstances, you should first read this section
describing the aims and essentials of the WMOA process.
For more detailed information on conducting a WMOA,
consult the Waste Minimization Opportunity Assessment
Manual.

ASSESSMENT PROCESS
    The four phases of a waste minimization assessment,
described briefly below, are:

    • Planning and  organization

    • Assessment phase

    • Feasibility analysis phase

    • Implementation

Planning and Organization
  *  Essential elements of planning and organization for a
waste minimization program are: getting management
commitment for the program; setting waste minimization
goals; and organizing an assessment program  task force.
The importance of getting management support for waste
minimization cannot be overstated.

Assessment Phase
    The assessment phase involves  a number of steps:

    • Collect process and facility data

    • Prioritize and select assessment targets

    • Select assessment team

    • Review data and inspect site
     •  Generate options             '
                                   !
     •  Screen and select options for feasibility study

 Collect process and facility data. The waste streams at the
 facility should be identified and characterized. Information
 about-waste streams may be available oh hazardous waste
 manifests, lab pack packing  lists, National Pollutant
 Discharge Elimination System  (NPDES) reports, routine'
 sampling programs and other sources.
     Developing a basic understanding of the activities that
 generate waste at  a hospital facility is essential to the
 WMOA process.  Flow diagrams should be prepared to
 identify the quantity, types and rates of waste generating
 activities.  Also, preparing material balances for various
 processes  can be useful in tracking various process
 components and identifying losses that may have been
 unaccounted for previously. This may be especially useful
 when attempting to differentiate between  infectious and
 hazardous wastes.

 Prioritize and select assessment targets. Ideally, all waste
 streams in a facility should be evaluated for potential waste
•minimization opportunities.  However, with  limited
 resources, a hospital administrator may need to concentrate
 waste minimization efforts in a specific area.  Such
 considerations as quantity of waste, hazardous properties
 of the waste, regulations, safety of employees, economics,
 and other characteristics need to be evaluated in selecting
 a target stream.
 Select assessment team. The team should include people
 with direct responsibility for and knowledge of the waste
 streams or activities that generate  the wastes.  Use of
 consultants should be considered when no internal expertise
 is available.
 Review data andinspect site. The assessment team evaluates
 activitydatainadvanceof the site inspection. Theinspection
 should follow the target activities from the point where raw
 materials enter the facility to the points where wastes leave.
 The team should identify the suspected and known sources
 of waste. For hazardous waste this may include laboratories,
 pharmacies, pathology, radiology,  surgery, dialysis,
 embalming, nursing units, nuclear medicine, mercury from
 broken or obsolete equipment, "red bag" (infectious) wastes;
 maintenance operations; and storage areas for raw materials
 and wastes. The inspection may result in the formation of
 preliminary conclusions about waste  minimization
 opportunities. Full confirmation of these conclusions may
 require additional data collection or analysis.
 Generate options. The objective of thi
 a comprehensive set of waste minimization
is step is to generate
       options for

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Figure 1. The Waste Minimization Assessment Procedure
      The Recognized Need to Minimize Waste
         PLANNING AND ORGANIZATION

      Get management commitment
     1 Set overall assessment program goals
     ' Organize assessment program task force
           Assessment Organization &
             Commitment to Proceed
              ASSESSMENT PHASE

     • Collect process and facility data
     • Prioritize and select assessment targets
     > Select people for assessment teams
     > Review data and inspect site
     • Generate options
     • Screen and select options for further study
Select New Assessment
Targets and Reevaluate
  Previous Options
              Assessment Report of
                Selected Options
         FEASIBILITY ANALYSIS PHASE

      • Technical evaluation
      1 Economic evaluation
      > Select options for Implementation
               Final Report, Including
               Recommended Options
                 IMPLEMENTATION

      • Justify projects and obtain funding
      • Installation (equipment)
      • Implementation (procedure)
       Evaluate performance
     Repeat the Process
               Successfully Implemented
              Waste Minimization Projects

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further consideration. Since technical and economic con-
cerns will be considered in the later feasibility step, no
options should be ruled out at this stage. Information from
the site inspection, as well  as  medical associations,
govemmentagencies, technical and medical reports, equip-
ment vendors, consultants, and facility engineers and tech-
nicians may serve as sources of ideas for waste minimiza-
tion options.
    Both source reduction and recycling options should be
considered. Source reduction approaches include:

    • Good operating practices

    • Eliminating or reducing use of carcinogenic
      chemicals such as benzene and chloroform

    • Increased use of analytical instrumentation -
      this can decrease the use of chemicals

    • Improved inventory  control  utilizing
      computerized tracking and inventory systems,
      also use of central purchasing

    • Elimination of use of  oil based paints in
      maintenance

    Recycling includes:

    • Use and reuse of waste

    * Reclamation
Screen and select options for further study. This screening
process is intended to select the most promising options for
full technical and economic  feasibility study.  Through
either an informal review or a quantitative decision-mak-
ing process, options that appear marginal, impractical or
inferior are eliminated from consideration.
Feasibility Analysis            \
    An option must be shown  to be  technically and
economically feasible in order to merit seriousconsideradon
for adoption. A technical evaluation determines whether a
proposed option will work in a specific application.  Both
operational and equipment changes need to be assessed for
their overall effects on waste quantity.   Also, any new
products or raw materials need to be tested for efficacy.

    An economic evaluation is carried out using standard
measures of profitability, such as payback period, return on
investment, and net present value.  As in any project, the
cost  elements of a waste minimization project  can be
broken down into capital costs arid operating costs. Savings
and changes in revenue need also to be considered.

Implementation
    An option that passes both technical and economic
feasibility reviews should then lie implemented. It is then
up to the WMOA team, with  management support, to
continue the process of tracking wastes and identifying
future opportunities for waste minimization throughout a
facility by way of periodic reassessments. Both the ongoing
reassessments and an initial investigation of waste minimi-
zation opportunities can be conducted' using this guide.

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                                                SECTION 2
                                   HOSPITAL WASTE PROFILE
     Hospital hazardous waste is unique in several ways.
 There is a large variety of wastes but the volumes are small
 relative to industrial facilities.  Hospitals employ toxic
 chemicals and hazardousmaterials for numerous diagnostic
 and treatment purposes. The hazardous materials include:

     • Chemotherapy and antineoplastic chemicals

     • Formaldehyde

     • Photographic chemicals

     * Radionuclides

     • Solvents

     • Mercury

     • Waste anesthetic gases

     • Other toxic, corrosive, and miscellaneous
       chemicals

     Based on audits of three hospitals conducted for this
 study,  chemotherapy  wastes, including concentrated
 antineoplastic chemicals mixed with other inert materials,
 represented the highest volume of hazardous waste at each
 hospital.   This was followed by spent photographic
 chemicalsandformaldehyde solutions usedfor disinfecting
 equipment. Other significant and potentially significant
 sources of hazardous wastes noted  were solvents,
 radioactive wastes/mercury, waste anesthetic gases and
 other toxics and corrosives. The scope of the assessments
 did not include  infectious waste, incinerator exhaust,
 laundry-related waste, utility waste and trash.

 Waste Description
 CHEMOTHERAPY AND ANTINEOPLASTIC
 CHEMICALS
     Procurement of antineoplastic, or cytotoxic, agents
 thatare used to produce chemotherapy soluu'onsis generally
 conducted through a central clinic or pharmacy. Quantities
 kept on hand at the hospitals audited were generally
 sufficient to last less than two weeks. Chemicals are mixed
 or compounded within a hood, which recirculates air
 through a filter.  Chemotherapy wastes account for the
. largest volume of hazardous wastes produced by surveyed
hospitals.  Only a small percentage of these wastes
contain concentrated amounts of chemotherapy
compounds.  Much of the waste volume is associated
with lightly contaminated  items  such as personal
protective clothing and gauze pads. Sharp items such as
needles ("sharps") are also discarded, but may be
separated and handled as infectious waste.

    Waste materials are placed into plastic bags or
plastic containers that are either replaced daily, or when
they are full.  An average  of  2 to 8  cubic feet of
chemotherapy wastes per week were generated by the
hospitals surveyed. These wastes are either transported
off-site to a Class I landfill or incinerated as infectious
waste.  However, it should be noted that the latter may
not be an acceptable alternative under  some state
hazardous waste regulations. Landfilling of hazardous
wastes is discouraged or prohibited in many areas of the
country and should not generally be considered a viable
disposal option for hospital hazardous wastes.

FORMALDEHYDE
    Formaldehydeis used in pathology, autopsy, dialysis,
embalming, and nursing units. Occupational exposure to
airbone concentrations of formaldehyde is regulated by
OSHA. New regulations limit the permissible exposure
to 1.0 ppm as an 8-hour time weighted average (TWA),
with an action level of 0.5 ppm (ECRI, Jan, 1988).

    Formaldehyde also represents a significant source
of hazardous waste at many hospitals. For use in dialysis,
formaldehyde is generally purchased as a 37 percent
formaldehyde-in-water solution (formalin).  It  is
subsequently diluted with filtered, deionized water to
achieveafinalformaldehydeconcentrationof2-4 percent
The formalin is either pumped or poured into dialysis
machines to disinfect the membranes and the effluent is
discharged to the sewer.  In other  departments,
formaldehyde is generally used to preserve specimens
with small quantities of waste generated and discharged
to the sewer. Discharging a hazardous material to the
sewer may be illegal and is generally an undesirable
managementpractice, even if sanitation authorities allow
such disposal.

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PHOTOGRAPHIC CHEMICALS
    Full-service hospitals generally have a radiology
department. The photographic developing solutions used
in X-ray departments consist of two parts, a fixer and a
developer.   The fixer normally contains 5-10 percent
hydroquinone, 1-5 percent potassium hydroxide, and less
than 1 percentsilver. Thedevelopercontainsapproximately
45 percent glutaraldehyde. Acetic acid is a component of
stop baths and fixer solutions. These two chemical solutions
usually are obtained in 30- or 55-gallon drums.   The
contents are routed from these drums directly to the
developing machine.

    Silver-containing effluent from the fixer solution is
passed through a steel wool filter or otherwise treated to
recover thisprecious metal. The remaining aqueous waste,
containing  approximately 1.4 percent  glutaraldehyde,
0.3 percent hydroquinone,  and 0.2 percent potassium
hydroxide,  is typically  discharged to the sewer.  Some
hospitals utilize X-ray  services that also provide silver
recovery as part of the package.

RADIONUCLIDES
    Radioactive wastes are generated in nuclear medicine
and clinical testing laboratory departments. Atthe hospitals
surveyed, radioactive materials in nuclear medicine were
retained on site until they decayed to nonhazardous levels.
In clinical testing laboratories, solvents are also used for
radioactive tagging. Wastes at the audited hospitals are
generated at a rate of about 800 cubic centimeters per week.
The radioactive wastes are  transported off site for land
disposal.

SOLVENTS
    Solvent wastes are typically generated in  various
departments throughout a hospital.  These include
pathology, histology, engineering,  embalming,  and
laboratories. Volumes of solvent wastes generated at the
hospitals surveyed  were small. Specific solvents used in
medical settings include halogenated compounds such as
methylene chloride, chloroform, freons, trichloroethylene,
and 1,1,1-trichloromethane. Other solvents include non-
halogenated compounds such as xylene, acetone, ethanol,
isopropanol,  methanol, toluene, ethyl acetate,  and
acetonitrile. Xylene, methanol, and acetone were the most
frequently used solvents at the audited hospitals.

    Xylene and ethanol are used in histology and cytology
laboratories of hospital  anatomic pathology departments.
In tissue processing, ethanol dehydrates and xylene clears
tissue prior to  paraffin infiltration and embedding. Then
xylene is used to remove paraffin and ethanol to hydrate
sections before staining. Ethanol and xylene are again used
to dehydrate and clear sections before the cover slip is
applied to the  microscope slide'  preparation (L.
McGlothlin, histology supervisor at UC Davis, cited in
Roarkl989).                     !

    While  acetone and methanol,waste are usually
evaporated or discharged to the sewer, the xylene wastes
are normally handled as hazardous materials. Some of
these wastes are absorbed in specimens which are then
treated instead as infectious wastes. Solvent wastes are
typically stored in 30- or 55-gallon drums arid are either
recycled or transported off site for incineration.  In the
past, small quantities of solvent wastes were routinely
disposed of via lab packs to land fills.; This alternative is
becoming increasingly less  desirable due to higher
disposal costs, long-term liability,  and  limitations
introduced by new, more stringent regulations.*

MERCURY                     •
    The primary sources of mercury waste  at most
hospitals include broken or obsolete equipment. Mercury
wastes are decreasing in quantity due to the substitution
of  solid  state electronic sensing instruments
(thermometers, blood pressure gauges, etc.) for  those
containing mercury.              !

    Mercury from broken equipment is recovered and
reused (if uncontaminated).  Mercury losses due to
spillage may not be frequently recovered; no mercury
spill kits were present in any of the three surveyed
hospitals.                        :

ANESTHETIC GASES          j
    Nitrous oxide and the halogenated agents halothane
(Fluothane), enflurane (Ethrane), isoflurane (Forane),
and other substances are used as inhalation anesthetics.
Exposure of health care personnel to these substances
may result in acute  toxic. effects and, possibly,
reproductive disorders and carcinogenesis (ECRI Feb.
1988).                          |

    Nitrous oxide is  supplied as a gas in cartridges or
cylinders that are attached directly  to the anesthetic
administering equipment. Used containers are returned
to the supplier. The halogenated anesthetic agents are
supplied in liquid form, in glass bottles. Once empty, the
bottles are handled as hazardous waste.

Purchase                       ;
    Waste anesthetic gases are generally removed from
the operating room, or the site of application, in one of
two ways. At some of the larger hospitals, a scavenging
unit is attached to the anesthesia unit to remove the waste
gases.  The scavenging unit may have a charcoal filter
which would adsorb halogenated anesthetic gases but
not nitrous oxide. Spent charcoal filters are sent off site

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as hazardous waste. If there is no scavenging unit, or if the
scavenging unit does not have a filter, then vacuum lines
are used to collect waste anesthetic gases and vent them to
the outside.

TOXICS, CORROSIVES, AND MISCELLANEOUS
CHEMICALS
    Poisons, oxidizers, and caustics are used throughout
most hospitals, generally in small quantities. Waste oils
and solvents from maintenance may also be considered
hazardous wastes as may some boiler water conditioning
chemicals.  Although many of these types of wastes are
considered hazardous materials, only ethylene oxide was
used at the surveyed hospitals in large quantities. All of the
audited hospitals currently discharge this gas to the
atmosphere but may soon  be required to treat  it.  Many
facilities in California are already required to "scrub" these
emissions.

    Listed below are some major toxic, corrosive, and
miscellaneous chemical wastes and their sources of origin:

    Ethylene Oxide        Used in sterilizers. Classified
                         by EPA as a probable human
                         carcinogen; also a smog
                         forming agent, and
                         explosive/flammability
                         hazard.
    Disinfecting Cleaning
    Solutions             Phenol based, used  for
                         scrubbing floors and other
                         applications.
    Utility Wastes         Boiler feed water treatment
                         residuals (resin regeneration
                         brine, spent resin)
                         Boiler blowdown
                         Boiler cleaning (layup) wastes
                         Cooling tower blowdown
                         Cooling tower sludges/
                         sediments
    Maintenance Wastes  Waste lube oils, vacuum pump
                         oils
                         Cleaning solvents
                         Paint stripping  wastes
                         Leftover paints and painting
                         accessories
                         Spent fluorescent lamps

Ethylene Oxide
    Ethylene oxide (EtO), used to sterilize medical devices,
is used in central supply areas, respiratory therapy, and at
times, in operating rooms. This colorless and odorless gas
can cause a number of acute toxic reactions and  is a
probable human carcinogen (ECRI Jan. 1989).
    Ethyleneoxide ispurchased in cartridgesorcylinders
that can be attached directly to specially designed
sterilizers. Equipment that has been sterilized in a EtO
sterilizer is transferred to an EtO aeration chamber. Both
EtO sterilizers and aerators are connected to ventilation
systems which duct the exhaust to the outside. Used
ethylene oxide cylinders are returned to the supplier.
Some hospitals are going to bulk storage of ethylene
oxide, using large tanks.

Waste Management Issues
    A large variety of hazardous materials is used in
hospitals; however, overall waste quantities generated
are relatively low.  Tracking of hazardous wastes in
hospitals is often complicated by ,a lack of available
records on waste generation. This results from hazardous
wastes being  mixed with infectious wastes and from
disposal of potentially hazardous wastes into the sewer.

    The Medical Waste Tracking Actis ademonstration
program (participants  are New York, New  Jersey,
Connecticut, Rhode Island, Louisiana, and the District
of Columbia) that will require generators of more than 50
pounds of waste monthly to use a four-copy manifest
tracking system. Included in "medical waste", for the
purposes of the Act,  will be cultures and stocks of
infectiousagentsandassociatedbiologicals; pathological
waste; human blood and blood products; used sharps;
contaminated animal carcasses; surgery or autopsy waste;
laboratory wastes; dialysis wastes; discarded medical
equipment; and isolation wastes.

    MWTA is expected to lead eventually to a broader
tracking program that will affect all states. It may also
provide impetus to hospitals to incinerate many types of
waste on site. With this possibility in view, EPA expects
to establish medical waste incineration regulations under
the Clean Air Act (Roy 1989).

INFECTIOUS WASTES
    Although recently awareness has increased regarding
the need for proper disposal of medical waste, there has
been a misconception at some hospitals regarding the
need to apply proper hazardous waste disposal practices
for wastes containing both infectious and hazardous
components. By current law, any waste mixture of non-
hazardous and hazardous or infectious and hazardous
wastes must be handled as a hazardous waste. Many
items that are routinely handled as infectious waste
(gauze pads,  gowns, etc. that are contaminated with
hazardous waste) should be handled as hazardous waste.
The lack of manifesting requirements for infectious
wastes makes accurate determinations  of hazardous

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components in these waste streams even more difficult.
The generation and disposal of infectious wastes were
excluded from the scope of the assessments.

SEWER USE AND PRETREATMENT
    The  diluted nature and/or low volume of certain
hazardous liquid wastes has resulted in some  hospitals
obtaining permission from the local sanitary district to
discharge these solutions to the sewer.  For  instance,
formaldehyde solutions from dialysis and pathology
departmerits are routinely discharged to the sewer. Wastes
from these departments contain between 4 and 10 percent
formaldehyde, respectively.  Permission by the sanitary
districts to discharge these wastes to the sewer is normally
granted only for non-bioaccumulative wastes.

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                                             SECTION 3
                            WASTE MINIMIZATION OPTIONS
Description of Techniques
    This  section  discusses  recommended  waste
minimization  methods for general medical and surgical
hospitals.  These methods were identified through waste
minimization assessments of  hospitals  and through
reference to technical literature. Hospitals' primary waste
streams are listed in Table 1  along with recommended
control methods. Infectious wastes, incinerator exhaust,
laundry-related waste, utility  wastes  and  trash are not
addressed. The control methods can be classified generally
as source reduction methods which can be achieved through
material substitution, process or equipment modification,
or better operating practices; or as recycling. Treatment of
hazardous waste is not the focus of this guide.

    The waste minimization  options are  presented for
specific waste streams, following.a discussion of better
operating practices that can be  used in overall hospital
waste management

Better Operating Practices
    Better operating practices are procedures and
institutional policies that result  in a reduction of waste.
Improved management oversight, tracking, and inventory
control can  effectively reduce  waste generation.
Computerized data base tracking systems provide a very
effective and efficient method of tracking  and inventory
control.

    Key overall operating strategies include:

    • Keep individual waste streams segregated.

            Keep hazardous  waste segregated from
            nonhazardous waste.  All waste
            contaminated with a hazardous substance
            becomes hazardous.

            Keep hazardous  chemical wastes
            segregated from infectious wastes.

            Keep recyclable waste segregated from
            non-recyclable waste.

            Minimize dilution  of hazardous waste.
• Assure that the identity of all chemical and
  wastes is clearly marked on all containers.

Improved managementandcontrolpractices include:

• Centralizepurchasinganddispensingofdrugs
  and other hazardous chemicals.

• Monitor drug and chemical flows within the .
  facility from receipt as raw  materials  to
  disposal as hazardous wastes.  This may be
  partially or fully automated by the use of
  computer systems and computer-readable
  barcoded labels for incoming chemicals,
  similar to those used in supermarkets.

• Apportion  waste management costs to the
  departments that generate the wastes.

• Improve inventory control by:

  - Requiring users of chemicals with limited
    shelf life to use up old stock before ordering
    or using new stock.

  - Ordering hazardous chemicals only when
    needed and in minimal quantities to avoid
    outdated inventory.

• Provide employee training  in hazardous
  materials  management  and  waste
  minimization.   The  major generating
  departments should have a training program
  for all staff who may generate or handle
  hazardousmaterials.Trainingshouldinclude:

        Chemical hazards.

        Spill prevention.

        Preventive maintenance.

        Emergency  preparedness  and
    response, including spill clean-up.

• Implement  an institution-wide waste
  reduction program.

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Table 1.  Waste Minimization  Methods for General Medical and Surgical Hospitals
    Waste Category

    Chemotherapy and
    Antineoplastics
    Formaldehyde
    Photographic Chemicals
    Radionuclides
    Solvents
    Mercury
    Waste Anesthetic Gases
    Toxics, Corrosives and
    Miscellaneous Chemicals
Waste Minimization Method                    :

Reduce volumes used.
Optimize drug container sizes in purchasing.
Return outdated drugs to manufacturer.
Centralize chemotherapy compounding location.
Minimize waste from compounding hood cleaning.
Provide spill cleanup kits.
Segregate wastes. •
Minimize strength of formaldehyde solutions.           .
Minimize wastes from cleaning of dialysis machines land RO units.
Use reverse osmosis water treatment to reduce dialysis cleaning
demands.
Capture waste formaldehyde.                     '
Investigate reuse in pathology, autopsy laboratories.
Return off-spec developer to manufacturer.
Cover developer and fixer tanks to reduce evaporation, oxidation.
Recover silver efficiently.
Recycle waste film and paper.
Use squeegees to reduce bath losses.               '
Use countercurrent washing.
Use less hazardous isotopes whenever possible.
Segregate and properly label radioactive wastes, and store short-lived
radioactive wastes in isolation on site until decay permits disposal in
trash.
Substitute less hazardous cleaning agents, methods for solvents
cleaners.
Reduce analyte volume requirements.
Use pre-mixed kits for tests involving solvent fixation
Use calibrated solvent dispensers for routine tests.
Segregate solvent wastes.
Recover/reuse solvents through distillation.
Substitute electronic sensing devices for mercury-containing devices.
Provide mercury spill cleanup kits and train personnel.
Recycle uncontaminated mercury wastes using proper safety controls.
Employ low leakage work practices.               :
Purchase low-leakage equipment.             .     \
Maintain equipment properly to avoid leaks.

Inspection and proper equipment maintenance for ethylene oxide
sterilizers.
Substitute less toxic compounds, cleaning agents.
Reduce volumes used in experiments.              :
Return containers for reuse, use recyclable drams.
Neutralize acid waste with basic waste.
Use mechanical handling aids for dnims to reduce spills.
Use automated systems for laundry chemicals.
Use physical instead of chemical cleaning methods.
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    • Establish  an internal  recycling  program.
      Package stills are available that are capable of
      recycling histology and other solvents to reagent
      grade purity.

    Other approaches that will improve hazardous waste
management in hospitals include:

    • Requiring  that all  new materials  (cleaning
      compounds, process chemicals, etc.) that may
      result in hazardous waste generation be tested
      in small quantities before being purchased-in
      bulk to assure that large quantities  of unused
      materials that do not perform as expected do
      not need disposal.

    • Encouraging drug and chemical suppliers to
      become responsible partners  in a  waste
      minimization  program by ordering  from
      suppliers who will provide quick delivery of
      small orders, will accept return of unopened
      stock, and are willing to offer off-site waste
      management outlets or cooperatives  for
      hazardous wastes.

    These practices apply to all waste streams. In addition,
specific better operating practices that apply to certain
waste streams are identified in the appropriate sections that
follow.

CHEMOTHERAPY AND ANTINEOPLASTIC
WASTES
    The toxicity of  antineoplastic agents is inherent,
because of their  efficacy against cancer. The  hazards
associated with the handling of a given antineoplastic drug
are usually of secondary concern compared with its
phamnaceuticaleffectiveness. Because individual responses
to drugs in this  category vary widely, many different
antineoplastics have been marketed,

    The greatest volume of antineoplastic  wastes is
generated from drug dispensing devices, contaminated
protective clothing, and associated paraphernalia.  At
surveyed hospitals, there is significant potential for reducing
waste volumes through administrative controls. These
include waste segregation,  minimizing clean-up waste
volume, and employee training. Other methods include:

    • Segregate chemotherapy  wastes from other
      wastes.   Adherence to  this procedure is
      facilitated through training and by providing
      separate containers with distinctive labels in
      chemotherapy drug handling areas.

    • Disposable garments may be disposed of with
      nonhazardous refuse if no chemotherapy agents
      were spilled during handling.   However,
      glovesshouldbe assumed to be contaminated.

    • Minimizethecleaningfrequencyandvolume
      of gauze material used for the compounding
      hood.

    OSHA has a publication 8-1.1 (January 29,1986)
regarding health and safety when handling antineoplastic
drugs.  In it, OSHA recommends that hoods be wiped
down  daily with  70  percent alcohol and  be
decontaminated weekly with a high-pH (basic) solution.
The actual cleaning frequency required depends on drug
handling volume and the amount of spillage  which
occurs in the hood. Proper handling practices should be
emphasized to minimize hood cleaning requirements.

    • Purchase drug volumes according to need.

    Over-purchasing results in the generation of out-of-
date materials that must be disposed of. Reducing the
generation of residual material may be accomplished by
computing  daily compounding requirements of each
drug and ordering appropriately sized containers. In
addition, obtain pre-scored ampule containers. This will
minimize spillageassociated with breaking open unscored
ampule necks.

    • Employ proper spill containment and clean-
      up procedures.

    Spillcontainmentandclean-upkitsshouldbereadily
available in the compounding area(s). These kits, usually
available from the drug suppliers, should contain both
small and large absorbent devices.

     • Proper training.

    Effective administrative and engineering control
require ongoing employee training and supervision.
Surveyed hospitals reported that chemotherapy drug
handling training is primarily limited to health and
safety. However, employees also need to be trained in
methods to minimize generation of chemotherapy wastes.

     • Return outdated drugs to the manufacturer.

     • Centralize the  location of chemotherapy
      compounding areas.

FORMALDEHYDE WASTES
     For use  in dialysis, formaldehyde  is generally
purchased as a 37% formaldehyde-in-water solution
(formalin).  It is subsequently diluted with filtered,
deionized  water to  achieve a final  formaldehyde
concentration of 3-4%. The formalin is eitherpumpedor
poured into  dialysis  machines,  and the effluent is
                                                      11

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discharged to the sewer.  Ways to minimize this waste
include installation of reverse osmosis water  supply
equipment, using minimium effective cleaning procedures,
recycling and reusing waste solutions, and proper waste
management.

Install Reverse Osmosis (RO) Water
Supply Equipment.
    Since the cleaning of dialysis equipment is the major
reason for formaldehyde waste, any measures that help to
reduce the need  for cleaning will help reduce waste
generation. Hospitals reported that use of RO units allows
a reduction in the cleaning  frequency requirements of,
dialysis machines. While RO water treatment units also
are typically flushed with formalin, they can be cleaned
instead with hydrogen peroxide, which is less persistent in
the environment.

Determine Minimum Effective Cleaning Procedures.
    At the surveyed hospitals, a significant variation was
observed in the cleaning frequency of the hemodialysis
machines and of the reverse osmosis (RO) water supply
equipment.  Since waste generation  rates are directly
related to  cleaning frequency and formalin strength, the
potential exists for minimizing these wastes by optimizing
both variables.  There is an apparent need to develop
consistent standards for formalin solutions, based upon
microbial culture studies. These studies should compare
microbial  residues with variations in formalin strength,
cleaning frequency, and water supply systems.

Reuse/Recycle Waste Solutions.
    The diluted  formalin  waste stream contains
approximately4percentformaldehyde, 1 percent me thanol,
and 95 percent water.  Surplus or absolute dialysis units
could possibly be used to concentrate the formaldehyde for
reuse.  Dialysis has been used to recover organic material
in rayon manufacturing (Sawyer and McCarty 1967). Off-
spec dialysis membranes could possibly be used to extract
and concentrate the formaldehyde wastes  for eventual
reuse, recycle, or incineration.

Recovery  of waste formalin through distillation is also
theoretically feasible.   However, none of the  surveyed
hospitals  is recycling formaldehyde wastes through
distillation. The tendency for formaldehyde to polymerize
and form azeotropes with water and methanol may affect
recovery efficiencies.  Moreover, a high purity extract is
required for reuse in dialysis to ensure that there are no
pathogenic contaminants in theaqueous fraction. For these
reasons, distillation would need to be monitored carefully.
In autopsy and pathology laboratories, depending upon the
type of specimen, direct reuse of formaldehyde solutions
may be feasible. These solutions retain their desired
properties for periods far longer than the usual holding
times for specimens. In addition, thedesired preservative
properties may be effective at lower concentrations than
the 10 percent formaldehyde solutions typically used.
Reuse of hospital formaldehyde wastes through an open-
market waste exchange does not appear feasible. This is
because of the potential presence of pathogens in  the
waste stream.                    ;
Proper Waste Management.
    All waste managementmethods should stresscontro'l
of airborne emissions since formaldehyde is a suspected
carcinogen of the upper respiratory system  (ACGIH
1987). The OSHA permissible exposure level (PEL) for
formaldehyde was recently reduced from 10 ppm to 1
ppm.

PHOTOGRAPHIC CHEMICAL WASTE
    The major  waste stream associated with image
processing  at  hospital  radiology departments  is
wastewater that contains photographic chemicals and
silver removed from film.  Other wastes include spoiled
chemicals and scrap film.  Ways to reduce these wastes
include:                     •    ,

Store Materials Properly.         ;
    Many photoprocessing chemicals are sensitive to
temperature  and light.  Photosensitive film and paper
storage areas should be designed for economical and
efficient use. Chemical containers list the recommended
storage conditions. Meetingthe recommended conditions
will increase their shelf life.       ;

Recycle Spoiled Photographic Film and Paper.
    It is a current practice in the photoprocessing and
printing industry to send used and/or spoiled film to
professional  recyclers for recovery of silver (USEPA
1986). However, this option might not be practical to
small scale operations or available to facilities located
far away from recyclers.
                                |
Test Expired Material for Usefulness.
    Materials having expired shelf-life should  not
automatically be thrown out.  Instead, this material
should be tested for effectiveness. The materials may be
usable, rather than becoming a waste.1 A recycling outlet
should be found for left over raw material that is no
longer wanted.

Extend Processing Bath Life.     ;
    Wastes from photographic processing can be reduced
by extending the life of fixing baths. Techniques include
                                                      12

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(1) adding ammonium thiosulfate, which doubles the
allowable concentration of silver buildup in the bath; (2)
using an acid stop bath prior to the fixing bath; and (3)
adding acetic acid to the fixing bath as needed to keep the
pHlow.

Accurately adding and monitoring chemical replenishment
of process baths will cut down chemical wastage. Stored
process bath chemicals should be protected from oxidation
byreducing exposure to air. Somesmallerphoto developers
store chemicals in closed plastic containers. Glass marbles
are added to bring the liquid level to the brim each time
liquid is used. In this way, the amount of chemical subject
to degradation by exposure to air is  reduced, thereby
extending the chemical's useful life and the life of the bath.
Use Squeegees.
    Squeegees can be used in  non-automated processing
systems to wipe excess liquid from the film and paper. This
can reduce chemical carryover from one process bath to the
nextby 50percent(Campbelland Glenn 1982). Minimizing
chemical contamination  of process bath increases
recyclability, enhances the lifetime of the process baths,
and reduces the amount of replenisher chemicals required.
Most firms, however, use automated  processors. Also,
using squeegees may damage the film image if it has not
fully hardened, so a squeegee should be used after the film
image has hardened.

Use Countercurrent Washing.
    In photographic processors, countercurrent washing
can replace the commonly used parallel tank system. This
can reduce the amount of wastewater generated.  In a
parallel system, fresh water enters each wash tank and
effluent leaves each wash tank. In countercurrent rinsing,
the water from previous rinsings is used in the initial film-
washing stage. Fresh water enters the process only at the
final stage, at which point much of the contamination has
already been rinsed off the film. However.acountercurrent
system requires more space and equipment

Recover Silver and Recycle Spent Chemicals.
    Basically, photoprocessing chemicals consist of
developer, fixer, and rinse water. Keeping the individual
process baths as uncontaminated as possible isaprerequisite
to the successful recycling of these chemicals. Stiver is a
component in most photographic films and paper and is
present in the wastewaters produced.  Various economical
methods of recovering silver are available (e.g. metallic
replacement, chemical precipitation, electrolytic recovery),
and a number of companies market equipment that will suit
the needs of even the smallest generator.

The most common method of silver recovery employed by
hospitals is metallic replacement. The spent fixing bath is
pumpedintoacartridgecontaining steel wool. An oxidation-
reduction reaction occurs and the iron in the wool replaces
the silver in solution. The silver settles to the bottom of the
cartridge as a sludge.
Another, more  efficient,  method of silver recovery is
electrolytic deposition. In an electrolytic recovery unit, a
low voltage direct current is created between a carbon
anode and stainless steel cathode.  Metallic silver plates
onto the cathode.  Once the silver is removed, the fixing
bath may be able to be reused  in  the photographic
development process by mixing the desilvered solution
with fresh solution. Recovered silver is worth about 80%
of its commodity price.
Some of the companies that buy used film or cartridges
containingrecovered silver can be located under "Goldand
Silver  Refiners and Dealers" in a business telephone
directory.These firms maypickupdirectlyormaypurchase
through dealers. Torecycleusedfilm, it may be worthwhile
to sort the film into "largely black" versus "largely clear"
segments, since the rate of payment for mostly black film
may be twice that for mostly clear.
Technologies for reuse of developer and fixer are available
andinclude ozone oxidation, electrolysis, and ion exchange.
RADIONUCLIDES
    Radioactive wastes cannot be treated or neutralized.
Therefore,sourcereductionand substitution are theprimary
waste minimization strategies  for  such  materials.
Knowledge of the physical and biological properties of the
various nuclides  is required to enable assessment of
environmental hazards associated with waste products.

    Table 2 lists properties of common nuclides used in
hospital research and treatment.  The type  of radiation
emitted, energy, physical and effective half lives, and
decay products are the factors which must be considered
when choosing among various nuclides. The objective is
to choose a nuclide which has a short half-life, low energy,
a stable, non-toxic decay product, and emits minimal
amounts of extraneous radiation.   Extraneous radiation
refers to the production of a type of radiation which is not
required in the test or procedure. For example, if a beta
emitter is required for a certain test, a nuclide which
produces minimal gamma radiation should  be  chosen.
This is because gamma radiation is hazardous to the patient
and is more difficult to contain during handling.

     Radium-226 is probably the most  hazardous
radionuclide used in hospitals. Its physical and effective
half lives are extremely long  and its decay products are
unstable. Radium-226 needles used in cancer treatment are
being phased out at many hospitals in favor of indium-192
or cesium-137 needles.
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Table 2.  Properties of Radionuclides Used In Hospitals
Nuclide1
Carbon-14
Phosphorus
Chromium-51
GalIium-67
Technetium-99
Type of
Radiation2
Energies3
{MeV)
beta', no gamma 0.156 max
beta', no gamma 1.7 max
gamma
gamma
gamma
0.32
0.093 (40%)
0.14
Physical
Half-Life4
5,730 yrs.
14 days
28 days
78hrs.
6hrs.
Effective
Half-Life5
12 days
14 days
27 days

Shrs.
R/hr per Ci
at 1 meter6
N.A.8
N.A.
0.018

0.059
lndium-111
lodine-125
Tritium
Iodine-131

Cesium-137


Barium-1 37m
lridium-192

Radium-226

Cobalt-609
gamma
gamma
beta', no gamma
beta-
gamma
beta'

gamma
gamma
beta-
gamma
alpha
gamma
beta-
0.173
0.035
0.0186 max
0.606 max
0.365
1.1 76 max (7%)
0.51 4 max
0.662
0.662
0.666 max
0.317, 0.468
4.78
0.186
0.31 8 max
2.8 days
60 days
12.3 yrs.
8 days

30 years


2.5 min
74 days
.
1,600 yrs.

5.27 yrs.

42 days
12 days
8 days

70 days





44 yrs.

10 days

0.07
N.A.
0.21

0.32





0.825

1.33
Daughters7
Nitrogen-14  (stable)
Sulfur-32 (stable)
Vanadium-51 (stable)
Zinc-67 (stable)   "
Technetium-99
 (radioactive)
Ruthenium-9(stable)
Cadmium-111 (stable)
Tellurium-125 (stable)
Helium-3  (stable)
Xenon-131. (stable)

Barium-137  (stable)
                                                                                         Barium-137 (stable)
                                                                                         Platinum-192 (stable)

                                                                                         Radon-22 (radioactive)
                                                                                         (See Note 7)
                                                                                         Nickel-60 (stable)
                 gamma
 1 Nuclide:  Most common-radioactive nuclides (radionuclides) present at hospitals.  Tritium, iodine-125, and;carbon-14 are most
 commonly used atresearch hospitals. The "m" in barium-137m and technetium-99m represents ametastsble state of that nuclide (see
 note 7).                      .  .'                                                              .''...'",'
 2 Type of Radiation: beta-: negative beta particle called beta minus; alpha: alpha particle; gamma: gamma ray. "no gamma" means
 thatnuclide emits no gammarays, which is unusual; most alpha and beta decays are accompanied by gamrnaradiation. Only the major
 radiations are listed here.                                                                        \   .'       . ..  , •..
 3 Energies: Most significant energies are given here (MeV = million electron-volts). For beta-decay, a continuous spectrum of beta
 energies are released up to some maximum value which is specific to a given radionuclide. The average beta- energy is  a better
 indication of the hazard - average beta energy is generally 30-40% of the maximum energy.                ;
 4 Physical Half-Life: The time required for half of the original number of atoms to decay: abbrev. T_ or Tp.
 3 Effective Half-Life: A combination of the physical T_ (Tp) and biological T_ (Tb), where 1  = JL  +-1
                                                                                Teff  Tp Tb             '  .   .
  1* is the time required for half of the atoms to be removed from the body (through excretion)
 * R/hr per Ci at one meter Specific activity, given for gamma-emitting radionuclides - indicates the Roentgen/hr measurement
 expected from a one-Curie point source at a distance of one meter.                                         '
 7 Daughters: When an atom decays by beta or alpha emission it becomes an atom of another element; the original atom is called the
 parent and the product is called the daughter. Most of the radionuclides used in hospitals have daughters that are stable (i.e.,  they are
 notradioactive). However, some have daughters that are also radioactive, which in turn can produce subsequent rudioactive daughters.
 For example, as radium-226 decays, it produces seven "generations" of distinct, radioactive decay products, and only in the eighth
 generation is a stable decay product, lead-206, produced. These seven daughters all emit alphas and betas and have a range of half-
 lives.                                                                                         ,              .
 * N.A.: not applicable
 ' Used in teletherapy units only - not routine waste.
 Note: Blanks indicate no_ information available.                                                     !
 Source: Calif. .DBS. 1988.
                                                          14

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    E. Party and E.L. Gershey of The  Rockefeller
University, who reviewed the field of low-levelradioactive
waste (LLRW) for the Annual Review of Public Health,
recommend several ways that the amounts of LLRW that
are generated by biomedical institutions and that require
disposal, can be reduced substantially (1989). The primary
method of waste reduction requires allocation of space
(100 to 200  square meters) on site  where short-lived
radioactive materials may be isolated and stored until
decay to acceptably low levels as verified by survey meter.
They then can be disposed of as non-radioactive liquids
and trash.

    Low level radioactive wastes need to be segregated
and properly labeled as to isotope, form, volume, laboratory
origin,  activity^ and  chemical composition.  Central
processing is recommended.

SOLVENTS
    The primary sources of hospital solvent wastes are the
laboratory,  pathology,  histology,  and  maintenance
(engineering) departments.   Waste quantities vary
significantly depending on die size and specific functions
of the hospital. Solvents are used for degreasing and parts
cleaning in engineering, for fixation and preservation of
specimens in histology and pathology, and for extractions
in laboratories.

  .  For the purposes of waste management, solvents can
be classified  as  either halogenated or non-halogenated.
Halogenated solvents are generally more  toxic and
persistent.  Specific  halogenated compounds used in
hospitals include methylene chloride,  chloroform,
tetrachloroethylene, chlorobenzene,  trichloroethylene,
1,1,1-trichloromethane,  and Freon. Non-halogenated
compounds include xylene, acetone,  toluene, methanol,
ethyl ether, methyl ethyl ketone, and pyridine.

    Routine  procedures for managing solvent waste at
many hospitals currently include discharge to the sewer
and lab-pack disposal in landfills. While these procedures
have been considered acceptable in the past, they are no
longer advisable options  and in some situations may be
illegal. Land disposal is becoming increasingly costly and
the number of substances banned from landfilling continues
to grow. Although disposal of some solvent wastes to the
sewer in small concentrations may be acceptable by some
municipal standards, state and federal laws may prohibit
such discharges. Questions of legality aside, both land
disposal and sewer discharge are environmentally unsound
alternatives.

Material Substitution
     Source reduction options  for solvents consist of
substituting non-halogenated compounds for halogenated
compounds, substituting simple alcohols and ketones for
petroleum hydrocarbons (i.e., toluene or xylene), and using
aqueous reagents (such as biodegradable Alconox) wherever
possible. In addition, sonic or steam cleaning can often be
substituted for alcohol-based disinfectants.

    Histology sol vents must dehydrate tissues, so aqueous-
based solvents are not suitable in histology. In the past,
benzene was the solvent of choice.  However,  due to
concerns about the hazards of benzene, it has largely been
replacedby xylene. There areanumberofxylenesubstitutes
currently on the market, one or more of which may be a
viable substitute.

Improved Laboratory Techniques
    Solvent use in laboratories has decreased in recent
years due to technological advances. For example,
monoclonal   antibodies,    radioisotope-labeled
immunoassays, and ultrasensitive analytical devices have
reduced or eliminated the need for solvent extractions and
fixation.

    Calibrated  solvent dispensers or unitized test kits
should be used. The sizes of cultures or specimens should
be minimized in the pathology, histology, and laboratory
departments.

Recycle Solvents
    An important first step in determining the feasibility of
on-site distillation and recovery of waste solvents consists
of separating waste streams according to specific chemical
components. This may allow the use of simple batch
distillation equipment which is less expensive than fractional
distillation equipment. Individual solvent recycling units
suitable for hospital use have been developed.  One
manufacturer has a fractional distillation system equipped
with a microprocessor to automatically distill, fractionate,
and purify a sol vent It can be used, for example, to separate
xylene from ethanol in histology wastes (Roark 1989).
     In the event that on-site distillation is not feasible, off-
 site distillation or waste exchange should be considered.
 Solventwastes that havebeenkeptsegregated (halogenated
 vs.. non-halogenated) may be more easily recycled off site.
 Solvent wastes with sufficiently low chlorine content can
 be used as a fuel supplement in cement kilns and some
 industrial boilers.

 MERCURY
 Electronic Sensing Devices
     Perhaps the best, if not the least costly, approach to
 mercury waste minimization is  to eliminate mercury-
 containing instruments entirely.  Substituting solid state
                                                       15

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electronic sensing devices for mercury-based thermome-
ters and blood pressure instruments is occurring at many
hospitals. This source elimination technique appears to be
the primary reduction alternative for mercury wastes. The
higher initial costs of electronic  devices are typically
justified because they eliminate  costly clean-ups and
associated hazards from glass breakage and mercury spills.

Proper Spill Clean-Up
    Elemental mercury exhibits high toxicity via inhalation,
skin absorption and ingestion. Spill clean-up procedures
and handling operations must be carefully designed and
monitoredtoprotectemployeesandpublichealth. Specially
designed mercury vacuums and spill absorbent kits should
be used for spill clean-ups.

Recycle/Reuse
    Waste mercury can easily be recycled depending on
the type or degree of contamination. Residual mercury in
reservoirs of broken devices can be coarsely filtered and
reused. While mercury recovered from spills or otherwise
contaminated can be distilled to remove impurities, mercury
distillation requires a hazardous waste treatment permit
and possibly an air emissions permit. The equipment costs
and elaborate  permitting requirements make on-site
distillation infeasible at most hospital, facilities.

    ECRI (ECRI March 1989)lists four mercury refineries
in the U.S:

      Adrow Chemical Co.
      3 Lines Ave.
      Wanaque, NJ 07465
      (201) 839-2372

      Bethlehem Apparatus Co., Inc.
      890 Front St
      Hellertown, PA 18055
      (201) 838-7034

      D.F. Goldsmith Chemical and Metals Corp.
      909 Pitner Ave.
      Evanston, EL 60202
      (312) 869-7800

      Mercury  Distributors, Inc.
       13814 AlmedaRd
      Houston, TX 77053
      (713) 433-2418

    In addition, your regional U.S. Environmental Protec-
tion Agency office or your state environmental department
may have information about commercial mercury-recov-
ery firms in your area.
    One mercury recycler provides hospitals with an
airtight steel container that can hold up to 76 pounds of
mercury.  The container is used  at the hospital for
collecting and then can be used to ship the mercury to the
recycler without additional packaging (ECRI March
1989).            .                 ;

WASTE ANESTHETIC GASES
    Non-hazardous substitutes are not available for
anesthetic gases. The waste minimization options that
are feasible are measures designed to reduce leaks and,
as a result, reduce exposure of health care personnel to
releases of these gases in the workplace. Many of these
measures are in fact "better operating practices."  The
reduction of inadvertentreleases of gases in the workplace
will, in the long run, reduce the amount of gases purchased
and the overall amount released as waste.
    ECRI (Feb.  1988) recommends  the following
approach for controlling waste anesthetic gases:

    • Use of low-leakage anesthetic equipment.
      Generally equipment less than 10 years old
      complies with low-leakage standards.

    • Proper routine maintenance, by qualified
      personnel, of  anesthesia equipment,
      scavenging equipment,  and  the ventilation
      system.

    • Daily leak testing before use of equipment

    • Quarterly monitoring of waste  anesthetic
      levels in operating rooms, recovery rooms,
      dental suites, and adjacent rooms that may
      receive waste gases.

    In addition, ECRI recommends several anesthetist
workpracticesdesignedtominimizeleakageandresulting
worker  exposure. These include, before  inducing
anesthesia: confirming proper connections  and leak
tightness of equipment, and avoiding spillage of liquid
anesthetics while filling vaporizers. During anesthesia
administration, anesthetists can  reduce leakage by
properly  fitting the mask on the patient's face before
turning on anesthetic  flow, and by turning off the gas
supply before disconnecting the breathing circuit during
short interruptions.

    In larger operating rooms, the anesthesia supply
system may include permanent, piping in the walls of the
room. This piping is  tested rigorously for leaks at the
time of installation. However, routine post-installation
testingprocedures are generally designed to assure proper
flow and pressure of the anesthetic gases without specifi-
                                                      16

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cally testing for leaks. As a result, leaks in wall plumbing
may go undetected for years. To avoid losses of anesthetic
gases and exposure of hospital personnel, tests for leakage
in this part of the supply system should be performed
periodically (Bastian 1989).

TOXICS, CORROSIVES, AND MISCELLANEOUS
CHEMICALS
    Standard  waste minimization practices, such as
replacing oil-based paints, reducing disposal of unused or
out-of-date materials (paints, pesticides, chemicals, etc.),
controlling inventories, and improving waste tracking
systems are all applicable to the hospital  environment.
Vehicle and building and grounds maintenance operations
generate waste oils, vehicle maintenance waste, solvents,
pesticides, water treatment chemicals, and possibly PCB
oil from old transformers, asbestos, and other wastes.

    Opportunities to minimize wastes in these activities
include:

    • Collect waste oil and solvents for recycling.

    • Segregate recyclable oils  and solvents from
      non-recyclable wastes.

    • Replaceoil-based paints with water-based paints
      in-maintenance operations.

    • Reduce generation of pesticide waste by
      reducing pesticide application, using non-
      chemical pest control methods, and preparing
      and using only the required quantities.

Ethylene Oxide
    There  are currently no acceptable non-hazardous
substitutes for ethylene oxide's (EtO) use as a sterilant for
a number of medical devices.   Several companies  are
reportedly working on alternatives toethyleneoxide (EtO);
however, details on these substitutes are not yet available
(ECRI Sept 1988).

    Currently all waste  EtO is vented to the outside
atmosphere.  The California Air Resources Board has
designated ethylene oxide as a toxic air contaminant; this
development may lead to emissions regulations for EtO.

    Better operating practices can be employed to reduce
the chances of spillage and accidental release of  EtO in
hospitals. These include frequent inspection and proper
maintenance of EtO sterilizer equipmentincluding checking
the seal integrity of sterilizer doors, and proper training of
personnel in the use of EtO sterilization equipment and
handling of EtO cylinders and cartridges.

Use of Recyclable Drums
    Many chemicals used in hospital engineering/
maintenance and in the laboratories are supplied in drums.
Unless the empty drums are triple rinsed before disposal,
they may have to be handled as hazardous waste. Many
industrial facilities now take delivery of chemicals in 400
gallon recyclable tote drums. When empty, the tote drum
is returned to the supplier for cleaning and refilling. This
will ensure that the container and any chemical residue left
inside it do not have to be disposed of by the hospital.

Proper Material Handling
    Use of mechanical handling  aids  for drums and
adherence to general spill reduction techniques will decrease
spill potential.  Pre-mixed solutions of these compounds
also decrease  spill potential by reducing handling
requirements. In the laundry facility, an automated system
that pumps bleach directly from drums into the machines
decreases spillage.

Material Substitution
    Oxidizers  are  found  in  hospital  laundries  and
laboratories. Process modification may minimize oxidizer
waste. For liquid oxidizers, such as hydrogen peroxide, the
most dilute form that will still be effective should be used.
As an example of an opportunity for process modification,
consider the procedure of using benzoyl peroxide to reduce
color in tissue or blood samples. Benzoyl peroxide is a
strong oxidizing agent that may explode spontaneously
when dry. Substituting a 30 percent hydrogen peroxide
solution for the benzoyl peroxide is more economical. This
solution is a weaker, yet effective oxidizing agent and is not
subject to spontaneous combustion.

    In hospitals, poisons such as glutaraldehyde and phenol
may be used in sterile processing, laboratories, and nursing
units. The main waste minimization technique in dealing
with poisons is substitution with a less environmentally
hazardous compound or process, where possible. Examples
of this are steam or sonic sterilization instead of chemical
sterilization.
                                                       17

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                                           SECTION 4
  GUIDELINES FOR USING THE WASTE MINIMIZATION ASSESSMENT
    Waste minimization assessments were conducted at
three hospitals. The assessments were used to develop-the
waste minimization questionnaire and worksheets that are
provided in this section.

    A comprehensive waste minimization assessment
includes a planning and organizational step, an assessment
step that includes gathering background information and
development of waste minimization options, a feasibility
study on specific waste minimization options, and an
implementation phase.
         The worksheets provided in this section are intended
     to assist hospital managers in systematically evaluating
     waste generating processes and in identifying waste
     minimization opportunities. These worksheets include only
     the assessment phase of the procedure described in the
     Waste Minimization  Opportunity Assessment Manual:
     For a full description of waste minimization assessment
     procedures, refer to the EPA Manual.  .

         Table 3 lists the worksheets that are provided in this
     section.                           ;
Table 3.  List of Waste Minimization Assessment Worksheets
    Number          Title
    1.          Waste Generation Questionnaire
    2.          Waste Quantities
    3.          Material Procurement and Usage
    4          Material Procurement and Usage
    5.          Waste Management Practices
    6.          Waste Management Practices
    7A         Selected Waste Streams

    7B.        Selected Waste Streams

    1C.        Selected Waste Streams
    8A.        Options/Selected Waste Streams

    8B.        Options/Selected Waste Streams

    8C.        Options/Selected Waste Streams
         Description                   '•
Questions on hospital waste tracking        ;
Form for documenting wastes by type and department
Questionnaire                           \
Waste minimization options
Questionnaire                           :
Waste minimization options
Questionnaire on chemotherapy and antineoplastics;
 flammable and chlorinated solvents
Questionnaire on formaldehyde, photographic
materials, radioactive materials            :
Questionnaire on mercury; anesthetic gases; ;
and toxics, corrosives, and miscellaneous compounds
Questionnaire on general practices         ;
Options for chemotherapy and antineoplastics;
flammable and chlorinated solvents; and formaldehyde
Options for photographic chemicals,        |
materials, mercury, and waste anesthetic gases
Options for toxics, corrosives and miscellaneous chemicals;
general options                        :
                                                   18.

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References
American Conference of Governmental Industrial
    Hygienists (ACGIH). 1987. Documentation of TLVs
    andBEIs. Cincinnati, OH.

Bastian.F. 1989. Personal communication with F.Bastian,
    senior industrial hygienist, ECRI, Plymouth Meeting,
    PA. July 19,1989.

Calif. DHS. August 1988. "Waste Audit Study: General
    Medical and Surgical Hospitals." Report prepared by
    Ecology and Environment, Inc., San Francisco,
    California, for the California Department of Health
    Services, Alternative Technology Section, Toxic
    Substances Control Division.

Calif. DHS. December 1988. Waste Minimization Audit
    Study of the Photoprocessing Industry. Draft report
    prepared for the  California Department of Health
    Services, Alternative Technology Section, Toxic
    Substances Control Division.

Campbell, Mฃ. and W.M. Glenn.  1982. Profit from
    Pollution Prevention: A Guide to Industrial Waste
    Reduction and Recycling. Toronto, Canada: Pollution
    Probe Foundation.

ECRI.   January 1988.  "Formaldehyde exposure: new
    standard directly affects hospitals," Hospital Hazardous
    Materials Management, Vol. 1, No. 4.
ECRI.   February  1988.  "Waste anesthetic gases:
    controlling the risk," Hospital Hazardous Materials
    Management, Vol. 1, No. 5.

ECRI.  September 1988. "EtO sterilization: possible
    alternatives'being developed," Hospital Hazardous
    Materials Management, Vol. l,No.!2.

ECRI. January 1989. "Ethylene oxide: protecting your
    employees,"  Hospital Hazardous Materials
    Management, Vol. 2, No. 4.

ECRI.  March 1989. "Mercury: quicksilver and other
    poisons,"  Hospital  Hazardous  Materials
    Management, Vol. 2, No.6.

Roark, R.R. June 16,1989. Letter from R. Roark, B/R
    Instrument Corp, to Andrew Nelson, Jacobs
    Engineering Group Inc.

Sawyer, C.N. and PJL. McCarty 1967. Chemistry for
    Sanitary Engineers. McGraw-Hill Book Co., N.Y.

The Merck Index, Tenth Ed. 1984. Rahway.NJ.

USEPA. 1988. Waste Minimization Opportunity
    Assessment Manual. Hazardous Waste Engineering
    Research Laboratory, Cincinnati, Ohio, EPA/625/
    7-88-003.

USEPA. 1986. WasteMinimization-issuesandOptions.
    Volume l-lll. EPA/530-SW-86-041 through-043.
    U.S.  Environmental  Protection  Agency.
    Washington, D.C.
                                                    19

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Hosp..
Site   .
Date  .
                                     Waste Minimization Assessment
Proj. No.
Prepared By       :     	
Checked By     '  !
Sheet	of	  Piige __ of __
    WORKSHEET
         1
 WASTE GENERATION:
       Questionnaire
 A. GENERAL INFORMATION
 Indicate which of the following departments are included in the facility:
        Chemotherapy
        Analytical laboratory
        Clinical laboratory
        Hemodialysis
        Pathology
        Histology
        Anesthesiology
       Facilities maintenance
       Radiology
       Startle processing
       Pharmacy
       Nuclear medicine
       Autopsy
 S.  WASTE GENERATION DATA
 Methods for quantifying the waste generated for the entire hospital facility should be
 developed and implemented.
 Are facility-wide material balances routinely performed?
 Are they performed for each material of concern (e.g. solvent) separately?
 Are records kept of individual wastes with their sources of origin and eventual disposal?
 (This can aid in pinpointing large waste streams and focus reuse efforts.)

 If answer is no: H adequate waste data are not available, establish a method for assessing
 waste quantities such as trie table shown in Worksheet 2. These forms should be kept on file
 and B possible, stored on a computer data base. Quarterly and yearly totals for hazardous
 waste generation can easily be determined using those manifests.

 This type of data is important for the following reasons:
    -  the data define the scope of waste generation for the entire facility and for
       each department;
    -   realistic wasto reduction goals can be established;
    -   specific generators can be targeted for waste reduction: and
    -   costs for proper waste management can be determined.
If answer is yes:  Establish facility wide and departmental waste reduction goals.  Setting specific
goals provides an incentive to meet established goals. A central committee should establish
goals. The committee should be made up of personnel from the hospital environmental/safety
office, administration, and managers/technicians from each waste generating department.  Reel-
uction goals should range from 3% to 10% per year. The committee should meet quarterly to
assess progress in achieving goals.
                                               -Jyt*
                                               Dyts
                           3 no
                           3no
                           3 no
                                                     20

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                            21

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Hasp Wast* Minimization Assessment Pป>
Sifซ Chi
patซ proj NO Shi


WORKSHEET WASTE MINIMIZATION:
3 Malarial Procurement and Usage

Use separate forms for departments if procurement is not done centrally.
Is procurement of chemicals done through a central department or person?


pared By ;
icked By
ict of Paae of


Gyes Gno


When products arrive, are they processed through a central receiving department or person? G yes D no
If nn ป*pl?in-



Is the inventory system computerized? G yes G no
The current supply stock is capable of meeting 	 	 months of usage. Complete inventories
of chemicals stocks are conducted 	 times par year.
Does the current program adequately prevent the generation of waste due to over-purchasing? G yes D no
Since a significant portion of laboratory waste is actually surplus reagent chemicals, is it possible
to purchase smaller quantities of reagent chemicals? This would reduce generation of this
chemical waste.
is it possible to increase the amount of sharing of chemicals between laboratories? This would ' 3 jits D no
reduce the amount of surplus chemicals that require disposal.
Is obsolete raw material returned to the supplier? Q yซs G no
Is inventory used in tirst-in, first-out order? G yes G no
Does the current inventory control system adequately prevent waste generation? HI yซs G no
What information dons thซ system track?



Is there a formal personnel training program on hazardous material handling, spill prevention,
proper storage techniques, and waste handling procedures? Oyts Gno
Does the program include information on the safe handling of the types of drums, containers
and packages received? G yes G no
HOW oftan ie fraiivng gtvซn and by whom? 	 i



Does the facility have a written spill prevention and mitigation plan?
G yes G no
22

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nosp Wastซ Minimization Assessment prepared By
Srte Prpc Unrt/Oper.
t Checked By
Dam Proj. No. : Sheet of Page of
• . > • • • • . . .
- i- -
WORKSHEET OPTION GENERATION:
4 Material Procurement & Usage
. „ . . . , ,, . - - . - - -
Meeting format (e.g., bralnstormlng, nominal group technique)
Meeting Coordinator


Meeting Participants

Suggested Waste Minimization Options
A. General Information
Centralize chemical and other procurement
Computerize inventory
Avoid over-purchase of supplies
Purchase smaller quantities of chemicals
Share chemicals among departments/laboratories
Label all chemical and waste containers
Return material to supplier
Use supplies in first-in, first-out order
Train personnel in material handling/
spill prevention
Write spill prevention/mitigation plan











••


Currently
Done Y/N?


























Rationale/Remarks on Option














: - . '











. 23

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Hosp.
&ซ•
r>aปซ

Waste Minimization Assessment Prepar
Check
Proj No Sheet


WORKSHEET WASTE MINIMIZATION:
5 Waste Management Practices

ed By
sdBv
of Page of


The following checklist should be completed by the facility's hazardous materials coordinator '
or engineer, or by departmental laboratory managers if practices vary among departments. :
nปpa^mf nf :
Name of person completing checklist: -
A. GOOD OPERATING PRACTICES
Are all affected personnel provided wttl
Are regularly scheduled training progra
Are there employe* incentive programc
Does the facility have an established w
If yes. is a specific person assigned to
Discuss the goals of the program and r
TitlA-
i detailed operating manuals or instruction sets?
ms offered to all personnel?
( related to waste minimization?
aste minimization program in place?
oversee the success of the program?
osjjtts:


G yes G no
G yes G no
D yet G no
G yes G no
Gyos Gno


Has a waste minimization assessment been performed at the facility in the past?
If yes riiscuf ซt:




i. WASTE MANAGEMENT PRACTICES
Is there a master list of hazardous waste generated? D yes G no
Are containers and bags w/ hazardous waste residues segregated from nonhazardous wastes? D yes G no
To reduce the generation of empty containers, has the facility attempted to use bulk dispensers
(e.g. returnable drums) and reuseabie transfer containers? D yes 3 no
Are hazardous wastes stored in a centralized area? Dyes Gnp
Is there a single individual m charge erf hazardous waste tracking and management throughoijt
the facility? dyes Gno
Have waste streams which are discharged to the sewer or municipal landfill been evaluated for
toxicity. f lammabtty, corrosivity. and reactivity, to determine whether the waste stream is
hazardous? D yes G no
Are infectious wastes which contain hazardous wastes segregated from nonhazardous
infectious wastes? O yes Gno
24

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Hosp. Waste Minimization Assessment Prepared By
Srta Proe Untt/Ooar.
Checked By
natป Pmj. NO. Sheet of Paoe of


WORKSHEET OPTION GENERATION:
O Waste Management Practices

Meeting format (e.g., bralnstormlng, nominal group technique)
Mtttlng Coordinator


Meeting Participant*

Suggested Watte Minimization Options
A. Good Operating Practices
Train personnel
Provide operating manuals
Employee incentives for waste minimization
Establish waste minimization program & policy
Set goals for source reduction
Set goals for assessments
Conduct annual assessments

B. Waste Management
Establish person responsfcle to
track/manage wastes
List hazardous wastes generated
Segregate wastes
Use buk dispensers
Store hazardous wastes centraly
Evaluate hazard of discharged/tanoliled wastes
Segregate infectious from hazardous wastes






„

Currently
DoneY/N?


























Rationale/Remarks on Option


























25

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Wnsp.
ซป•
Dal*

Wast* Minimization Assessment

Proj No

Prepared By
Checked Bv
Sheet of Page of
.. !
    WORKSHEET
      7A
 WASTE MINIMIZATION:
Selected Waste Streams
A. CHEMOTHERAPY AND ANT1NEOPLAST1C WASTES
Are chemotherapy wastes segregated from other wastes?                                 3 yes|       Zl no
(Disposable garments, if not contaminated, may be disposed of with non-hazardous refuse but        i
gloves are assumed to be contaminated.)                                                     ;
Is the biological safety hood cleaned no more frequently than once per day. with thorough de-
comamination occurring once per week as specified in OSHA Publication 6-1.1  (Antineoplastic        ;
Drug Handling)?                                                                     G yesj       a no
Are drugs purchased in container sizes that permit formulation of daily dosages with the least         |
quantity of excess product leftover?                                           .    •     Gyw:       Gno
                                                                                        '!
B. FLAMMABLE AND CHLORINATED SOLVENTS                                           !
Has substitution with toss environmentaBy hazardous materials or methods been evaluated?    G yen!'  • •    Gno
If yes. did the evaluation include:                                                             i
   -   use of sonic or steam cleaning                                                  O yet!       Dno
   •   use of aqueous reagents                                                       Gyeป.       3 no
   -   use of simple alcohols and ketones instead of petroleum hydrocarbons                G ye$j       O no
   -   use of non-chlorinated instead of chlorinated solvents                              D ywj       Gno
   -   other (explain)                                                                     :
                                                                                         i
Have routine processes such as fixation and extraction been evaluated to determine if quantities      !
of reagents used in these processes could be minimized?                                 O yeซ,       G no
If yes. did this evaluation include (check as appropriate):
   -   reducing volumes of reagents                                                  G yeoi       G no
   -   using calibrated dispensers                                                    Q yes;       Gno
   -   using urutized test kits                                                         G yesj       G no
   . -   other (explain):                                                                    ,,..  .
                                                                                         I

If solvents are used for cleaning, to counter current cleaning posstte?                       G yeซ  '     G no
This uses the used solvent for Wtlal cleaning and fresh solvent only for the final cleaning. This        !
decreases the amount of reagent solvent used.         .
Have requirements been established for purity of fresh solvents?                           G yeft       G no
Are waste solvents separated Into containers spetifie to single compounds so that simple distiB-
ation is more feasible?                                                               G yea;       G no
If the above answer is yes. are any individual waste solvents generated in quantities large enough    '
to warrant distillation of those solvents separately, ueing a simple batch dtotiatton column?     G yen       G no
(Cost ranges from approximately $3,000 for a 5-gaJton unit to $14,000 for a 55-gaBon unit.)
Are many different solvents used for cleaning?                                           G yeii       D no
If too many small-volume solvent waste streams are generated to justify on-alte distillation, can       :
the solvent used for equipment cleaning be standardized?                                 G yea       G no
                                                      26

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Hasp
Sitft
Datfl

Wast* Minimization Assessment

Proj No

Preoared By
C hacked Bv
Sheet of Pace of

   WORKSHEET
      7B
 WASTE MINIMIZATION:
Selected Waste Streams
B. FLAMMABLE AND CHLORINATED SOLVENTS (CONT.)
If solvent wastes cannot be segregated, are combined quantities of waste solvents large
  enough to warrant distillation using a fractionating distillation column?                      Oyes        D no
If on-site recycling is not currently feasible, has off-site recycling or the use of a waste
  exchange been evaluated?                                                          Dyes        ~Jno

C. FORMALDEHYDE
Were culture studies performed to determine minimum strength of formalin required & minimum
  cleaning frequency for adequate disinfecting of dialysis machines and water supply systems? D yes        3 no
Has the use of reverse osmosis water supply equipment to reduce the need for formaldehyde
 cleaning been investigated?                                                          Dyes        3 no
Has the reuse of formaldehyde in autopsy and pathology laboratory specimen preservation
  been Investigated?                                                                 O yes        One
Are airborne emissions from formaldehyde use property controlled?
Is formalin dispensed via a central distribution system with plumbing connected to
  each machine?                                                                    a yes        Ono

D. PHOTOGRAPHIC MATERIALS
Does storage area have proper temperature/tight conditions for photoprocMSing chemicals?    O yes        O no
Is material with expired shelf life tested for effectiveness before being returned or disposed of?  Oyes        CD no
Are obsolete or off-spec chemicals returned to manufacturer?                              Oyes        Ono
Is used and spoiled film sold to a recyder?                                              Oyes        O no
Are photoprocessing bath solutions optimized cnemicafly to extend bath life by:
   •   adding ammonium thiosuiiate?                                                  Oyes        3 no
   -   using acid stop bath prior to fixing?                                              Oyes        Ono
   •   adding acetic acid to fixing bath to keep pH tow?                                  Oyes        Ono
   -   keeping baths in covered, air-tight containers toreduce evaporation and oxidation?     Oyes        Ono
in non-automated processing systems, are squeegees used to minimize bath solution toss?    O yes        O no
Is countercurrent washing used In photographic processors to reduce wastewater generation?  Oyes        Ono
Is silver recovered from fixing baths to permit bath regeneration?                           Oyes        Ono

E. RADIOACTIVE MATERIALS
Are isotope containers returned to the distributor?                                        O yes        O no
Have processes been evaluated for substitution of tong-lived isotopes with short-lived isotopes? O yes        O no
Does the facility provide space (100 to 200 square meters) for isolation and interim storage o(
short-lived radioactive wastes during decay to acceptable levels?                           Oyes        Ono
Are radioactive wastes property labelled as to form, isotope, chemical composition: kept
segregated: and centrally processed?                                                  Oyes        Ono
                                                     27

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Hosp..

Sttt  .

Date .
                                   Waste Minimization Assessment
Proj. No.
Prepared By      .	
Checked By      :•	
Sheet	of	  (Page	of
    WORKSHEET
       7C
 WASTE MINIMIZATION:
Selected Waste Streams
 F. MERCURY                                                                      j
 Have solid state electronic sensing devices been substituted tor mercury-containing devices?   G yes        U no
 Is mercury recovered for reuse and contaminated mercury turned over, to a commercial          j
 mercury recycler?                                                                  G yes        D no
 Are mercury spill cleanup kits available?                                               Dyes        3 no
 If yes, have personnel been trained to use the kits?                                      D yea        D no

 a WASTE ANESTHETIC GASES
 Is low-leakage anesthetic equipment used?                                      •       Qyes        Gno
 Are Inspections and maintenance of Anesthesia equipment,  scavenging equipment.
  and ventilation systems performed regularly and by qualified personnel?                   G yee        G no
 Are tow leakage anesthetic practices employed?                                        G yes        G no


 H. TOXICS, CORROSIVES, AND MISCELLANEOUS CHEMICALS                         ,
 In sterile processing, can steam or sonic sterilization be used instead of sterilization             i
  using hazardous chemicals?                                                       G yes        G no
 Is ethylene oxide equipment frequency inspected and property maintained?                  Gyts        Ono
 Are personnel property trained In handling ethytone oxide equipment?                       G yen        Gno
 Can volumes of chemicals used in experiments bo reduced?                              G yes        G no
 Has the use of less toxic or diluted solutions of cleaning agents been investigated?            d yto        Gno
 If yes, describe the results:	,	
Are automated systems used for dispensing laundry chemicals to reduce spillage?
Are chemicals purchased in recyclable containers?
Are chemical containers returned to the suppler (or reuse?
ArernechankalaWsusedinhandBrfldnjmeolchernicatetorecboaspias?
Has the use of physical instead of chemical cleaning methods been investigated?
If yes, describe the results:	
                                              Gyes
                                              Gyet
                                              Gyts
                                              Gyw
                                              Oyjts
                          Gno
                          Gno
                          Gno
                          Gno
                          Gno
                                                  28

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HOSp.
Site
Date
                                   waste Minimization
Proj. No.
Prepared By 	
Checked By 	
Sheet	of	  Page 	of  	
    WORKSHEET
       7D
 WASTE MINIMIZATION:
Selected Waste Streams
 f. GENERAL PRACTICES
 Are high volume chemical inventories minimized to a four-week supply or less?              G yes        D no
 Are spill containment and clean-up kits available?
 Are chemicals and liquid wastes stored in areas which do not drain directly to the sewer?      G yes        G no
 Are ad chemicals containers property labeled?                                         O yes        3 no
 Are all wastes properly segregated?                                                  Dyes        Gno
 Has off-site reuse of wastes through waste exchange services been considered?
 Or reuse through commercial brokerage firms?                                         G yes        G no
 If yes. results:	—	
 Has the feasibility of constructing a pretreatment unit for formaldehyde and other organic
 solvent wastes been explored?                                                      G yes        Gno
 If yes. what type of unit was considered?                                              G yes        Gno
 Oxidation     Carbon Adsorption
 Other (describe):—_	
                                                    29

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•
Hasp. Waste Minimization Assessment Pmpa,^ BY
Srffl Pme LJniJ/Opar.
Checked Bv
Data Pmi. NO. Sheet of Pace of


WORKSHEET OPTION GENERATION:
OA Selected Waste Streams

Meeting fonnat (e.g., bralnstonnlng, nominal group technique
Meeting Coordlnttor
• •-

Mtttlno Purtte'rw "ซ*

Suggested Waste Minimization Options
A. Chefliotherapy and AntlneopEastlcs
Segregate chemotherapy wastes
Reduce cleaning frequency per OSHA regulations
Optimize size of drug containers purchased

B. Flammable and Chlorinated Solvents
Use less hazardous materials
Use aqueous reagents
Reduce quantities of reagents
Use sonic or stoam cleaning
Determine purity of solvent needed
Countercurrent cleaning using solvents
Standardize solvent use
Segregate waste solvents
Distal/recycle solvents
Off-site solvent recydng

C. Formaldehyde
Use of minimum strength formalin required
Minimize cleaning frequency
v Automate formalin dispensing
Reuse formalin preservative
Employ proper air emission control



Currently
OoneY/N?


























Rationale/Remarks on Option


























30

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Hasp. Wast* Minimization Assessment Preoarad Bv
SHซ Pmc Unit/Oper.
Checked By
nata Pmi. NO. Sheet of Paofl of
•
•
WORKSHEET OPTION GENERATION:
SB Selected Waste Streams

Meeting format (e.g., bralnstormlng, nominal group technique)
MMtlng Coordinator _. 	 	 	


Meeting Participant*

Suggested Wast* Minimization Options
D. Photographic Chemicals
Use proper chemical storage conditions
Return off-spec chemicals to supplier
Extend photoprocessing bath life
Test expired supplies for effectiveness
Use squeegees to minimize bath toss
Use countercurrent washing
Recover silver

E. Radioactive Materials
Return containers to supplier
Use short-lived isotopes
Store short-Jived wastes on site for decay
to acceptable levels

F. Mercury
Use electronic sensing devices
Provide mercury spM Us
Recover and recycle mercury

G. Waste Anesthetic Oases
Use tow-leakage equipment
Inspect/maintain equipment
Practice tow leakage anesthesia use


Currently
OoneY/N?


























Rationale/Remarks on Option


























31

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Hoi.p Wast* Minimization Assessment Prepared By

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                                             Appendix A
                FACILITY ASSESSMENTS OF THREE HOSPITALS
    In 1986 the California Department of Health Services
commissioned a waste minimization study (DHS 1988) of
three general medical and surgical hospitals. The objectives
of the waste minimization assessments were to:

    •  Gather site-specific information concerning the
      generation, handling, storage, treatment, and
      disposal of hazardous waste;

    •  Evaluate existing waste reduction practices;

 '   •  Develop recommendations for waste reduction
      through source control, treatment, and recycling
      techniques; and

    •  Assess costs/benefits  of existing  and
      recommended waste reduction techniques.

    In addition, the results of the waste assessments were
used to prepare waste minimization assessment worksheets
to be completed by other hospitals in a self-audit process.

    The first steps in conducting the assessments were the
selection of the three hospitals, and  contacting them to
solicit voluntary participation in the audit study. During
each of the hospital audits, the audit team observed a
variety of hospital operations; inspected waste management
facilities; interviewed the hospital managers, environmental
compliance personnel, and laboratory supervisors; and
reviewed and copied records pertinent to waste generation
and management The audits were performed by one or
two engineers over a one- to three-day period depending on
the size and complexity of the formulating and waste
management operations.

    This Appendix section presents  the results of the
assessments of the hospitals here identified as A, B and C
and the  potentially useful  waste  minimization options
 identified through the assessments. Also included are the
practices already in use at the facilities that have successfully
 reduced waste generation from past levels.

 Findings of Waste Audit of Hospital A
    Hospital A is a general surgical hospital with 323 beds
 and 2,000 employees. The types of in-house departments
 are typical for a full-service hospital, although much of the
 laboratory work is performed through aregional laboratory
 at a separate location. This regional laboratory manages
some of the hazardous waste streams that the hospital
would otherwise be required to manage itself.  Out-
patient clientele consists of approximately  125 to 150
persons per day.

    Procurement of hazardous materials is conducted
throughacentralclinicandaseparate general purchasing
department. Hazardous waste manifests are maintained
by the housekeeping department.   The hospital has
conducted an internal environmental compliance audit
and has inventoried hazardous materials on site. Waste
minimization, however,  has not been specifically
addressed.

    The laboratory and pathology departments generate
primarily xylene and formaldehyde waste, in the amount
of about one gallon each per month.  In both cases, this
waste is discharged to the sewer. Reagents are used in
"contained packs" for unit applications. These are
disposed of as infectious waste.

    Hazardous wastes generated by the radiology/
imaging department consist of fixer, developer, and
mercury on occasion. Silver from the fixer is extracted
and 20% of the solution is recycled. Although mercury
disposal does not occur on a routine basis, it is handled
regionally.

    The central sterile supply  department generates
only ethylene oxide, which is vented to the atmosphere
and sewer.

    The engineering  department handles various
hazardous materials. It generates only about three gallons
per month of used oil, which is transported off site for
disposal. This department also uses  solvents, aerosols,
and water-based latex paints, whichare consumed. Boiler/
water treatment compounds are also consumed.

    The pharmacy generates  antineoplastic wastes,
which are hauled off site for incineration. It also generates
outdated drugs,  which are returned to the regional
pharmacy (see Figure A-l).

    The respiratory therapy  department generates
approximately 16 ounces of 70% alcohol per day, which
is discharged to the sewer.
                                                      33

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    The hemodialysis department generates 4%
formaldehyde waste, which is disposed of to the sewer at
a rate of about 8 liters per week. It also generates 5.25%
sodium hypochlorate, which is also discharged to  the
sewer, at a rate of about 10 liters per week (see Figure A-
2).

Findings of Waste Audit of Hospital B
    Hospital B is a general surgical hospital with 415 beds.
In-house departments include a laboratory, pathology,
engineering, radiology, histology, dialysis, anda pharmacy.
Primary sources of hazardous wastes include hemodialysis,
theclinical testing laboratory, and the pharmacy. Outpatient
clientele consists of approximately 100 persons per day.
Hospital B has not conducted any in-house environmental
compliance or v/aste minimization audits.

    The pharmacy purchases antineoplastic chemicals,
which are inventoried through a computerized central
receiving system. Supplies kept in-house at a given time
are inventoried to last two weeks. Antineoplastic drugs
used as chemotherapy agents are the hospital's largest
sourceof hazardous waste by volume. Approximately two
five-gallon disposal cans are filled ^with liquid chemo-
therapy waste each week.  Gowns;, gloves, and other
articles contaminated by cytotoxic drugs are bagged and
placed in 55-gallon steel  drums.  All chemotherapy
wastes are transported off-site for disposal (see Figure A-
3).   .            '            |

    Hazardous waste generated through hemodialysis
includes4% formaldehyde that has been pumped through
18 individual dialysis units, at the rate of 250 cc's per day.
Effluent lines from these machines are connected to the
municipal sewer  system.   Tubing! from the units is
discarded as infectious waste (see Figure A-4).

    Radioactive tagging in the clinical testing laboratory
is  also  a source  of hazardous  waste  at Hospital B.
Approximately 800 ml per week of radioactive water, or
tritium, are generated. About five gallons per month of
radioactive solid waste are  also generated.  Tritium is a
beta-emitter with a half-life of 57 years. An additional
200 ml per week of toluene are evaporated under a hood.
Radioactive wastes are transported off site for disposal
(see Figure A-5).
                                                      34

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                                Fugitive Vapors

                                       A
                               Aerosols Captured
                                 By Hepa Filter
Procurement Thru Clinic
One Month Inventory)
                                      I
Chemotherapy Agents
  Prepared In Hood
                                Spillage Outside
                                      Hood
                              Spill Kit, Absorbent,
                                isoclean Solution
                               Expired Drugs Sent To Warehouse
                              And Then Returned To Manufacturer
"Non-Sharp" Items And Solutions
    Go Into Plastic Trash Bag
                                      "Sharp" Items Into
                                   TwoS-Gallon Containers,
                                    Changed Once Per Day
                                                                     Incineration Facility
                                                                         5Feet-3/Day
                  Figure A-1, Hospital A-Chemotherapy Waste Stream
                                                 •35

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                        39

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 Connecticut Department of Economic Development
 210 Washington Street
 Hartford, CT 06106
 (203) 566-7196
 Georgia
 Hazardous Waste Technical Assistance Program
 Georgia Institute of Technology
 Georgia Technical Research Institute
 Environmental Health and Safety Division
 O'Keefe Building, Room 027
 Atlanta, GA 30332
 (404) 894-3806
 Environmental Protection Division
 Georgia Department of Natural Resources
 Floyd Towers East, Suite 1154
 205 Butler Street
 Atlanta, GA 30334
 (404) 656-2833
 Illinois
 Hazardous Waste Research and Information Center
 Illinois Department of Energy  of Energy  and Natural
 Resources
 1808 Woodfield Drive
 Savoy, DL 61874
 (217) 333-8940
 Illinois Waste Elimination Research Center
 Pritzker Department of Environmental Engineering
 Alumni Building, Room 102
 Illinois Institute of Technology
 3200  South Federal Street
 Chicago, IL 60616
 (313)567-3535
 Indiana
 Environmental Management and Education Program
 Young Graduate House, Room 120
 Purdue University
 West Lafayette, IN 47907
 (317)494-5036
 Indiana Department of Environmental Management
 Office of Technical Assistance
 P.O. Box 6015
 105 South Meridian Street
 Indianapolis, IN 46206-6015
 (317)232-8172
Iowa
Center for Industrial Research and Service
205 Engineering Annex
Iowa State University
Ames, IA 50011
(515)294-3420
 Iowa Department of Natural Resources
 Air Quality and Solid Waste Pro'tection Bureau
 Wallace State Office Building   j
 900 East Grand Avenue        j
 Des Moines, IA 50319-0034    i
 (515) 281-8690   "            i
 Kansas                      •
 Bureau of Waste Management   !
 Department of Health and Environment
 Forbes Field, Building 730      |
 Topeka, KS 66620            j
 (913)269-1607
 Kentucky
 Division of Waste Management
 Natural Resources and Environmental
 Protection Cabinet
 18 Reilly Road
 Frankfort, KY 40601
 (502) 564-6716                j
 Louisiana                    !
 Department of Environmental Quality
 Office of Solid and Hazardous w!aste
 P.O. Box 44307               i
 Baton Rouge, LA 70804        !
 (504)342-1354                :
 Maryland                    !
 Maryland Hazardous Waste Facilities Siting Board
 60 West Street, Suite 200 A     !
 Annapolis, MD 21401          I
 (301) 974-3432                !
 Maryland Environmental Service
 2020 Industrial Drive
 Annapolis, MD 21401          !
 (301) 269-3291                '
 (800) 492-9188 (in Maryland)    j
 Massachusetts                i
 Office of Safe Waste Management
 Department of Environmental Management
 100 Cambridge Street, Room 109|4
 Boston, MA 02202             j
 (617) 727-3260
 Source Reduction Program      <
Massachusetts Department of Environmental Quality En-
gineering
 1 Winter Street
Boston, MA 02108             [
(617) 292-5982
                                                42

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Michigan
Resource Recovery Section
Department of Natural Resources
P.O. Box 30028
Lansing, MI 48909
(517) 373-0540
Minnesota
Minnesota Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Road
St. Paul, MN 55155
(612) 296-6300
Minnesota Technical Assistance Program
W-140 Boynton Health Service
University of Minnesota
Minneapolis, MN 55455
(612) 625-9677
(800) 247-0015 (in Minnesota)
Minnesota Waste Management Board
123 Thorson Center
7323 Fifty-Eighth Avenue North
Crystal, MN 55428
(612) 536-0816
Missouri
State Environmental Improvement and Energy
Resources Agency
P.O. Box 744
Jefferson City, MO 65102
(314) 751-4919
New Jersey
New Jersey Hazardous Waste Facilities Siting
 Commission
Room 614
28 West State Street
Trenton, NJ 08608
(609) 292-1459
(609) 292-1026
Hazardous Waste Advisement Program
Bureau of Regulation and Classification
New Jersey Department of Environmental
 Protection
401 East State Street
Trenton, NJ 08625
Risk Reduction Unit
Office of Science and Research
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
New York
New York State Environmental Facilities
 Corporation
50 Wolf Road
Albany, NY 12205
(518)457-3273
North Carolina
Pollution Prevention Pays Program
Department of Natural Resources and
Community Development
P.O. Box 27687
512 North Salisbury Street
Raleigh, NC 27611
(919) 733-7015
Governor's Waste Management Board
325 North Salisbury Street
Raleigh, NC 27611
(919) 733-9020
Technical Assistance Unit
Solid and Hazardous Waste Management Branch
North Carolina Department of Human Resources
P.O. Box 2091
306 North Wilmington Street
Releigh,NC 27602
(919) 733-2178
Ohio
Division of Solid and Hazardous Waste Management
Ohio Environmental Protection Agency
P.O. Box 1049
1800 WaterMark Drive
Columbus, OH 43266-1049
(614)481-7200
Ohio Technology Transfer Organization
Suite 200
65 East State Street
Columbus, OH 43266-0330
(614)466-4286
Oklahoma
Industrial Waste Elimination Program
Oklahoma State Department of Health
P.O. Box 53551
Oklahoma City, OK 73152
(405) 271-7353
Oregon
Oregon Hazardous Waste Reduction Program
Department of Environmental Quality
811 Southwest Sixth Avenue
Portland, OR 97204
(503) 229-5913
                                                43

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Pennsylvania
Pennsylvania Technical Assistance Program
501F. Orvis Keller Building
University Park, PA 16802
(814)865-0427
Center of Hazardous Material Research
320 William Pitt Way
Pittsburgh, PA 15238
(412) 826-5320
Bureau of Waste Management
Pennsylvania Department of
Environmental Resources
P.O. Box 2063
Fulton Building
3rd and Locust S treets
Harrisburg, PA 17120
(717) 787-6239
Rhode Island
Ocean State Cleanup and Recycling Program
Rhode Island Department of Environmental Management
9 Hayes Street
Providence, RI02908-5003
(401) 277-3434
(800) 253-2674 (in Rhode Island)
Center for Environmental Studies
Brown University
P.O. Box 1943
135 Angell Street
Providence, RI 02912
(401) 863-3449
Tennessee
Center for Industrial Services
102 Alumni Hall
University of Tennessee
Knoxville,TN 37996
(615) 974-2456
Virginia
Office of Policy and Planning
Virginia Department of Waste Management
11th Floor, Monroe Building
101 North 14th Street
Richmond, VA 23219
(804) 225-2667
Washington
Hazardous Waste Section
Mail Stop PV-11
Washington Department of Ecology
Olympia,WA 98504-8711
(206) 459-6322
Wisconsin                   j
Bureau of Solid Waste Management
Wisconsin Department of Natural 'Resources
P.O. Box 7921                ;
101 South Webster Street
Madison, WI53707           i
(608)267-3763                ;
Wyoming                   '
Solid Waste Management Program
Wyoming Department of Environmental Quality
Herchler Building, 4th Floor, West Wing
122 West 25th Street
Cheyenne, WY 82002
(307) 777-7752               \
                            i
WASTE EXCHANGES  i
Northeast Industrial Exchange  j
90 Presidential Plaza, Syracuse, NY 13202
(315) 422-6572               :
Southern Waste Information Exchange
P.O. Box 6487, Tallahassee, FL 3g313
(904) 644-5516               |
California Waste Exchange     !
Department of Health Services
Toxic Substances Control Division
Alternative Technology & Policy Development Section
714 P Street
Sacramento, CA 95814
(916) 324-1807
U.S. EPA REGIONAL OFFICES

Region 1 (VT, NH, ME, MA, CT, RI)
John F. Kennedy Federal Building
Boston, MA 02203           !
(617)565-3715               !
Region 2 (NY, NJ)           |
26 Federal Plaza             i
New York, NY 10278
(212) 264-2525               !
Region 3 (PA, DE, MD, WV, VA1)
841 Chestnut Street
Philadelphia, PA 19107        !
(215) 597-9800               ;
Region 4 (KY, TN, NC, SC, GAJFL, AL, MS)
345 Courtland Street, NE      '
Atlanta, GA 30365           |
(404) 347-4727
                                                44

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Region 5 (WI, MN, MI, IL, IN, OH)
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2000
Region 6 (MM, OK, AR, LA, TX)
1445 Ross Avenue
Dallas, TX 75202
(214) 655-6444
Region 7 (NE, KS, MO, IA)
756 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2800
Region 8 (MT, ND, SD, WY, UT, CO)
999 18th Street
Denver, CO 80202-2405
(303) 293-1603
Region 9 (CA, NV, AZ, HI)
215 Fremont Street
San Francisco, CA 94105
(415) 974-8071
Region 10 (AK, WA, OR, ID)
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-5810
                                               45

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