United States Region 8 EPA/908/R/98/001
Environmental Protection Office of Pollution Prevention June 1998
Agency Denver. CO 80202
&EPA Veterans Affairs
Medical Center
Pollution Prevention
Assessment
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VETERANS AFFAIRS MEDICAL CENTER
POLLUTION PREVENTION ASSESSMENT
Final Report
Prepared for:
Dianne Thiel 8P-P3T
Work Assignment Manager
U.S. EPA Region 8
999 18th Street, Suite 500
Denver, Colorado 80202-2466
Prepared by:
Tetra Tech EM Inc.
1099 19th Street, Suite 1960
Denver, CO 80202
O Contains 30% post consumer
content and is recyclable
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DISCLAIMER
The information in this document has been funded wholly by the United States Environmental Protection
Agency (EPA) under Contract 68-W4-0004 to Tetra Tech EM Inc. It has been subjected to the Agency's
peer and administrative review, and it has been approved for publication as an EPA document. Mention of
trade names or commercial products does not constitute endorsement or recommendation for use.
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CONTENTS
Section Page
1.0 INTRODUCTION 1
2.0 DENVER VAMC BACKGROUND AND ENVIRONMENTAL ASPECTS I
2.1 WATER USE AND WASTEWATER DISCHARGE 2
2.2 HAZARDOUS MATERIALS 3
2.2.1 Histology Laboratory and Morgue 3
2.2.2 Clinical Laboratory 4
2.2.3 Radiology 5
2.2.4 Facility Maintenance 5
2.3 HAZARDOUS WASTES 6
2.4 INFECTIOUS WASTE 7
3.0 CURRENT POLLUTION PREVENTION PRACTICES 7
3.1 SUBSTITUTION OF HEMO-DE FOR XYLENE 8
3.2 SUBSTITUTION OF IBF FOR B-5 TISSUE FIXATIVE 9
3.3 AUTOMATIC STAINING MACHINE 11
3 .4 SUBSTITUTION OF PERACETIC ACID FOR GLUTARALDEHYDE 15
3 .5 SOLID WASTE RECYCLING PROGRAM 17
3 .6 OTHER POLLUTION PREVENTION PRACTICES 18
4.0 RECOMMENDED POLLUTION PREVENTION PROJECTS 19
4.1 INFECTIOUS WASTE REDUCTION 20
4.1.1 Infectious Waste Generation at VAMC 20
4.1.2 Establishing an Infectious Waste Reduction Program at VAMC 22
4.1.3 Successful Infectious Waste Reduction 25
4.1.4 Potential Cost Savings from Infectious Waste Reduction 26
4.2 FORMALIN REPLACEMENT 27
4.2.1 Formalin Use and Disposal at VAMC 28
4.2.2 Replacement Options 28
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CONTENTS
Section Page
4.2.3 Formalin Recycling 30
4.2.4 Formalin and Formalin Replacement Costs 30
4.3 CLEANING SOLVENT REPLACEMENT 31
4.3.1 Sink-top Aqueous Cleaning Units 32
4.3.2 Implementation Issues 32
4.3.3 Solvent Substitution Costs and Benefits 33
5.0 OTHER POLLUTION PREVENTION OPPORTUNITIES 33
6.0 INDEX 38
TABLES
Table Page
2-1 DENVER VAMC BACKGROUND INFORMATION 1
2-2 HAZARDOUS MATERIALS USED AT DENVER VAMC 4
3-1 VAMC POLLUTION PREVENTION ASSESSMENT SUMMARY:
SUBSTITUTION OF HEMO-DE FOR XYLENE 9
3-2 VAMC POLLUTION PREVENTION ASSESSMENT SUMMARY:
SUBSTITUTION OF IBF FOR B-5 11
3-3 VAMC POLLUTION PREVENTION ASSESSMENT
SPECIAL STAINS REPLACED BY AUTOMATIC STAINING MACHINE 13
3-4 VAMC POLLUTION PREVENTION ASSESSMENT SUMMARY:
AUTOMATIC STAINING MACHINE 14
3-5 VAMC POLLUTION PREVENTION ASSESSMENT SUMMARY:
SUBSTITUTION OF PERACETIC ACID FOR GLUTARALDEHYDE 16
3-6 DENVER VAMC RECYCLED MATERIALS 17
4-1 ANTICIPATED COST SAVINGS AND WASTE REDUCTION BY PERCENT 27
4-2 VAMC POLLUTION PREVENTION ASSESSMENT FORMALIN REPLACEMENTS . 29
4-3 FORMALIN PURCHASING COSTS 30
4-4 COST COMPARISON OF FORMALIN VERSUS A FORMALIN REPLACEMENT 31
4-5 SINK-TOP AQUEOUS CLEANING UNITS AND VENDORS 35
4-6 VAMC POLLUTION PREVENTION ASSESSMENT SOLVENT SUBSTITUTION 37
FIGURES
2-1 VAMC COMPLEX MAIN BUILDING 2
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CONTENTS
Section Page
APPENDICES
1 VAMC FACILITY MAP 40
2 1996 CLOSING THE CIRCLE AWARD NOMINATION 42
3 VA P2 STRATEGY 47
4 FORMALIN RECYCLING SYSTEM PAYBACK PERIOD ANALYSIS 54
IV
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1.0 INTRODUCTION
This report presents the results of a pollution prevention (P2) assessment of the Denver Veterans Affairs
Medical Center (VAMC). The P2 assessment was conducted by personnel from U.S. Environmental
Protection Agency (EPA) Region 8, its contractor, Tetra Tech EM Inc. (Tetra Tech), and the Denver
VAMC. The scope of the P2 assessment included all hospital and facility operations except for research
laboratories and restaurants. The P2 assessment had two primary objectives: (1) document current
P2 practices, and (2) identify P2 opportunities. P2 practices and opportunities for this assessment include
techniques, technologies, and programs that reduce the quantity or toxicity of wastes generated, enable
waste recycling, or conserve natural resources.
The following sections discuss the Denver VAMC and the environmental aspects of its operations (Section
2.0), describe current P2 practices observed during the assessment (Section 3.0), present three proposed P2
projects for VAMC's consideration (Section 4.0), and list other P2 opportunities identified by the
assessment (Section 5.0).
2.0 DENVER VAMC BACKGROUND AND ENVIRONMENTAL ASPECTS
VAMC is a multibuilding complex located at 1055 Clermont Street in Denver, Colorado. The facility
consists of patient wards; surgical facilities; clinical, radiology, histology, and research laboratories;
pharmacy; morgue; nursing home; office space; maintenance facilities; and a food court and kitchen. A
map of the facility is provided in Appendix 1. General background information about the Denver VAMC
is summarized below. A photograph of the main building of the VAMC complex is shown in Figure 2-1.
TABLE 2-1
DENVER VAMC BACKGROUND INFORMATION
Number of beds
272 plus 60 in nursing home
Average bed occupancy
73 .5 percent
Facility property size
12 acres
Number of buildings in complex
21 buildings
Total floor space under roof
540,000 square feet in main building
Age of facility
40 years
Number of full-time employees
1,270
Number of part-time employees
180
Environmental staff
3 full time, 1 part time
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FIGURE 2-1
VAMC COMPLEX MAIN BUILDING
The major environmental aspects of Denver VAMC operations were investigated initially as a basis for
selecting P2 assessment focus areas and identifying P2 opportunities. The environmental aspects
investigated include water use and wastewater discharge, hazardous materials, hazardous wastes, and
infectious waste. Wherever possible, P2 opportunities that compliment the Department of Veterans Affairs
(VA) P2 Strategy have been incorporated (see Appendix 2). The process and sources of information Tetra
Tech used for the initial investigation are described in the following sections.
2.1 WATER USE AND WASTEWATER DISCHARGE
Water bills from fiscal year 1997 (October 1996 through September 1997) were reviewed to calculate
average monthly water use. During that period, the average monthly water use was 3,502,200 gallons.
The average monthly water purchase and sewer discharge costs were $4,062 and $6,829, respectively.
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Denver VAMC uses water for numerous purposes. According to a 1991 VAMC water audit conducted
by the Denver Water Department, the areas of greatest water use were domestic (sink, toilet, and shower
use), heating and cooling. Water is also used in grounds irrigation. The audit report concluded that the
greatest savings in water costs could be realized by reducing domestic and once-through cooling water
use. The report suggested installing flow restrictors on flush-valve toilets, replacing tank toilets with
low-volume toilets, installing aerators on sink faucets, and eliminating all once-through cooling units
through use of close-loop systems and equipment retrofit or retirement. The Denver Water Department
planned a follow up evaluation of the report's recommendations, but it was not executed because no
action had been taken on the recommendations 6 months or 1 year following the audit.
All wastewater from VAMC operations is discharged to the wastewater treatment plant (WWTP) Denver
Metro Wastewater Reclamation District (Denver Metro) via a sanitary sewer. The facility is not required
to obtain a discharge permit. Various areas of VAMC discharge a variety of chemicals to the sewer.
While the assessment team confirmed that Denver Metro accepts all chemicals discharged by the
Medical Center to the WWTP, disposal of chemicals to the sewer is not a pollution prevention practice.
2.2 HAZARDOUS MATERIALS
A variety of hazardous materials are used by several Denver VAMC departments. A summary of
hazardous material use is presented in Table 2-2 and discussed below. This table is not a comprehensive
list of all hazardous materials used at VAMC. Instead, it is a list of hazardous materials that were
focused on during assessment team visits to the facility.
2.2.1 Histology Laboratory and Morgue
The histology laboratory and morgue use about 110 liters (L) of formalin (formaldehyde and water) per
month for tissue and organ sample preservation. Tissue samples are stored in 15 to 180 milliliter (mL)
biopsy containers prepackaged with a 10 percent formalin solution. Organ samples are stored in 5-gallon
closed buckets that contain 1 to 2 gallons of a 10 percent formalin solution. Samples are typically stored
on site for about 6 months. When the samples are disposed of, waste formalin is flushed down the drain
with running water. Although no formal standard operating procedure (SOPs) exist for drain disposal,
employees are all directed to flush with "copious amounts of water." This disposal practice is acceptable
from a regulatory perspective. However, drain disposal is not a desirable practice from a P2 perspective,
which aims fundamentally at source reduction. Laboratory personnel estimated the waste formalin
generation rate is 600 mL per day from tissue samples and 60 to 120 L from organ samples every
3 months.
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TABLE 2-2
HAZARDOUS MATERIALS USED AT DENVER VAMC
Department
Hazardous Material(s)
Use
Histology Laboratory and
Morgue
Formalin (formaldehyde)
Xylene, toluene, various alcohols, and
other organic solvents
Miscellaneous chemicals
Tissue preservative
Tissue staining
Tissue staining
Clinical Laboratory
Methanol
Slide staining
Radiology
Silver-containing developers
X-ray developing
Facility Maintenance
Petroleum distillate
"Virginia 10" (petroleum distillate
containing perchloroethylene and
methylene chloride)
R-12 and R-22 refrigerant gases
Parts degreasing/cleaning
Parts degreasing/cleanmg
Air cooling systems
Operating Room
Cardiology
Gastrointestinal Laboratory
Ear, Nose, and Throat
Glutaradehyde
Ethylene Oxide
Equipment sterilization
Equipment sterilization
The histology laboratory is currently evaluating less toxic formalin substitutes. Detailed information
about the formalin substitution is provided in Section 4.2.
Historically, the histology laboratory used toluene, xylene, various alcohols, and other solvents in several
staining processes. Before 1986, xylene use decreased significantly as a result of a less toxic substitute
Hemo-De (see Section 3.1). A wide variety of solvents and chemicals are used for special staining;
however, use of these chemicals declined when the laboratory installed an automatic staining machine
(see Section 3.3). All staining processes are carried out under a ventilated hood, and waste organic
solvents used for staining are disposed of down a sink with running water. Although no formal SOPs
exist for drain disposal, employees are all directed to flush with "copious amounts of water." This
disposal practice is acceptable from a regulatory perspective. However, drain disposal is not a desirable
practice from a P2 perspective, which aims fundamentally at source reduction.
2.2.2 Clinical Laboratory
The clinical laboratory hematology division also uses staining procedures. Methanol is used as a rinse
step in the staining process. About 500 mL of methanol is used per day in the staining process. Before
the waste methanol is disposed of, it is reused to clean stain from slide racks. Waste methanol is
ultimately disposed of down a sink with running water. Although no formal SOPs exist for drain
disposal, employees are all directed to flush with "copious amounts of water." This disposal practice is
acceptable from a regulatory perspective. However, drain disposal is not a desirable practice from a
P2 perspective, which aims fundamentally at source reduction.
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2.2.3 Radiology
Medical, dental, and research x-ray films are developed in film processing units that use silver-
containing developing solution. Spent developing solutions from the processing units are combined in a
holding tank and batch treated to remove the silver. Primary treatment is accomplished using electrolytic
silver removal that involves electroplating metallic silver onto inert cathodes. A 30-gallon batch is
treated in 8 hours. Cathodes are removed from the primary treatment unit about every 2 months, when
silver deposition reaches 0.5 inch thick. Effluent from the primary treatment unit is pumped to a holding
tank and then through a secondary treatment unit that removes any residual silver. The secondary
treatment unit consists of two silver-scavenging filters arranged in series. Treated spent developing
solution is discharged to the sanitary sewer via a drain in the treatment room.
2.2.4 Facility Maintenance
The facility maintenance department is organized according to the following maintenance shops:
heating, ventilation, and air conditioning (HVAC); transport; grounds; paint; metal; carpentry; plumbing;
beds; and electrical. Many facility maintenance activities that involve hazardous materials are contracted
to external organizations; for example, no vehicles are repaired on site. Other shops have phased out or
are phasing out hazardous materials. For example, the HVAC shop has substituted the refrigerant in the
chillers, replacing R-l 1 with R-123. R-l 1 is a Class I ozone depleting substance (ODS). R-123 is a
Class 2 ODS and is less detrimental to the ozone layer. However, the HVAC shop does maintain a small
R-l 2 and R-22 inventory to top-off air conditioners.
The paint shop uses only latex paint and has reduced its painting requirements. The Medical Center has
been painted with a standardized, limited set of paint colors. Paint colors can be chosen from a color
board designed by the facility's interior decorator. By standardizing the number of colors of paint
available, paint is not over purchased. Overstock of paint can lead to paint expiration that requires
disposal. Since one paint color has multiple uses throughout the facility, paint that is left over after
one paint order it can be used on another order before it expires. Paint use and labor expenditures are
also minimized by establishing that only one base color of paint be used on the main walls throughout
the facility. By not changing the color of the base wall paint, touch ups require only one coat of paint
instead of the two coats required when paint colors are changed. In addition, the VAMC has switched
from using paint to adhesive vinyl tape for roadway crosswalks. They found the vinyl tape lasts twice as
long as the painted crosswalks.
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Hazardous materials are used primarily by the metal shop, which operates a solvent-based parts cleaning
unit. The part cleaning unit uses a petroleum distillate solvent. The cleaning unit is a sink-top unit
equipped with a spray. Cleaning solvent is held in a 20-gallon drum that contains a 12.5-gallon reservoir
of solvent floating on a small volume of water. Solvent is pumped into the cleaning sink through the
spray gun and drains back to the 20-gallon drum. Inorganics and soil settle out of the solvent into the
water at the bottom of the drum and solvent is reused. Fresh solvent is periodically added to make up for
evaporative losses. Solvent in the reservoir becomes spent and is disposed of off-site about once per
year. See Section 4.3 for detailed information about replacements for the petroleum distillate solvent
unit.
The metal shop also maintains a flammable materials locker that contains several 1-gallon cans of
"Virginia 10 Degreasing Solvent." This solvent is a petroleum distillate that contains aliphatic solvent
naphtha, propylene glycol propyl ether, n-methyl pyrrolidone, and monoethanolamine . Shop personnel
reported that this solvent is used sporadically when small parts such as ball bearings require stringent
cleaning. Maintenance personnel noted that solvent in the parts cleaning unit is sometimes too tainted
with oils and grease to clean these applications effectively. Shop personnel also note that they do not
require a cleaning solvent as stringent as the Virginia 10. However, they primarily use the Virginia 10 so
that their stock will become depleted and they will no longer have to store this hazardous material.
2.3 HAZARDOUS WASTES
Regularly generated hazardous wastes include (1) mercury and mercury-containing devices generated by
the mercury phase-out program (see Section 3.6), (2) nickel/cadmium (NiCad)-containing battery packs
from operating rooms, (3) expired laboratory chemicals, (4) asbestos from abatement activities, (5) lead-
based paint from abatement activities, (6) alcohols, (7) spent gas calibration cylinders, and (8) expired or
unused housekeeping cleaning solvents.
The primary hazardous waste stream managed in the designated storage area is expired chemicals from
the clinical, dental, and research laboratories. This waste stream is generated by periodic laboratory
cleanups, old equipment decommissioning, process or procedure changes, and research laboratory
project shut-downs. A flammable materials locker is located in the storage area to manage flammable
solvents.
Other types of "one-time" hazardous wastes are also common. Examples observed during the
P2 assessment include spray paint from a substance abuse case, absorbent pads saturated with blood and
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disinfectant, chemical bottles that arrived damaged, and expired 35 percent peracetic acid from
over-ordering.
2.4 INFECTIOUS WASTE
Infectious waste is defined by the State of Colorado House Bill Number 1328 as any waste capable of
producing an infectious disease. For a waste to be considered infectious, "it must contain pathogens with
sufficient virulence and quantity so that exposure to the waste by a susceptible host could result in
disease." The Denver VAMC considers infectious waste to be any tissue, organ, or bodily fluid or any
article that has come in contact with them and meets the state definition. Articles may include petri
dishes, pipette tips, protective gloves, or any other objects that may have come in contact with tissue,
organs, or bodily fluids. "Sharps" are also considered infectious waste, but are placed in separate,
designated containers. Sharps include items such as lancets, syringes, and needles. Infectious waste
generated in the Denver VAMC is collected in red bags located throughout the VAMC.
Between October 1996 and July 1997, the Denver VAMC generated about 63.9 tons of infectious waste.
The average monthly generation was 7.1 tons. Disposal costs for infectious waste were significant.
During the aforementioned time period, infectious waste disposal averaged about $4,125 per month. See
Section 4.1 for a detailed discussion of infections waste reduction opportunities.
Driven by the high volume and disposal costs of infectious waste and VAMC staff observations of waste
that may have been managed as infectious waste when it didn't need to be, VAMC is organizing a
committee to address infectious waste minimization. This committee will investigate the types of waste
currently placed in the red bags as infectious waste, how much waste is inappropriately placed in the red
bags, and methods to reduce the amount of waste inappropriately disposed of as infectious waste.
3.0 CURRENT POLLUTION PREVENTION PRACTICES
The P2 assessment identified P2 practices in current use at Denver VAMC. These practices were
documented for the purpose of technology transfer to other hospitals and to recognize VAMC
administration and staff for proactive environmental management. Several of these current P2 practices
are considered widely transferable to other hospitals and have significant benefits; these practices, listed
below, are described in this section. Other P2 practices observed during the assessment are
acknowledged in Section 3.6.
Substitution of Hemo-De for Xylene (Section 3.0)
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Substitution of IBF for B-5 Tissue Fixative (Section 3.2)
Automatic Staining Machine (Section 3.3)
Substitution of Peracetic Acid for Glutaraldehyde (Section 3.4)
Solid Waste Recycling Program (Section 3.5)
The remainder of this section provides, for each of these five P 2 practices, a brief description of: (1) past
and current process operation, waste generation, and costs; and (2) implementation issues. Also listed is
a VAMC point of contact for additional information. Each P2 practice description includes a cost-
benefit comparison for each option, with indirect benefits and concerns related to the old and new
processes. Indirect costs related to these benefits and concerns are not presented because of the
uncertainty in appraising their actual or approximate values. It is important to note, however, that
indirect costs are real costs associated with these benefits and concerns and should not be overlooked.
3.1 SUBSTITUTION OF HEMO-DE FOR XYLENE
Description: The VAMC histology laboratory used xylene in various tissue staining procedures. The
xylene was used for three processes: to allow paraffin to infiltrate specimens, to remove paraffin from
specimens, and to mount a specimen to a slide. Some time before 1986, the histology laboratory
substituted Hemo-De for xylene.
Past Process Operation, Waste Generation, and Costs: Xylene was used as a carrier to allow paraffin
to infiltrate specimens prepared for slide development. The specimen was placed on a tissue processor
and exposed to alcohol, xylene, and paraffin. A slice was cut and placed on a slide. The slide was then
dipped in a series of xylene and alcohol solutions in order to remove the paraffin to view the specimen.
Finally, the slide was dipped in a series of alcohol and xylene solutions in order to mount the specimen to
the slide. Waste xylene was disposed of as a hazardous waste. No data are available regarding xylene
use rate, purchase costs, waste generation rate, or disposal costs.
Current Process Operation, Waste Generation, and Costs: Hemo-De is a direct substitute for xylene
for all three processes described above. Hemo-De contains 98 percent D-Limonene and 0.024 percent
butylated hydroxyanisole and has a flash point of 49 ฐC. The laboratory uses about 15.1 L of Hemo-De
per month. The purchase cost of Hemo-De is S7.88/L. The Hemo-De solution is reused continuously
and new Hemo-De is added to the reservoir as it evaporates and is absorbed by the specimens. When the
slides begin to look cloudy and the process begins to slow (about once every 2 weeks), the spent
Hemo-De solution is poured down the drain with running water. Although no formal SOPs exist for
drain disposal, employees are all directed to flush with "copious amounts of water." This disposal
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practice is acceptable from a regulatory perspective. However, drain disposal is not a desirable practice
from a P2 perspective, which aims fundamentally at source reduction. The generation rate of waste
Hemo-De is about 7.6 L per month.
Implementation Issues: Using Hemo-De instead of xylene did not impair process quality or process
time. Worker health and safety conditions improved because Hemo-De is not a hazardous material.
VAMC Point of Contact: Jeannine Porter, SCT-HTL(ASCP), Supervisor of Anatomic Pathology,
Pathology Department, (303) 399-8020 ext. 2751
TABLE 3-1
VAMC POLLUTION PREVENTION ASSESSMENT SUMMARY:
SUBSTITUTION OF HEMO-DE FOR XYLENE
Before
After
Raw Material
Xylene
Hemo-De
Annual Use
Unknown
181.2 L
Annual Cost
Unknown
$1,428
Waste Generation
Waste Xylene
Waste Hemo-De
Annual Quantity
Unknown
91.2 L
Management
Hazardous Waste
Poured down drain
Disposal Costs
Unknown
None
Indirect Benefits
Worker familiarity
Eliminated potential worker exposure
to xylene
Effective substitute that maintained
process quality
Indirect Concerns
Potential worker exposure to xylene
Requires tracking, proper handling
and disnosa!
None
3.2 SUBSTITUTION OF IBF FOR B-5 TISSUE FIXATIVE
Description: The VAMC histology laboratory processes about 16 lymph node and bone marrow
specimens per month. After a specimen is collected, it is placed in a fixative solution to preserve the
cellular and nuclear components of the specimen for staining and subsequent analysis. Lymph node and
bone marrow specimens are usually placed in a mercuiy-based fixative lcnown as B-5. In April, 1994,
the VAMC histology laboratory replaced B-5 with IBF Tissue Fixative (IBF), a nonmercury-based
fixative.
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Past Process Operation, Waste Generation, and Costs: Specimens were stored in about 15 to 100 mL
of "unactivated" B-5 until the tissue was stained. Unactivated B-5 is a mixture of 12 grams of mercuric
chloride and 2.5 grams of sodium acetate in 200 mL of water. Before tissue staining, about 2 mL of
37 percent formaldehyde was added to "activate" the B-5. After staining, the specimens were dipped in
potassium iodide and sodium thiosulfate solution to remove the mercuric chloride from the specimen.
This procedure was necessary to make the specimens visible under a microscope. About 1,050 mL of
activated B-5 was used per month. The cost to purchase the unactivated B-5 ingredients was about
$160 per year. After specimen analysis, waste specimens were disposed of in designated infectious
waste containers and waste B-5 was placed in a 5-gallon container, which was disposed of off-site as
hazardous waste. The 5-gallon container was filled about every 18 months. Waste B-5 was disposed of
as hazardous waste (D009) due to its mercuric chloride content. The cost to dispose of a 5-gallon
container of mercury waste was $500.
Current Process Operation, Waste Generation, and Costs: EBF is used as a direct substitute for
activated B-5; no process modifications were necessary. About 600 mL of IBF is used per month, less
than activated B-5 because IBF is used only in the histology laboratories. If a specimen is placed in a
fixative outside of the histology laboratory, formaldehyde is used. VAMC may consider replacing IBF
in place of formaldehyde for applications outside of the histology laboratory. The principal components
of IBF are isopropanol (22 percent), formaldehyde (less than 3 percent), and methanol (less than
0.5 percent). Because there is no mercuric chloride in EBF, post-staining application of potassium iodide
and sodium thiosulfate is not required. Waste IBF, a non-hazardous waste is poured down the drain after
use; therefore no disposal costs are incurred. Surgipath Medical Industries, Inc. manufactures IBF. The
unit cost for IBF is $85.05 per 15 L.
Implementation Issues: Using IBF instead of B-5 to preserve specimens did not impair process quality.
Worker health and safety conditions and waste management improved because IBF is a not a hazardous
waste. The primary implementation issue associated with the B-5 substitution involved laboratory staff
acceptance of a new process chemical and concerns about process quality. The issue was resolved
through testing and experience.
VAMC Point of Contact: Jeannine Porter, SCT-HTL(ASCP), Supervisor of Anatomic Pathology,
Pathology Department, (303) 399-8020 ext. 2751
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TABLE 3-2
VAMC POLLUTION PREVENTION ASSESSMENT SUMMARY:
SUBSTITUTION OF IBF FOR B-5
Before
After
Annual Direct
Cost Savings
RAW MATERIAL
B-5
IBF
Annual Use
12.6 liters
7.2 liters
Annual Cost
$ 160 Unactivated ingredients
S22
$138
WASTE GENERATION
Waste B-5
Waste IBF
Annual Quantity
12.6 liters
7.2 liters
Management
Accumulated in a 5-gallon
container; ultimately disposed
of off site as a hazardous waste
(D009)
Poured down drain
Disposal costs
$330 per year + staff time to
track and dispose of waste
None
$330
Total Annual Direct Cost Savings
S468
Indirect Benefits
Worker familiarity
Do not need to precipitate
mercuric chloride
Eliminated worker exposure to
mercury
Reduced worker exposure to
formaldehyde
Indirect Concerns
Mercuric chloride must be
removed from specimens
before analysis
Potential worker exposure to
mercury and formaldehyde
Requires proper tracking,
handling, and disposal
Need for workers to leam new
tissue staining process
3.3 AUTOMATIC STAINING MACHINE
Description: The VAMC histology laboratory used a manual staining procedure for special stains. In
October 1997, the histology laboratory received a Microprobe automatic staining machine manufactured
by Curtis Matheson Scientific (CMS). This equipment reduced staining chemical use from 50 mL to
100 |iL per slide.
Past Process Operation, Waste Generation, and Costs: Different procedures and chemicals are used
for each special stain. In general, however, slides are dipped in a series of solutions in Copeland jars to
stain the cytoplasmic and nuclear components of the specimen. VAMC spent about $2,275 plus shipping
and handling per year to purchase staining chemicals. Common special stains, the chemicals used to
process the stain, annual chemical use for manual staining quantities, and disposal methods are shown in
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Table 3-3. Disposal of the staining solutions varied. Some chemicals were reusable, some were poured
down the drain, and five of the chemicals - methamine silver, silver nitrate, borax, potassium hydroxide,
and ammonium hydroxide, were collected and disposed of as hazardous waste. Disposal of these
hazardous wastes cost approximately $240 per year.
Current Process Operation, Waste Generation, and Costs: The laboratory began using the automatic
staining machine in November 1997. Chemicals for the automatic staining machine are supplied as a
reagent kit. Reagent kits may be used with the automatic staining machine in place of certain special
stains. The procedure implemented by the automatic staining machine depends on the stain. Generally,
specimens are placed on a slide and dipped in the reagent. Capillary action draws the reagent into the
specimen. The slide is then incubated for several minutes by heating to 60"C; after incubation, the slide
is removed and is dabbed on an absorbent pad to remove the reagent. This process is repeated with
different reagents as many times as necessary to stain the slide. The machine is provided at no cost by
the company that supplies reagents to VAMC. The total cost to purchase all reagent kits is $2,063 per
year. Kits are purchased on an as needed basis and have a shelf life of about 2 years. Each reagent kit
contains a predetermined set of various reagents in volumes proportional to the amount required for each
staining procedure. Thus, the volumes of reagents become depleted at the same rate so there are no
excess reagents left. The only waste disposed from this process is an absorbent pad, which contains trace
amounts of silver nitrate and picric acid. A VAMC contractor calculated the amount of hazardous
chemicals in the pads and determined that they are considered nonhazardous and may be disposed of as
general refuse. The chemical savings are estimated at $212 per year. According to VAMC personnel,
the technician time savings are estimated at nearly $27,000 per year. Disposal cost savings are estimated
at approximately $240 per year.
Implementation Issues: Using the automatic staining machine instead of manual staining procedures to
stain specimens did not impair process quality. Process time was reduced because staining solutions do
not have to be mixed and the automatic staining machine stains more quickly because of a heating unit
that increases reaction time. Worker health and safety conditions improved because exposure to staining
chemicals was eliminated. New procedures and worker training were required to use the machine. For
example, the stains no longer have to be prepared, the slides do not have to be dipped in each of the
solutions, technicians need to adapt to the new technology, and specimens have to be placed on the
bottom third of the slide for use in the automatic staining machine.
VAMC Point of Contact: Jeannine Porter, SCT-HTL(ASCP), Supervisor of Anatomic Pathology,
Pathology Department, (303) 399-8020 ext. 2751
12
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TABLE 3-3
VAMC POLLUTION PREVENTION ASSESSMENT
SPECIAL STAINS REPLACED BY AUTOMATIC STAINING MACHINE
Stain
Ingredients
Annual Use
Disposal Practice
PAS
periodic acid
2,500 mL
reuse
hydrochloric acid
410 mL
reuse
sodium bisulfite
20 g
reuse
light green
0.4 g
reuse
Iron
potassium ferrocyanide
100 g
sink dram, diluted
nuclear fast red
1 g
reuse
Muci-carmme
metanil yellow
2.5 g
reuse
carmine
10g
drain
aluminum chloride
84 g
dram
Elastic
ferric chloride
20 g
sink drain
potassium iodide
4g
sink dram
iodme
2g
sink drain
sodium thiosulfate
10 g
sink drain
GMS
methamine silver
8.6 L
hazardous waste
silver nitrate
4,320 mL
hazardous waste
chromic acid
150 g
reuse
borax
432 mL
sink drain
Retic
silver nitrate
50 g
hazardous waste
potassium hydroxide
50 g
sink drain
ammonium hydroxide
10 drops
sink drain, diluted
Trichrime
biebrich scarlet
10g
reuse
acid fuchsin
10g
reuse
glacial acetic acid
10 mL
reuse
phosphmolybdic acid
1,120 g
sink drain
phosphotungstic acid
1,120 g
sink drain
aniline blue
20 g
reuse
bouins
100 g
reuse
Alcian Blue
glacial acetic acid
30 mL
reuse
alcian blue
10 g
reuse
thymol
12 crystals
reuse
AFB
carbol fuchsin
620 mL
reuse
hydrochloric acid
1,240 mL
sink drain
methylene blue
14 g
reuse
13
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TABLE 3-4
VAMC POLLUTION PREVENTION ASSESSMENT SUMMARY:
AUTOMATIC STAINING MACHINE
Before
After
Annual Direct
Cost Savings
Procedure
Manual staining
Automatic staining machine
Annual Chemical Use
See Table 3-3 (50 mU
slide)
19 kits (mL/slide)
Annual Chemical Cost
$2,275 plus shipping and
handling
$2,063
$212
Waste Generation
Miscellaneous staining
chemical solutions
Waste absorbent pads
Annual Quantity
5 g of silver nitrate in
4,320 mL of liquid
solution and 200 mL of
picric acid
1 pad every 3 months
(estimated)
Management
Hazardous Waste
General Refuse
Disposal costs
$240
Negligible
$240
Total Annual Direct Cost Savings
$452
Indirect Benefits
Worker procedure
familiarity
Shorter process time
Decrease potential for
worker exposure
No bulk chemical storage
Reduced staff time for
managing and ordering
chemicals
Reduced staff time to
track and dispose of
hazardous waste
Reduced staff time to
prepare and stain slides
Indirect Concerns
Longer process time
Potential for worker
exposure
Bulk chemical storage
with potential for waste
due to expired
chemicals
Increased staff time for
managing and ordering
chemicals, disposing of
hazardous waste
Increased staff time to
prepare and stain slides
Staff must learn new
technology
14
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3.4
SUBSTITUTION OF PERACETIC ACID FOR GLUTARALDEHYDE
Description: The Denver VAMC Respiratory Therapy department formerly used glutaraldehyde (trade
name CIDE-X) to clean respiratory therapy equipment. In September 1995, glutaraldehyde was replaced
with a machine using peracetic acid (trade name Steris). Reasons for pursuing a glutaraldehyde
substitute include the following: (1) glutaraldehyde has a bad odor and workers can become sensitized to
it, (2) the glutaraldehyde solution had to be changed every 2 weeks, (3) glutaraldehyde residue on the
respiratory therapy equipment created an unpleasant taste on mouth pieces.
Past Process Operation, Waste Generation, and Costs: Respiratory therapy equipment was frcst
soaked in an enzymatic cleaner and rinsed in water. After rinsing, the equipment was immersed in
glutaraldehyde for 20 minutes at a temperature of 24ฐC. The equipment was then rinsed with
0.25 percent acetic acid and sterile water, and finally placed in a drier. The entire process lasted
45 minutes. At the end of the process, the equipment was considered clean, but not sterile. Ten gallons
of glutaraldehyde were used per month at a cost of $56 to $ 135 per month, depending on how the
glutaraldehyde was purchased. Ten gallons of waste glutaraldehyde was generated per month and was
disposed of down the drain followed by 5 minutes of running water. This disposal practice is acceptable
from a regulatory perspective. However, drain disposal is not a desirable practice from a P2 perspective,
which aims fundamentally at source reduction. One respiratory therapy employee was monitored to
measure exposure. The cost to monitor the employee was S35 per year. Eventually, the equipment
would acquire a bad taste and would require replacement.
Current Process Operation, Waste Generation, and Costs: Respiratory therapy equipment is first
soaked in an enzymatic cleaner and rinsed in water. After rinsing, the equipment is inserted into a
peracetic acid-based system (the Steris machine) that requires a 12-minute exposure time at a
temperature of 49ฐC. Each time the Steris machine is used, a box (0.24 L) of 35 percent peracetic acid in
powder form is placed in the Steris machine. The sterilization cycle uses about 50 L of water. The
equipment is air dried after sterilization. The process requires about 20 to 30 minutes. At the end of the
process, the equipment is considered sterile. Peracetic acid leaves no unpleasant taste on the equipment.
The waste peracetic acid solution is discharged directly to the sewer with other VAMC wastewater. The
Steris machine is operated about 20 times per month. One case (4.71 L) of peracetic acid is used per
month at a cost of $99 per case. There is no cost for disposal. The cost to purchase the Steris machine
was approximately $16,000.
Implementation Issues: The process quality improved after glutaraldehyde substitution because no
residual taste remains on the equipment. In addition, process time decreased by about 50 percent. The
Steris system also eliminated both worker exposure to glutaraldehyde and the concomitant exposure
monitoring. Finally, implementation of the Steris system also eliminated use of dilute acetic acid, which
was formerly used as a final rinse. There were no implementation issues other than worker training.
15
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VAMC Point of Contact: Betty Jarvis, Home Respiratory Care Coordinator, Respiratory Care Section
of VAMC, (303) 399-8020 ext. 3125
TABLE 3-5
VAMC POLLUTION PREVENTION ASSESSMENT SUMMARY:
SUBSTITUTION OF PERACETIC ACID FOR GLUTARALDEHYDE
Before
After
Annual Direct
Cost Savings
Raw Material
Glutaraldehyde
Peracetic acid
Annual Use
454 liters
12 cases (57 liters)
Annual Cost
$672 to $1,620
$1,188
S<516>to S432
Waste Generation
Waste glutaraldehyde
Waste peracetic acid solution
Annual Quantity
454 liters
12,000 liters
Management
Poured down the drain followed
by running water for 5 minutes
Discharged directly to drain
Disposal costs .^ione
None
$0
Total Annual Direct Cost Savings
S<516>to $432
Indirect Benefits
No capital equipment/
maintenance costs
Workers do not become
sensitized to odor
Workers do not need to be
monitored
25-minute process time
Does not leave bad taste on
equipment
Sterilizes equipment
Requires less frequent
equipment replacement
Indirect Concerns
Workers become sensitized to
odor
Workers must be monitored
45-minute process time
Leaves bad taste on
equipment
Cleans equipment
Frequent respiratory therapy
equipment replacement due
to glutaraldehyde taste and
wear on equipment (6
mouthpieces per year at $3.00
per mouthpeice)
Requires workers to properly
flush when disposing of
glutaraldehyde down the
drain
Initial investment is high -
Steris machine costs $16,000
Less frequent respiratory
therapy equipment replacement
from wear on equipment
(3 mouthpieces per year)
16
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3.5 SOLID WASTE RECYCLING PROGRAM
Description: In 1991, a VAMC committee implemented a volunteer solid waste recycling program.
Past Process Operation, Waste Generation, and Costs: Before 1991, no recycling programs were in
place at the VAMC. All solid waste was disposed of as general refuse in a landfill. The cost for disposal
of general refuse was $220 per dumpster (40 yd3). Annual expenditures prior to 1991 for general refuse
were unavailable during this assessment.
Current Process Operation, Waste Generation, and Costs: A recycling program was started in 1991
by an ad hoc committee of six VAMC employees. The items and quantities listed in the table below are
recycled at VAMC.
TABLE 3-6
DENVER VAMC RECYCLED MATERIALS
Recycle Waste
Annual Quantity
Recycled (1996)
Recycling Firm
Office paper
114 tons
Waste Management of Colorado, Denver, CO
Cardboard
50 tons
Waste Management of Colorado, Denver, CO
Aluminum cans
26 tons
VAMC volunteers
Newspaper
300 cubic yards
Tri R Systems, Denver, Colorado
Printer ribbons
1,600 printer ribbons
Unknown at this time
Fluorescent lamps
4,000 fluorescent lamps
Environmental Information Service, Inc.
Arvada, CO
Cooking oil
2.6 tons
Unknown at this time
Wooden pallets
900 wooden pallets
Ace Kauffman, Denver, CO
Rubber stamps
100 rubber stamps
Unknown at this time
Plastic bottles
7,500 plastic bottles
Sierra Club, Denver, CO
NiCad batteries
150 NiCad batteries
Rocky Mountain Battery Service, Inc.,
Wheatridge, CO
Telephone books
600 telephone books
Waste Management of Colorado, Denver, CO
Photographic silver
70 pounds
Federal collection program
Steel cans
2,500 steel cans
VAMC volunteers
17
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According to the Recycling Program Coordinator, a volunteer, the program saves VAMC $35,000 per
year in disposal costs and operates on a budget of $4,000 per year. All items are recycled locally. Only
two types of recyclables, fluorescent lamps and NiCad batteries, cost VAMC money to recycle.
However, these wastes would otherwise be disposed of as hazardous waste, which is costly and a less
desirable option. The program won the 1996 Hammer Award and 199" Closing the Circle Award from
the White House. A copy of the 1996 Closing the Circle Award nomination is in Appendix 2. Future
plans for the recycling program include glass and increased plastic recycling.
In addition to recycling, VAMC also purchases recycled material such as copy paper, toner cartridges,
pens, toilet paper, and tissue paper.
Implementation Issues: One person was hired to bale the cardboard; this salary is essentially paid for
by the money received for the cardboard recycling and money saved from reduced trash compactor
waste. The money from the cardboard recycling is paid to the Directors Office and the Directors Office
pays the person to bale. Because of recycling, $400 per week is saved by the reduction in waste added to
the trash compactor. Janitorial staff are required to do extra work to collect separated recyclable
materials. There was an initial cost of $10,000 to rent the baler for one year and purchase recycling
containers. The program operates on a budget of $4,000 per year. This money is used to pay for
fluorescent lamp and NiCad battery recycling and baler rental. The baler rental fee includes maintenance
costs. The initial and annual costs of the recycling program are paid by the VAMC Director's Office.
Several VAMC employees have volunteered their time to keep the program running. Barriers to growth
of the program include lack of outdoor storage area and limited pickup of certain items. For example,
certain glass and plastic items are not recycled because the City of Denver recycling service is not
available to federal facilities. VAMC does not have space to store the recyclables until they are taken to
a recycling service.
VAMC Point of Contact: Dr. Amie Schultz, Recycling Task Force Co-Chair, Clinical Chemistry
Laboratory, (303) 399-8020 ext. 2625
3.6 OTHER POLLUTION PREVENTION PRACTICES
The P2 assessment team observed several other on going P2 practices or initiatives at VAMC that
demonstrate commitment to P2. These include:
A program to replace mercury-containing medical devices, such as thermometers and
manometers, with nonmercury-containing replacements through attrition. For the most
part, this program has been completed. Occasionally mercury-containing devices are
18
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still found and are replaced immediately. Additional details regarding this program are
unknown because the program was initiated by personnel who are no longer employed at
VAMC.
The clinical laboratory reuses spent methanol from its staining machine to clean slide
holders.
The reverse osmosis membranes in kidney dialysis machines are cleaned with a
hydrogen peroxide and peracetic acid mixture instead of formaldehyde. This minimizes
chemical exposure risk to employees.
Compared to other Federal facilities in the Denver metro area, a large number
(55 participants) of VAMC employees participated in the 1997 Bike to Work Day, a
program to reduce pollution associated with commuting. To promote bicycle use,
bicycle racks are located at main building entrances.
Research laboratories have reusable pipette tip stands. In most VAMC research
laboratories, pipette tips stands are cleaned and reused rather than being disposed of after
one use.
The paint shop uses only latex paint and has reduced its painting requirements. The
Medical Center has been painted with a standardized, limited set of paint colors. Paint
colors can be chosen from a color board designed by the facility's interior decorator. By
standardizing the number of colors of paint available, paint is not over purchased.
Overstock of paint can lead to paint expiration that requires disposal. Since one paint
color has multiple uses throughout the facility, paint that is left over after one paint order
it can be used on another order before it expires. Paint use and labor expenditures are
also minimized by establishing that only one base color of paint be used on the main
walls throughout the facility. By not changing the color of the base wall paint, touch ups
require only one coat of paint instead of the two coats required when paint colors are
changed.
The VAMC has switched from using paint to adhesive vinyl tape for roadway
crosswalks. They found the vinyl tape lasts twice as long as the painted crosswalks.
4.0 RECOMMENDED POLLUTION PREVENTION PROJECTS
This section analyzes three recommended P2 projects based on the site visits to VAMC. The P2 projects
presented in this section received a detailed feasibility analysis which evaluated the project's impact on
the use and generation of hazardous substances and its ability to reduce costs and environmental impacts
and improve worker health and safety. Each of the analyses is presented in a slightly different format
due to the inherent differences in the types of wastes and P2 opportunities associated with them.
Only the direct costs and savings have been provided. Indirect costs and savings related to these benefits
and concerns are not presented because of the uncertainty in appraising the actual or approximate values
of these costs. It is important to note, however, that indirect costs are real costs associated with these
19
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benefits and concerns and should be considered when evaluating the pros and cons of the proposed
P2 opportunity.
P2 opportunities discussed in Section 5.0 did not appear to offer a lucrative pay back period at the time
of this assessment and therefore were not presented in the same level of detail as P2 options presented in
Section 4.0. Technical availability, financial conditions and VAMC operating practices may change over
time. The VAMC should consider periodically evaluating each option presented in Section 5.0 against
feasibility criteria such as potential waste reduction, cost savings, risk reduction, and improved quality to
determine if conditions have become more favorable for implementation.
4.1 INFECTIOUS WASTE REDUCTION
Infectious waste is generated in various areas throughout the VAMC complex. These areas include
patient ward, operating rooms, clinical laboratories, research laboratories, and the morgue. Infectious
waste is collected in red bags and sent off site for incineration and disposal. VAMC generates about
85 tons of infectious waste per year at a treatment and disposal cost of $49,500. At the time of the
September 1997 P2 assessment, VAMC was in the initial stages of establishing a committee to address
infectious waste reduction. Creating such a committee is an important first step to developing a
successful infectious waste reduction program. This section describes observations on infectious waste
generation at VAMC, outlines an approach to developing an infectious waste reduction program,
presents successful infectious waste reduction activities, and estimates cost savings from potential
infectious waste reductions.
4.1.1 Infectious Waste Generation at VAMC
The Denver VAMC must adhere to waste definitions and protocols included in various state and federal
statutes, regulations, and guidelines including:
Medical Waste Tracking Act of 1988
Centers for Disease Control (CDC) and Occupational Safety and Health Administration
universal precautions for bloodbome pathogens
State of Colorado House Bill 89-1328, which is based on EPA's 1986 "Guide for
Infectious Waste Management"
20
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Infectious waste is defined as "waste capable of producing an infectious disease." For a waste to be
classified as infectious, it must contain a pathogen of sufficient virulence, dose, portal of entry and
resistance of the host to induce a disease. Categories of waste that meet such criteria include:
Isolation wastes from persons diagnosed as having a disease caused by an organism
requiring CDC biosafety level IV containment
Cultures and stocks of infectious agents and associated biologicals
Human blood, blood products, and body fluids
Human pathological and anatomical wastes
Contaminated sharp instruments ("sharps")
Contaminated laboratory and research wastes including contaminated animal carcasses,
body parts, and bedding
Under current regulations, it is not always easy to determine what constitutes infectious waste. In order
to promote worker safety, adhere to stringent regulations, minimize liability, and maintain a positive
public image with regard to infectious waste management, VAMC, like many health care organizations,
may be conservative in identifying its infectious waste. According to the Minnesota Hospital
Association Public Affairs Division, some hospitals routinely dispose of 30 to 45 percent of their total
waste stream as "red bag," or infectious waste. An article from the April 1990 Pollution Engineering,
"Hospital Waste Management," estimated that 85 percent of the overall hospital waste stream can be
categorized as general refuse, while the remaining 15 percent can be categorized as infectious waste.
These estimates suggest that a 50 to 67 percent infectious waste reduction is possible. The percent of
VAMC's total waste stream attributed to infectious waste could not be determined from the information
collected during the P2 assessment.
During the VAMC P2 assessment, visual inspections and staff interviews were conducted to gauge the
potential for infectious waste reduction. During visual inspection of red bag containers, the assessment
team noted the presence of product packaging and disposable containers apparently un-associated with
infectious waste. However, visual inspection alone is inadequate to determine if a waste item is
classified as infectious. The placement of questionable waste items in infectious waste containers should
be considered on a case-by-case basis. The history of each waste item's exposure to potential pathogens
should be tracked to determine the appropriate waste category (infectious or solid) for the item. A
comprehensive audit of this nature was not conducted under the scope of this P2 assessment.
21
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Interviews with VAMC laboratory and research staff suggest that the definition of infectious waste and
how it applies to wastes generated from their department is not always clear. Consequently, wastes of
"uncertain status" are often conservatively disposed of as infectious waste. For example, one laboratory
considers items such as protective gloves to be infectious waste (even if the gloves had not come into
contact with potential infectious sources) in order to minimize questions during regulatory inspections.
VAMC departments that generate infectious waste are not responsible for paying for infectious waste
management costs from their separate operating budgets. Instead, waste management costs are covered
by a facility-wide, waste management budget. This practice reduces departmental incentives for waste
reduction because each department is not accountable for its waste management costs. Moreover,
VAMC does not track infectious waste generation and associated costs for each department source.
Without a tracking system m place, the department or processes with the largest potential for infectious
waste reduction is difficult to identify.
VAMC should establish a comprehensive infectious waste reduction program to (1) determine the areas
and sources with the greatest potential or cost incentive for reduction and (2) identify and implement
P2 opportunities to reduce infectious waste generation. The following section provides an approach for
implementing such a program.
4.1.2 Establishing an Infectious Waste Reduction Program at VAMC
An infectious waste reduction program should be established to create an environment that is conducive
to identifying and successfully implementing P2 opportunities. There is no one solution to reduce
infectious waste generation at VAMC because infectious waste is generated by hundreds of different
operations and activities within several different departments. Infectious waste reduction must be
pursued in a programmatic manner that involves worker training and focused source reduction efforts on
high-volume sources of infectious waste. A variety of P2 approaches should be explored. P2 approaches
involve material substitution, equipment changes, process modifications, material handling
improvements, and waste segregation.
The infectious waste reduction program at VAMC should include the following components:
An infectious waste reduction committee (this component has already been initiated at
VAMC)
22
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An infectious waste generation tracking system
An employee training program
Periodic assessments of infectious waste generating activities to identify source
reduction opportunities
A review panel whose purpose is to (1) review infectious waste reduction opportunities
with respect to regulatory compliance, health and safety, payback period, and quality and
(2) ensure that feasible opportunities are implemented.
The infectious waste reduction committee should establish a specific approach and timeline for
implementing the infectious waste reduction program. The committee should include representatives
from each department that generates infectious waste, as well as staff from nursing, environmental
services, purchasing, risk management, and senior management.
Before infectious waste reduction opportunities are implemented, a baseline of infectious waste
generation should be established. Then, as infectious waste opportunities are put into place, the resulting
waste reduction should be tracked to assess the percent infectious waste reduction. This infectious waste
tracking system can also be used to determine which areas of VAMC have the largest potential for
infectious waste reduction and the specific processes that generate infectious waste.
One approach to establishing a tracking system would be to (1) assign each infectious waste collection
receptacle a number and note which department contributes to it; (2) conduct a 1-week infectious waste
survey, recording the weight, not volume, of red bag waste collected from each receptacle; (3) on a
periodic basis (for example, every 3 months), repeat the 1-week survey to track changes in generation
rates. Environmental service or housekeeping staff that collect infectious waste on a daily basis would
be good candidates for this task. During the survey, the staff should use a scale to weigh each red bag
and a log to record data after each receptacle is picked up.
The distribution of infectious waste according to various categories (for example, product packaging,
disposable equipment, absorbent pads, petri dishes, protective gloves, and sharps) is also important
information to collect in the infectious waste survey. Each department that generates infectious waste
should list the types of materials that are placed into the corresponding red bag receptacles. This task
should be conducted by department members since they are most familiar with the composition of their
red bag waste.
23
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Waste types can be recorded in a quantitative or qualitative manner. To collect quantitative information,
VAMC staff, in appropriate protective gear, should sort through the waste, and separate, weigh, and
record each waste category. To collect qualitative information VAMC staff should record waste
component types using visual observation. However, since the waste types are not weighed, statistics
will not be available to determine the percent, by weight, of each waste type in the red bag. For both
qualitative and quantitative data collection methods, VAMC department personnel should record tasks
generating each infectious waste type and the reason the material was considered an infectious waste.
Infectious waste characterization is an essential first step toward identifying and implementing source
reduction techniques.
All staff involved in activities that generate infectious waste should receive training that clarifies the
regulatory definitions of infectious waste and how the definitions apply to wastes generated in their
department. In addition, existing policies and SOPs should be reevaluated. If a policy or SOP is more
stringent than the regulations, the basis for its stringency should be determined and the impact of overly
conservative approaches on infectious waste quantities should be evaluated. Staff should be encouraged
to identify source reduction opportunities and optimize segregation of non-infectious waste from
infectious waste.
There are several benefits that result when segregation and source reduction methods are applied to
processes that generate infectious waste. The environmental benefit of separating infectious waste and
non-infectious waste derives from less waste that requires energy-intensive incineration for treatment. In
addition, by reducing the quantity of non-infectious waste disposed of as infectious waste, release of
hazardous constituents (for example, heavy metals) through incinerator emissions or ash can also be
reduced. The cost benefit is associated with reduced treatment and disposal costs.
However, if segregation is implemented without source reduction, the total volume of waste (including
infectious waste, solid waste and recyclables) generated by VAMC will not be reduced. In other words,
segregation prevents solid waste and recyclables from becoming infectious waste but does not reduce the
overall waste stream. The reduction in infectious waste is countered by a similar gain in solid waste and
recyclables generated.
Source reduction, unlike segregation, reduces the overall volume of waste generated. Source reduction
examples that minimize infectious waste generation include:
Switching from disposable infectious waste containers to reusable containers
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Switching to a reusable sharps collection system
Switching to reusable surgery masks, gowns, caps, and drapes
Purchasing products that come in reduced amounts of packaging
Improving staff training and equipment quality to prevent mistakes that involve
repeating procedures that generate infectious waste
Source reduction results in benefits similar to those achieved from waste segregation, including reduced
treatment and disposal costs, energy conservation from reduced infectious waste requiring treatment, and
reduced incineration emissions. Additionally, source reduction decreases costs associated with
purchasing disposable products such as waste containers, surgery garments, and surgery drapes.
When an infectious waste reduction opportunity is identified, the VAMC infectious waste reduction
committee should evaluate the feasibility of the P2 opportunity, comparing it against criteria for
regulatory compliance, health and safety, payback period, and quality.
Finally, each step toward infectious waste reduction should be considered in a prudent manner, to avoid
liability associated with potential infectious waste mismanagement. Program successes help promote
additional accomplishments and imbue the program with the momentum necessary to achieve its goals.
In turn, one violation of infectious waste regulations can create program inertia that is difficult to
overcome.
4.1.3 Successful Infectious Waste Reduction
The following are four examples of infectious waste reduction from the "Waste Not Boole" by the
Minnesota Hospital Associations Public Affairs Division and three examples from the Beth Israel
Medical Center Complex:
Proper segregation helped the Minneapolis VAMC reduce infectious waste by 50 percent
over a 6-month period. Through efforts of the environmental management services
working in concert with surgery services and the operating room nurses, two regular
waste containers and one red bag container were placed in each surgical unit, rather that
two red bag containers and one regular container. All wrappings prior to surgery are
automatically deposited into the municipal solid waste container. In addition, the
hospital previously had red bagged all waste after the incision was made. Now the
nurses consider placement of each item before disposing. All glass and plastic from the
operating room is recycled. The volume of infectious waste has been reduced from
32,000 to 17,000 pounds per month. (Contact - Evan Smith, Assistant Chief, VAMC,
Minneapolis).
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Reusable infectious waste containers replaced disposable containers at Community
Hospital in Cannon Falls and Methodist Hospital in St. Louis Park, among others. In
addition, many hospitals now use reusable sharps containers. (Contact - Judy Paprock
Brenner, Public Relations, Methodist Hospital, St Louis Park)
Reusable surgical gowns replaced disposable gowns in many hospitals, including Weiner
Memorial Medical Center in Marshall, Minnesota. Weiner Memorial is projecting a
savings between $1.50 to $2.00 per use.
St. Joseph's Medical Center in Brainerd, Minnesota, switched to reusable isolation
gowns. The hospital eliminated purchases of 1,500 gowns each year. In Coon Rapids,
Minnesota, Health One Mercy Hospital found that it costs $0.87 for a disposable
isolation gown compared to $0.20 per use for a reusable gown.
At the Beth Israel Medical Center in Manhattan, New York, red bag waste has been
reduced by at least 1 million pounds per year, and associated waste hauling fees reduced
by more than $600,000 per year through improved segregation, reuse, and recycling, and
changing the types of products purchased and work practices.
Beth Israel's North Division saved $175,000 per year in red bag waste disposal through
improved segregation, reuse, and product and process changes. Switching to reusable
sharps containers and improved recycling also contributed to the cost savings. (Contact ฆ
Janet Brown, Waste Manager, Beth Israel Medical Center, (212) 420-2442 or jbrown@
bethisraelny.org)
The Beth Israel's Kings Highway Division implemented an improved waste
management program in August of 1996. As a result, the waste budget of $300,000 per
year was cut in half. The program included reducing red bag waste by two thirds
through improved segregation effort by staff members, renegotiating an overpriced
waste contract, switching to a reusable sharps collection system, and implementing
office paper recycling. (Contact - Janet Brown, Waste Manager, Beth Israel Medical
Center, (212) 420-2442 or jbrown@ bethisraelny.org)
4.1.4 Potential Cost Savings from Infectious Waste Reduction
The percentage of direct cost savings that can be realized from reducing infectious waste generation is
proportional to the percentage of infectious waste reduction achieved. VAMC generates about 85 tons of
infectious waste per year at a treatment and disposal cost of $49,500. According to estimates presented
in Section 4.1.1, it may be feasible for VAMC to realize an infectious waste reduction of up to 50 to
67 percent, which equates to a potential direct cost savings of up to about $33,000. Direct cost savings
from reduced treatment and disposal will be offset by the administrative cost to implement the infectious
waste reduction program. Table 4-1 presents the direct cost savings associated with various percent
reductions in infectious waste amounts.
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TABLE 4-1
ANTICIPATED COST SAVINGS AND WASTE REDUCTION BY PERCENT
Infectious Waste
Reduction (%)1
Annual
Infectious Waste
Reduction (tons)
Annual Cost
Savings2
Annual Infectious
Waste Generation
(tons)
Annual Costs1
0
0.0
$0
85.2
$49,503
5
4.3
$2,475
81.0
$47,028
10
8.5
$4,950
76.7
$44,552
15
12.8
$7,425
72.5
$42,077
20
17.0
$9,901
68.2
$39,602
25
21.3
$12,376
63.9
$37,127
30
25.6
$14,851
59.7
$34,652
35
29.8
$17,326
55.4
$32,177
40
34.1
$19,801
51.1
$29,702
45
38.4
$22,276
46.9
$27,226
50
42.6
$24,751
42.6
$24,751
55
46.9
$27,226
38.4
$22,276
60
51.1
$29,702
34.1
$19,801
65
55.4
$32,177
29.8
$17,326
67
57.1
$33,167
28.1
$16,336
Notes:
1 For illustrative purposes, this table assumes that VAMC is disposing of 45% of their total waste stream as red bag waste
and that only IS percent of the total waste stream is actually considered infectious waste. These numbers could not be
verified during the VAMC P2 assessment since a comprehensive infectious waste survey was not conducted.
2 Costs include those associated with offsite treatment and disposal, but exclude labor costs to collect red bags inside the
VAMC complex. The average cost per ion (SSSl/ton) was determined using invoices for infectious waste treatment and
disposal from the 1997 fiscal year at VAMC.
4.2 FORMALIN REPLACEMENT
The VAMC histology laboratory and morgue use formalin as a tissue and organ sample fixative.
Formalin is a semi-aqueous solution containing 37 to 40 percent formaldehyde and about 10 percent
methanol. Formalin is a preferred fixative because it destroys bacteria, fungi, molds, and yeast; has a
long history of use; and maintains a natural pink color in the specimens. Formalin is particularly
important as a brain fixative because it not only preserves it from decay, but it also causes the brain
tissue to become firmer, thus more manageable without causing deformation.
27
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Formalin is considered a hazardous material because of its formaldehyde and methanol content. Workers
using formalin must be monitored for formaldehyde exposure. Formalin is highly irritating to the upper
respiratory tract and eyes. Further, prolonged or repeated exposure may result in respiratory impairment.
It is also a severe skin irritant and a sensitizer. The perception of formaldehyde by odor and eye
irritation becomes less sensitive with time as one adapts to formaldehyde. This can lead to overexposure
if a worker is relying on formaldehyde's warning properties to alert him or her to the potential for
exposure. A person sensitized to formaldehyde is often required to change job functions to eliminate
further formaldehyde exposure. In a study cited by the Occupational Heath and Safety Administration's
preamble to the Formaldehyde Standard, 79 percent of histotechnologists suffered from formaldehyde-
related respiratory symptoms, dermatitis, or both. Formaldehyde has the potential to cause cancer in
humans. Repeated and prolonged exposure increases the risk. In humans, formaldehyde exposure has
been associated with cancers of the lung, nasopharynx and oropharynx, and nasal passages. Therefore,
due to these health and safety issues, formalin replacement is a high P2 priority. Further, VA P2
Strategy directs VA facilities to reduce toxic or hazardous substances. The VA P2 strategy is included in
Appendix 3. This section describes formalin use and disposal at VAMC, presents three less toxic
formalin replacements, outlines an approach to an on-site formalin replacement feasibility study, and
compares the costs of formalin and formalin replacements.
4.2.1 Formalin Use and Disposal at VAMC
The histology laboratory and morgue use about 100 L of formalin per month for tissue and organ sample
preservation. Tissue samples are stored in 15 to 180 mL biopsy containers prepackaged with a
10 percent formalin solution. Organ samples are stored in closed 5-gallon buckets that contain 1 to
2 gallons of 10 percent formalin solution. Samples are typically stored on site for about 6 months.
When tissue and organ samples are disposed of at VAMC, waste formalin is flushed down the drain with
running water. This disposal practice is acceptable from a regulatory perspective because the waste
formalin does not exhibit hazardous waste characteristics and the Denver Metro does not prohibit waste
formalin in the sanitary sewer system. However, drain disposal is not a desirable practice from a
P2 perspective, which aims fundamentally at source reduction. Laboratory personnel estimated the
waste formalin generation rate is 18.25 L per month from tissue samples and 57 to 114 L from organ
samples every 3 months.
4.2.2 Replacement Options
Three less toxic formalin replacements are commercially available and promoted as direct replacements
for formalin; these replacements are listed in Table 4-2.
28
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TABLE 4-2
VAMC POLLUTION PREVENTION ASSESSMENT
FORMALIN REPLACEMENTS
Product Name
Manufacturer
Description
Prefer
Anatech Ltd.
1-800-ANATECH
glyoxal (two-carbon di-aldehyde) in a solution
of ethanol, water, and non-toxic buffer
OmniFix 2000
Aaron Medical Industries, Inc.
1-800-537-2790
solution of alcohols and water with non-toxic
buffer
SafeFix II
Biochemical Sciences, Inc.
1-800-524-0294
non-toxic aldehydic compound with alcohol
Formalin replacement manufacturers have tested the products using a variety of methods to compare the
performance to formalin. For example, Biochemical Sciences, Inc. used Safe Fix II in several
hematoxylin and eosin (H&E) and special stains and compared the results to those obtained using
formalin. Similarly, large organs were placed in SafeFix II to compare its fixing ability to formalin.
Anatech Ltd. set up a series of two clinical laboratory experiments. The first involved sending 10 tissue
samples to 12 pathologists at 10 to 12 hospitals. The samples were labeled control (formalin fixed) or
experiment {Prefer fixed). Portions of the same tissue were placed in each of the fixatives and the
facilities were asked to stain the samples in any manner they preferred and rate the experimental versus
control fixed tissues. The second stage of the clinical trial was to send samples of the replacement to
technicians at six facilities and ask for responses related to the performance of the formalin replacement.
Each of the experiments yielded positive results about the formalin replacements. In general, formalin
replacements perform as well as formalin with respect to preventing the growth of bacteria, fungi, molds,
and yeast. However, the natural pink color of the specimens is not maintained as well with formalin.
This appears to be a cultural barrier and not a quality issue. According to various studies, visual clarity
of the tissues fixed with formalin replacements can be comparable to formalin fixed tissues. Tissues
fixed with formalin replacements do not tend to be as firm as tissues fixed with formalin. VAMC should
evaluate the formalin replacements to determine if they meet their tissue firmness requirements.
Using formalin replacements sometimes requires changes in laboratory procedures. A common
difference experienced using formalin replacements is tissues stain too dark to view. This difference is
easily corrected by modifying staining procedures to decrease the staining time when using a formalin
replacement.
In 1997, VAMC histology laboratory personnel informally evaluated the effectiveness of SafeFix (the
predecessor of SafeFix II) as a formalin replacement using free samples obtained from the manufacturer.
During this informal evaluation, tissue samples were randomly placed in SafeFix without informing
pathology staff of the substitution. About 6 months after SafeFix was introduced, the pathology staff
were informed of the substitution and told which samples were preserved in formalin and SafeFix. No
29
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complaints regarding sample quality were received until 1 month after the pathology staff was informed
of the substitution. The complaint concerned difficulty in viewing nuclear characteristics of a melanoma
specimen fixed in the formalin replacement. According to VAMC personnel, this complaint was not
related to the length of staining time. After receiving this complaint, the histology laboratory stopped
using SafeFix. Because there were few complaints about SafeFtx and because the single complaint
pertained to specific specimen types, VAMC should continue its evaluation of formalin substitutes.
Further evaluations should consider the three products identified in Table 4-2.
VAMC should consider a more formal evaluation process for formalin replacement. For example,
VAMC could stain duplicate samples in formalin and one or more in formalin replacements.
Pathologists could then view each of the samples, one in formalin and the others in a formalin
replacement. This approach would help VAMC identify the best formalin replacement and, more
importantly, specimen types not amenable to nonformalin fixation. A structured evaluation would also
help assess different staining procedures necessary when using the replacements. Representatives from
all VAMC departments affected should be involved in the formalin replacement evaluation process to
ensure all viewpoints and potential barriers to replacement are considered before final decisions are
made.
4.2.3 Formalin Recycling
If total elimination of formalin use is not possible, VAMC should consider formalin recycling.
Recycling formalin will reduce the amount of waste generated at VAMC and reduce formalin purchasing
costs. B/R Instrument Corporation (B/R) manufactures a formalin recycling system. B/R calculated a
payback period analysis of the system for VAMC. This analysis is included in Appendix 4.
4.2.4 Formalin and Formalin Replacement Costs
VAMC purchases formalin in small, prefilled tissue biopsy containers and in bulk form for organ
samples. Examples of formalin products and costs regularly purchased by VAMC are shown on
Table 4-3.
TABLE 4-3
FORMALIN PURCHASING COSTS
Product
Total Formalin
Volume
Cost
200 X 10 mL prefilled Formalin
2.00 L
$130.00
48 X 15 mL prefilled Formalin
0.720 L
$33.00
24 X 60 mL prefilled Formalin
1.44 L
$31.00
4 L (1 gallon) Formalin
4 L
$19.00
19 L (5 gallons) Formalin
19 L
$48.00
30
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Formalin use also incurs monitoring costs for employee exposure. At least 25 percent (usually about
8 people) of the workers who come in contact with formalin are monitored for a 15-minute exposure and
an 8-hour exposure once per year. Each badge costs $35 per year to purchase and analyze. VAMC staff
time to oversee formalin monitoring is about 4 hours per year. According to VAMC personnel, no
significant costs such as time spent report writing or reviewing are related to monitoring costs.
It is possible to find replacements less expensive than formalin. Table 4-4 compares the costs of
formalin to an alternative fixative.
TABLE 4-4
COST COMPARISON OF FORMALIN VERSUS A FORMALIN REPLACEMENT
Quantity
Formalin
Cost
Prefer
Cost
OmniFix
2000ฎ
Cost
SafeFix II
Cost
Total Annual
Direct Cost
Savings*
144 X 60 mL
prefill
$186.00
$105.50
NA
NA
$2,795.24
1 gallon
$19.00
$20
$18.50
$34.46
$<158.50>
20 gallons
$192.00
$221.60
$250
$382.28
$<229.68>
Total Annual Direct Cost Savings
$2,407.06
Note: Annual use based on monthly use of 100 L with the assumption that 25 percent of the quantity is purchased in prefilled
containers, 50 percent in 1 gallon containers and 25 percent in 20 gallon increments. In cases where formalin
replacement costs varied, the middle cost value (Prefer) was used for cost comparison.
Other indirect costs associated with formalin use may include:
Worker exposure monitoring and tracking costs
Staff down time
Compensation claims
Medical expenses for illness
Annual exams for individuals who become sensitized
Reduced odor and improved working conditions
Indirect costs related to formalin replacement are not presented because of the uncertainty in appraising
the actual or approximate values of these costs. It is important to note, however, that indirect costs are
real costs and should be considered when evaluating the advantages and disadvantages of formalin
replacement.
4.3 CLEANING SOLVENT REPLACEMENT
The VAMC facility maintenance metal shop operates a solvent-based parts cleaning unit to clean
miscellaneous machinery parts associated with repair and maintenance. The parts cleaning unit uses a
petroleum distillate solvent that is managed as a hazardous chemical. The cleaning unit is operated by
31
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placing the part to be cleaned in a sink-like basin mounted above a 20-gallon solvent reservoir container.
The part is cleaned by spraying and brushing with solvent. Oils and grease are dissolved and removed
from the part in the solvent. Solvent drains back into the reservoir. The 20-gallon reservoir contains
12.5-gallons of solvent floating on a small volume of water. Inorganic particles and soil settle out of the
solvent into the water at the bottom of the drum and solvent is reused. Fresh solvent is periodically
added to make up for evaporative losses. VAMC uses about 19 gallons of solvent per year. In addition,
solvent in the reservoir eventually becomes spent due to an excess of dissolved oil and grease. The
solvent is disposed approximately once per year.
VAMC should consider replacing the solvent parts cleaner with a water-based (aqueous) cleaning unit.
Aqueous systems are beneficial because they promote healthier working conditions, reduce paper work,
and reduce environmental risk associated with storing and moving hazardous chemicals. This section
describes sink-top aqueous cleaning units, discusses implementation issues associated with aqueous
cleaning, and provides information about sink-top aqueous cleaning unit vendors.
4.3.1 Sink-top Aqueous Cleaning Units
Sink-top units are designed for manual cleaning of parts. Parts are loaded into the sink-like basin and
cleaning solution is applied by a faucet, spray, or flow-through brush. The sink area is generally about
2 feet wide by 3 feet long and 1 foot deep. Used solution flows down through a drain, is stored in a
container below the sink top, and is recirculated back to the faucet or brush by a small pump. The
cleaning solution is typically heated to between 105 and 110ฐF. Cleaning occurs primarily through
manual scrubbing. Special features on some sink-top cleaning units include particulate filters and oil
removal devices. Some sink top units also use microbes to biodegrade organic impurities such as oil and
grease. Microbes are introduced into the solution either through a filter media or biological chamber.
These units can significantly extend solution life and reduce spent solution generation. Many
manufacturers claim that cleaning solutions with microbes never become spent and only need additional
solution to be added.
4.3.2 Implementation Issues
Replacing traditional solvent parts cleaners with aqueous units presents several issues that must be
resolved for successful implementation. The foremost issue typically concerns the possibility of
oxidation (rust) on metal surfaces after contact with aqueous cleaning solutions. Most cleaning unit
vendors address this by adding a rust inhibitor to the aqueous cleaner. The concentration of rust inhibitor
depends on application-specific conditions. Another strategy for preventing surface oxidation involves
the use of compressed air to quickly dry parts immediately after cleaning. Manual application of
compressed air is usually feasible in maintenance shops where use of the cleaning unit is intermittent. In
cases where the cleaning unit is used continuously, manual application of compressed air to dry part
32
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surfaces may not be practical due to reduced throughput caused by introducing a drying step. Rust
inhibitors and compressed air are often combined to resolve the oxidation issue; however, on-site testing
is needed to establish preferred operating conditions. Many manufacturers suggest coating the parts after
cleaning to prohibit rust formation.
Aqueous cleaning units may generate spent cleaning solution, and the management and disposal
requirements for spent aqueous cleaning solution should be considered before implementation.
Biodegradation-type system manufacturers claim that no wastewater is generated because the microbes
eliminate all contaminants. Many systems include filters that must be disposed of regularly.
Manufacturers claim all filters can usually be disposed of as general refuse. The disposal method
depends, however, on the contaminants on the parts being cleaned. The aqueous parts cleaner should be
used to remove nonhazardous contaminants, such as grease and soil, from parts. If hazardous chemicals,
such as trichloroethane, are put in the parts cleaning unit, it could cause the cleaning solution to be
considered a hazardous waste.
Another implementation issue associated with solvent substitution is worker skepticism about the
effectiveness of the aqueous cleaning unit. This issue is potentially "project stopping" and should be
overcome by working with cleaning unit vendors to demonstrate the ability of aqueous units to provide
comparable cleaning. Many vendors offer free on-site demonstrations or will rent units for a trial period.
Table 4-5 summarizes information about seven sink-top cleaning units and their vendors. In some cases,
vendors provided reference names of companies that are presently using their parts cleaning system.
VAMC should use this information to contact vendors and arrange for on-site testing and
demonstrations. Most small maintenance operations, such as VAMC's metal shop, require about
3 months to collect sufficient information about available sink-top aqueous cleaning units to make a final
selection.
43.3 Solvent Substitution Costs and Benefits
Estimated costs and benefits associated with solvent substitution are summarized in Table 4-6.
Although a direct cost savings is not realized, indirect benefits should justify purchasing an aqueous
cleaning unit.
5.0 OTHER POLLUTION PREVENTION OPPORTUNITIES
Other P2 opportunities were observed during the VAMC assessment in addition to those discussed in
Section 4.0. The following list briefly explains other P2 opportunities at VAMC.
Water: Decrease water use by installing flow restrictors on flush valve toilets, replacing
tank toilets with low-volume toilets, installing faucet aerators on all sink faucets, and
eliminating and replacing all once-through cooling units. These suggestions derive from
a 1991 Denver Water Department Nonresidential Water Audit. Questions related to
33
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water use may be directed to Eddie Hernandez of the Denver Water Department at
(303) 628-6563.
Wastewater: VAMC is currently discharging wastewater containing spent chemicals to
Denver Metro. While VAMC appears to be in compliance with all applicable
regulations, a source reduction approach would take water management a step further.
Using source reduction to prevent chemicals from entering the wastewater is the
management approach of choice. Chemicals that end up in a waste stream are
essentially wasted raw materials. For example, formalin and methanol are both
chemicals that may be reused following distillation. Consider collecting these chemicals
for distillation instead of disposing down the drain.
Glutaraldehyde: Reduce glutaraldehyde use by replacing equipment in ear, nose, and
throat, and gastrointestinal laboratories with peracetic acid-based equipment (for
example, Steris).
Methanol: The clinical laboratory generates 20 L of waste methanol per month; waste
methanol could be recycled using a simple distillation apparatus. Currently, waste
methanol is disposed of down the drain.
Ethylene oxide: Replace ethylene oxide sterilization with other sterilization
systems such as peracetic acid system, hydrogen peroxide gas plasma system,
peracetic acid plasma system, or ozone-based systems. Ethylene oxide should be
removed of because it is an EPA classified probable human carcinogen, smog forming
agent, and explosion/flammability hazard. Complete elimination of ethylene oxide is an
attainable goal: Children's Hospital in Denver has eliminated this sterilizer (Contact:
Robin Koons, Manager of Environmental Health and Safety, (303) 861-6335).
Expired or unused laboratory chemicals: Develop a central purchasing and
distribution system for laboratory chemical procurement. This system would ensure that
chemicals are not over ordered and that laboratories have access to the exact amount of
necessary chemical without having to purchase excessive quantities. In addition, the
system would minimize the quantity of expired chemicals on the premises and reduce
hazardous waste tracking, management and disposal costs. This opportunity may be
difficult to implement due to space limitations and laboratory culture (sharing of
chemicals is not always desirable because of concerns about possible chemical cross
contamination). While these concerns are valid, they may be taken into consideration
and addressed in development of the system. Furthermore, the VA P2 strategy directs
VA facilities to implement acquisition and procurement policies that promote pollution
prevention. Implementation of a central purchasing and distribution would achieve this
goal. The VA Pollution Prevention Strategy is included in Appendix 3.
Hazardous waste tracking system: Develop a standardized system to track hazardous
waste management. This tracking system would provide data to support trends in
hazardous waste generation, so that priorities and decisions could more easily be made to
help focus pollution prevention efforts. The tracking system should contain the
following types of information: (1) name of hazardous waste, (2) hazardous constituents
of the waste, (3) volume of the waste, (4) source of the waste (area name and room
number), (5) reason that the material became a waste, (6) VAMC contact familiar with
the generation of the waste, and (7) date the waste was generated.
Latex Paint: Close the recycling loop by purchasing consolidated and reprocessed paint
outlined under the Comprehensive Procurement Guidelines.
Boiun's Solution: Boiun's solution is used in the histology staining machine and
contains formaldehyde and picric acid. Consider using an alternative to Boiun's
Solution which uses acetic acid instead.
34
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TABLE 4-5
SINK-TOP AQUEOUS CLEANING UNITS AND VENDORS
Supplier
Contact
Equipment Name
(GSA National
Stock Number)
Equipment
Size
Special Features
Solution Name
(GSA National
Stock Number)
Pricing
Oil
Skimmer
Filtration
Bio-
Remediation
Purchase
Long-Term
Lease
4U Products/Metalube
Corporation
Lit Goehring
(909) 279-9181
4U Kieer-flo Sink-Tops
A-35
20 gallons
~
~
4U Multi-Purpose Cleaner
Degreaser MC-509
Starts at SI,495
~
Batavia Technical Solutions, Inc.
Jimmy S. Varisco
(800) 231-6374
PW 2000
BTS Aqueous Parts
Washer System
35 gallons
~
BTS PC Parts Cleaner
$1,195
~
ChemFree Corporation
www.chemfree.com
Melissa
(770) 564-5589
SMARTWASHER
25 gallons
~
~
Ozzv Juices SW2
(6850-01-454-1310)
$1,500
~
Graymills Corporation
Don Kuehnert
(626)331-5334
Bio 436
25 gallons
~
~
Biotene
$1,395
Hydro-Tech Environmental
Systems
Aran M. LaVanter
(707) 586-8390
Zymo Parts Washer
(4940-01-439-7936)
15 gallons
~
Bio-Concentrate
(4940-01-439-7993)
$1,550
~
Nature's Way Eco-Systems, Inc.
www.ecoclean.com
Jim Andrews
(510) 797-4050
ES20 Bio-remediating
Aqueous Parts Washer
(GS-07F-9834-H)
21 to 22
gallons
~
~
Nature's Way Parts
Cleaning Solution
$1,295
Inland Technology
Joe Lucas
(253) 922-8932
IT33
30 gallons
~
LAI 171
$800
~
35
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TABLE 4-5 (Continued)
SINK-TOP AQUEOUS CLEANING UNITS AND VENDORS
| Supplier
Free On-site
Demonstration
Denver Area
Representative
Service
References
Notes |
4V Products/Metalube
Corporation
Byran Goehring
Corona, CA
(909)279-9181
4U does not provide services.
Client must request service from
manufacturer
PB Fasteners; S.M.U.D.; Nelson Irrigation;
SP.S. Technologies; Monogram
Aerospace; Hi-Shear Corp; Air Exhaust;
Textron Industries; Web Industries
Options for reusing solution; (l)oil f
skimmer plus filter plus solution
recycler, or (2) MEMBREX closed loop
system.
Batavia Technical Solutions, Inc.
Jimmy S. Varisco
Seabrook, TX
(800)231-6374
Fully serviced and maintained by
BTS representative
Anderson-Behcl Imports, San Jose, CA;
DSL Transportation, Southgate, CA; Villa
Honda, Hemet, CA
Microbes present in cleaning solution
that degrade oil and grease. New I
microbes can be added and solution 1
regenerated if microbes are killed from j
addition of inappropriate materials
IChemFree Corporation
www.chemfree.com
~
Bowman
Distribution
Kelly Fitzpatrick
Denver, Cx)
(303) 528-9700
Technical support on-site and
over the phone is an option
City of Tallahassee (Bowman Dit Rep.
Arian Dixon), Abbott Labs, lnc (Denise
Bauer 847-937-6825), Miller Brewing
(Danielle Abseil 513-844-4238), HerfT
Jones (Mike Rogers 334-288-5260)
Qaims no wastewater generated from
system. Filtration pad is impregnated
with microbes that biodegrade oil and
grease. User replaces nitration pad
every 4 weeks
Graymills Corporation
~
Gary Bax
Denver, CO
(303) 466-2268
Units are virtually maintenance
free with ChemFree
bioremediation solution
No references, system is new
Filter collects larger particles and must
be changed approximately once evety
month. Solution never needs to be
disposed of, only topped ofT as
necessary
Hydro-Tech Environmental
Systems
~
Aron M. LaVanter
(707) 586-8390
Service is generally not required
and customer is responsible for
waste disposal
National Park Service; Korbel Winery;
San Jose Mercury News
Filtering system releases microbes into
the fluid to degrade oil and grease.
Filter replaced every 2 to 4 weeks.
Fluid replaced every 18 to 24 months.
Nature's Way Eco-Systems, Inc.
www.ecoclean.com
Jim Andrews
Fremont, CA
(510) 797-4050
$50 every 1 to 2 months.
Includes filtration of pans
cleaning (PC) fluid, system check,
surface cleaning, adding PC fluid,
adding nutrients, and replacing
filter
American Airlines (contact Kate Caldwell
@415-877-6026), Kelley-Moore Paint,
U.S. Air Force, U.S. Postal Service -
Northeast Areas
Microbes retained in reservoir, or
"biochamber," in the bottom of the
sink-top unit. Favorable demonstration
by Air Force.
Inland Technology
~
Joe Lucas
(253)922-8932
San Diego Gas and Electric
System is new and not yet fully tested
by Inland. Inland will provide solution
and filters for free while in the trail
stage of the system. Facility should
provide feedback to Inland. |
36
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TABLE 4-6
VAMC POLLUTION PREVENTION ASSESSMENT
SOLVENT SUBSTITUTION
Cost and Benefit
Considerations
Solvent Cleaning
(per year)
Aqueous Cleaning
(per year)
Annual
Savings
Cleaning Chemical Use
19 gallons
35 gallons
Waste Generation
15 gallons
12 filters
Cleaning Chemical and
Filter Purchase Costs
$230
$600*
$<370>
Waste Disposal Cost
$250
negligible
$250
O&M" Costs
comparable
Total direct cost annual savings =
$<120>
Worker Adaptation
VAMC maintenance staff are familiar with
solvent cleaning and will require training and
demonstration before they accept the new
equipment
Cost (NQ)
Material Management
Healthier working conditions from eliminated
potential solvent exposure during parts cleaning
Benefit (NQ)
Solvent Emissions
Reduced environmental risk associated with
storing and moving hazardous material and waste
Benefit (NQ)
Waste Management
Reduced paperwork burden associated with
manifesting spent solvent as a hazardous waste
Benefit (NQ)
Assume aqueous cleaning unit capital cost =
$1,500'
Notes:
a Average values obtained from vendors
b O&M = operation and maintenance
c NQ = not quantified
37
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6.0 INDEX
Xopjฃ Page Numbers
automatic staining machine 4,8, 11-14
bicycle 19
Boiun's solution 13, 34
cleaning solvent replacement 31
clinical lab 4,19,20,29
ear, nose, and throat 4,34
ethylene oxide 4, 34
facility maintenance 4,5, 31
formaldehyde 3,4, 10,11,19, 27,28, 34
formalin 4, 28
formalin replacement 27-31
glutaraldehyde 8, 15, 16, 34
hazardous waste 2, 6, 8-14, 18, 28, 33, 34, 37
histology 1,3,4, 8-11,27-30,34
ffiF 8-11
infectious waste 2, 7, 10, 20- 24, 25, 27
mercury 6, 9-11, 18, 36
methanol 4, 10,19,27-28,34
morgue 1, 3, 4, 20, 27, 28
peracetic acid 7, 8, 15, 16, 19, 34
recycling 1, 8, 17, 18, 26, 30, 34,41
solid waste 8, 17,24-25, 41
solvent 4,6, 31-33, 37
special stains 11-13,29
staining 4,8,10-14, 19,29, 30, 34
sterilization 4, 15, 34
Steris 15,16, 34
technology transfer 7
wastewater 2, 3,15,33, 34, 36
water use 2, 3, 33, 34
xylene 4, 7-9
38
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APPENDIX 1
Map of Veteran Affairs Medical Center, Denver, CO
39
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APPENDIX 2
1996 Closing the Circle Award Nomination
41
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CLOSING THE CIRCLE AWARDS 1996
Nominations Form -- Deadline: February 15. 1996
1 Category: Recycling
2 Title of Nomination: Recycling at the Denver Department of Veterans
Affairs Medical Center
3. Contact Name: Bruce C. Carruthers
Acting Medical Center Director (00)
Department of Veterans Affairs Medical Center
1055 Clermont Street
Denver. Colorado 80220
Telephone: (303) 393-2800. FAX: (303) 393-2861
4. Nominee: Arnold L. Schultz. Ph.D.
Supervisory Chemist
Pathology and Laboratpry Medicine Service (113)
Department of Veterans Affairs Medical Center
1055 Clermont Street
Denver. CO 80220
(303) 393-2830
Noella B. Pregill
Contract Specialist
Acquisition and Material Management Service (90C)
Department of Veterans Affairs Medical Center
1055 Clermont Street
Denver. CO 80220
(303) 393-2849
Ken Wed.erski
Aide. Physical Medicine & Rehabilitation Service (117)
Department of Veterans Affairs Medical Center
1055 Clermont Street
Denver. CO 80220
(303) 399-8020 ext. 3268
Robert G. Gibson
Housekeeping Aide. Environmental Management Service (137)
Department of Veterans Affairs Medical Center
1055 Clermont Street
Denver. CO 80220
(303) 399-8020 ext. 2578
Sue Lucht
Rehabilitation Planning Specialist
Physical Medicine & Rehabilitation Service (117B)
Department of Veterans Affairs Central Office
Department of Veterans Affairs Medical Center
1030 Jefferson
Memphis. TN 38104
Telephone: (901) 523-8990 ext. 7531. FAX: (901) 577-7396
5 Location: Department of Veterans Affairs Medical Center
Denver. Colorado
Printed on James River Eureka paper: 35* postconsumer + 15* preconsumer content
42
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Abstract: The Denver Department of Veterans Affairs Medical Center began its
recycling program with white office paper in April. 1991 and has expanded to include
all types of office paper, corrugated cardboard, fluorescent lamps, cooking oil.
newspaper, wooden pallets, printer ribbons, aluminum beverage cans, telephone
directories, rubber stamps, plastic containers, and nickel cadmium batteries. The
program's success is due to the Recycling Program Monitors, representing thirty five
services within the Medical Center, whose responsibility is to inform the employees
within their services about the various programs and to encourage them to
participate. An information sheet is distributed to all new employees.
The recycling program at the Denver Department of Veterans Affairs Medical Center
began in April. 1991 following the efforts of an ad hoc comittee of a few people
interested in preserving the environment. The conmittee decided to enter into
recycling with a white office paper program. A voluntary network of Recycling
Program Monitors representing several of the services with the largest use of
computer paper within the Medical Center was established. It took a lot of
convincing to get a paper recycling company to agree to set up a white paper
recycling program on a trial basis. They did not believe that we could provide a
large enough volume of paper to make it cost effective for them to pick up at our
facility. During the first month we recycled 1.4 tons of white office paper.
The network of Recycling Program Monitors has increased and now represents thirty
five different services within the Medical Center. The task of the Recycling
Program Monitors is to inform the employees within their services about the various
programs and to encourage them to participate. The motto of the recycling program
is taken from a Kenyan proverb. "We have inherited the Earth from our parents and
borrowed it from our children."
With the expansion of this group of conscientious volunteers, the office paper
program now includes copy machine paper, letterhead, white tablet paper, computer
printout, laser printer paper, typing paper, sticky notes, colored paper, facsimile
paper, non-carbon reproduction paper, and envelopes. The quantity of office paper
recycled has continued to increase. We recycled 15.5 tons of paper during the first
nine months of the program. 30.2 tons in 1992. 36.4 tons in 1993. 39.3 tons in 1994,
and over 40 tons for the first ten months in 1995. The proceeds, over S2.700 to
date, are deposited in the U.S. Treasury. The participants are kept informed of the
success of the program through e-mail. They are not only given the weight of paper
they have recycled (162.5 tons), but also the equivalent saved in terms of trees
(2.762). kilowatt hours of electric power (1.690.162). barrels of crude oil (487).
and cubic yards of landfill (536).
The next area that the Recycling Program Monitors decided to get involved in was the
recycling of U.S. West telephone directories used in the Medical Center. This
program was established in 1992 in cooperation with U.S. West. Pallets are placed
for employees to recycle the old directories when they pick up the new ones. U.S.
West then picks up the old directories for recycling. About 85-903: of the
directories are voluntarily recycled. This evolved into a source reduction program
as well as a recycling program. The Recycling Program Monitors have decreased the
number of telephone directories delivered to the Medical Center by approximately
60S. They conducted a survey in each of their services to find out how many
directories were actually required. That number was less than 75% of what we were
receiving We reduced the number of directories delivered to reflect that. We were
getting directories for metropolitan Denver in the fall and local area directories
in the spring Another survey by the Recycling Program Monitors showed no need for
the local area directories and delivery of those was discontinued
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Employees next asked about the possibility of recycling newspapers on station a
program was established in 1993 with the local chapter of the Shriners. They
provide a 2 cubic yard container which they empty once a week. The Shriners utilize
the proceeds in their charitable endeavors.
At about the same time, we began a voluntary program of recycling aluminum beverage
cans. Collection areas were set up in the Canteen and near vending machines in the
two patient waiting areas. The containers are maintained by an employee in
Environmental Management Service who volunteered to do so. Approximately 20 pounds
of cans are recycled each week from these two sources. There are also several
services within the Medical Center that have established their own aluminum can
recycling programs.
In 1993. the Medical Center began to recycle corrugated cardboard. We began with a
weekly pick-up of one 6 cubic yard container. Even though this program required
employees to voluntarily break down the cardboard before our Environmental
Management Service employees picked it up to place in the container, through the
efforts of the Recycling Program Monitors, the program rapidly expanded to four 6
cubic yard containers picked up twice a week. The program continued to grow and in
June. 1994 we leased a downstroke cardboard baler. During the period of June. 1994
through October. 1995 we recycled 55.2 tons of corrugated cardboard and returned
over $1,600 to the U.S. Treasury.
The Denver Department of Veterans Affairs Medical Center participates in the x-ray
film silver recovery program. In fiscal years 1993 and 1994. 1.075.10 and 992.37
troy ounces of silver were recovered, respectively. During fiscal year 1995 the
amount of silver recovered from x-ray film was 1.071.70 troy ounces, an increase of
8* compared to fiscal year 1994. This totals 3,139.17 troy ounces, which is
equivalent to 215 pounds, of silver that have been recovered by our facility in a
three year period.
The Medical Center uses a large quantity of printer ribbons. One of the Recycling
Program Monitors in Information Management Resource Service who was responsible for
ordering the printer ribbons researched the feasibility of recycling the ribbons.
We are now returning our used printer ribbons to a vendor who restuffs the plastic
cartridges with new ribbons. As a result of this individual's efforts, during the
first year of this program. 1.630 printer ribbons were recycled at a net savings to
the Medical Center of S3.420.
The Recycling Program Monitors have been the major driving force in expanding the
recycling programs at the Denver Department of Veterans Affairs Medical Center. The
Recycling Program Monitors meet once a quarter and also communicate thorough an e-
mail group with 46 members. Their suggestions have permitted us to expand our
programs to include the recycling of fluorescent lamps, cooking oil. wooden pallets,
cooking oil. rubber stamps, and plastic bottles used for irrigation purposes in the
operating rooms and outpatient clinics.
Fluorescent lamps are picked up for recycling on a quarterly basis. During the
first two years of the program we recycled approximately 8.000 lamps that would
otherwise have been treated as hazardous waste. The glass, aluminum, and mercury
contained in the lamps are all recycled.
Over 100 pounds of cooking oil per week from our Canteen Service is picked up and
recycled into soap products. This service is provided to the Medical Center at no
cost.
Another service provided to the Medical Center at no charge keeps 70-80 wooden
pallets out of the solid waste stream per month. They are repaired if necessary and
reused.
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Rubber stamps that are no longer used are returned to the vendor when new ones are
purchased. We receive a 5J discount on new stamps. Several hundred stamps have
been recycled since this program began in November. 1994.
Approximately 600 plastic bottles per month that would have otherwise gone into the
solid waste stream are now distributed to several groups that use them as water
bottles for hiking and sports activities. These groups include the Boy Scouts, the
Sierra Club. Colorado Outward Bound, and several youth sports teams. This program
began in late 1994.
An additional plastic container recycling program began in 1995. The laundry
section of the Medical Center's Environmental Management Service has recycled 31
drums that various laundry products are shipped in. This included both 30 and 55
gallon drums that had previously been discarded into the solid waste stream.
Another program begun in 1995 involves recycling wet nickel cadmium batteries used
by our Biomedical Section of the Medical Center's Engineering Service. We have had
three pick-ups totaling 195 pounds (approximately 150 batteries). The plastic,
metal, and hazardous liquid are all recycled. These batteries had previously been
treated as hazardous waste.
"Environmental Minutes" are sent by e-mail to the Recycling Program Monitors several
times a month. These contain information on various recycling and environmental
programs available within the metropolitan Denver area. Topics have included such
themes as Christmas tree recycling, leaf mulching, motor oil recycling, xeriscape,
composting, household chemical roundups, compact fluorescent lamps, wire clothes
hanger recycling, recycled products, and an environmental research house
demonstration. These e-mail messages are forwarded by the Recycling Program
Monitors and are read by almost 700 employees within the Denver Department of
Veterans Affairs Medical Center.
Through the efforts of the Recycling Program Monitors and all the employees at the
Denver Department of Veterans Affairs Medical Center, we have been able to recover
at least a third of the material from our solid waste stream. This is evidenced by
the fact that we have reduced the number of pulls of our trash compactor from three
times a week to twice a week at a cost reduction of S13.000 a year for trash
hauling. We have also reduced the amount of solid waste that had been treated as
hazardous waste.
The fiscal impact of the recycling programs at the Denver Department of Veterans
Affairs Medical Center is minor compared to the esprit de corp that has developed in
our employees and their increased awareness of recycling and environmental issues.
In 199S. to further awareness and encourage participation in our recycling programs,
a poster design and logo contest was open to all the employees within the Denver
Department of Veterans Affairs Medical Center. The first place entry is displayed
within the Medical Center.
The various recycling programs at the Denver Department of Veterans Affairs Medical
Center have received publicity in publications of both the Colorado Hospital
Association and the Sierra Club.
Printed on James River Eureka paper: 35J postconsumer + 1SX preconsumer content
45
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APPENDIX 3
Veterans Affairs Pollution Prevention Strategy
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DEPARTMENT OF VETERANS AFFAIRS
VA DIRECTIVE POLLUTION PREVENTION PROGRAM STRATEGIC GOAL
1. PURPOSE
The purpose of this Directive is to have Department of Veterans Affairs (VA) facilities and organizations pro-
mote the use of pollution prevention practices in accordance with the Executive Order (E.O.) 12856,
"Federal Compliance with Right to Know Laws ana Pollution Prevention Requirements."
2. DEFINITIONS
a. Pollution Prevention. For the purposes of implementing pollution prevention at VA facilities, "pollution
prevention" means "source reduction." as definea in tne Pollution Prevention Act (PPA) and other practices
that reduce or eliminate the creation of pollutants through: increased efficiency in the use of raw materials,
energy, water, or other resources: or protection or natural resources ov conservation.
b. Source Reduction. As defined Pv tne PPA. source reduction means any practice which potn reduces
the amount of any hazardous suDStance. pollutant, cr contaminant entering any waste stream or otherwise,
released into the environment (including fugitive emissions) prior to recycling, treatment or disposal; and the
hazards to public health and the environment associated with the release of such hazardous substances,
pollutants or contaminants. Source reduction includes: equipment or technology modifications; process or
procedure modifications; reformulation or redesign of products: substitution of raw materials: and improve-
ments in housekeeping, maintenance, training, or inventory control Source reduction does not include
practices such as incineration wnich alter tne pnysicai. cnemical. or biological characteristics or the volume
of a hazardous substance, pollutant or contaminant througn a process or activity which itself is integral to
and necessary for the production of a product or tne providing of a service.
c. EPCRA. "EPCRA" refers to the Emergency Planning Community Right to Know Act (SARA Title III).
Compliance with EPCRA is defined by criteria set out in tne EPA Cooe of Regulations 40 CFR Part 372. VA
has nad a written Circular since 1992 calling for yA facilities tc ccmpiv with tne intent of EPCRA. E.O.
12856 now mandates that Federal facilities compiv witn mis Act Artacnment A summarizes tne content of
this Circular and should be referred to by VA facilities to determine applicable EPCRA reauirements.
3. BACKGROUND
a. On August 3. 1993, President Clinton signea the E.O. 12856 entitled "Federal Compliance with Right To
Know Laws and Pollution Prevention Requirements This E.O. ccmoines requirements of EPCRA with
those of the Pollution Prevention Act (PPA) of 1990.
b. VA issued VA Circular 00-92-5. "Emergency Planning and 'Community Right to Know Act" in 1992. As a
result of this circular, VA has voluntarily complied wnn manv of tne requirements of the Emergency Planning
and Community Right to Know Act (EPCRA) even tnougn i-eaerai facilities were not required bv iaw at that
time to comply with EPCRA.
4. POLICY
VA is committed to environmental leadership and preventing pollution bv reducing the use or hazardous
materials. Additionally, VA is committed to reducing tne release cr coiiutants to the environment to as low as
is reasonably acnievaole. VA's goal is to accomonsn pollution prevention ana reouce the generation of
wastes through a hierarchy of actions. These actions range 'rem tne most preferred cnoice ot source reduc-
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tion, to recycling, then treatment, and disposal, as a last resort. To build a strong pollution prevention pro-
gram, this hierarchy of actions must be fully integratea into day-to-day VA operations.
5. ACTION
a. VA facilities shall:
(1) Continue to participate with local, state and Federal officials in emergency planning and community
right to know activities in accordance with the "Emergency Planning and Community Right to Know Act"
as required by VA Circular 00-92-5. Attachment A summarizes the content of this Circular and includes
EPCRA requirements applicable to VA facilities.
(2) Promote reducing the use of toxic and hazardous substances and the resulting generation of waste
by reviewing facility operations, procedures and unit processes. To the maximum extent feasible imple-
ment source reduction measures including, but not limited to, the substitution of materials that are less
hazardous and/or of reduced toxicity.
(3) Promote the development of a VA pollution prevention ethic by addressing pollution prevention goals
and actions in the development of facility guidance, policy and operating procedures.
(4) Develop and implement methods to identify and quantity releases and off-site transfers of toxic and
hazardous chemicals to all environmental media (i.e.. air. soil, surface and ground water).
(5) Develop and maintain a comprehensive inventory of toxic chemicals, extremely hazardous
substances and hazardous chemicals.
(6) Promote pollution prevention awareness through training, education, and outreach/awareness
programs.
(7) Include significant environmental costs in life-cycle or other cost estimating done in conjunction with
acquisition or construction.
(8) Purchase environmentally preferable proaucts. wnen possible. Environmentally preferable products
include, but are not limited to, products having recycled content, products that can be recycled after use.
products that substitute less toxic or hazardous comoonents. Droaucts that are energy efficient and proa-
ucts that otherwise protect the environment.
b. VA Central Office and Regional organizations shall implement pollution prevention actions as
specified below:
(1) Promote pollution prevention awareness through training, education, and outreach/awareness
programs.
(2) Incorporate pollution prevention goals and actions wnen appropriate in the development of
guidance, policy and procedures.
(3) Purchase environmentally preferable proaucts. when passible.
(4) Cognizant offices will require that new heating, ventilating, air conditioning (HVAC) and refrigeration
equipment associated with projects for wmch they a*e responsible use cnemicais that do not contain
chloroflurocarbons (CFCs). Additionally, when technically and economically feasible, such offices will
require the use of equipment that does not contain CFCs for HVAC and refrigeration renovation projects.
48
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c. Veterans Health Administration organizations at VA Central Office shall set pollution prevention
goals and take specific actions as listed below:
(1) Construction Management shall:
(a) Incorporate pollution prevention requirements in specifications for construction and construction
related building systems.
(2) Environmental Management Service shall:
(a) Develop policy and program guidance to implement integrated pest management using pollution
prevention techniques.
(b) Establish an annual goal to reduce the use of toxic pesticides by a specific percentage by the
year 2000.
(3) Operations/Engineering Management and Fietd Support shall:
(a) Ensure that pollution prevention considerations are taken into account in the construction of
Non-Recurring Maintenance and Minor projects.
(b) Incorporate pollution prevention considerations into guidance, policy and standard procedures
related to facility operations and building system maintenance.
d. National Cemetery System shall:
(1) Incorporate pollution prevention into grounds keeping operation, e.g., substitute less toxic/hazardous,
or non-toxic/hazardous materials for use as pesticides or fertilizers.
(2) Establish an annual goal to reduce the use of toxic pesticides by a specific percentage by the
year 2000.
e. Acquisition and Materiel Management shall:
(1) Incorporate pollution prevention and other environmental considerations into all phases of the acquisi-
tion/procurement process including, but not limited to: requests for proposals, evaluations of propos-
als, contract documents and contract performance.
(2) Revise the VA Acquisition Regulations (VAR) as necessary to implement this strategy.
(3) Evaluate the effectiveness of alternative sterilants to ETO and. if appropriate, establish and implement
a plan to reduce the use of ETO by VAMCs and other VA health care facilities.
(4) Implement acquisition and procurement policies and lifecycle costing practices that promote pollution
prevention, reduce waste, minimize effects on natural resources and encourage economically efficient
market demand for items using recovered material.
f. The VA Environmental Executive will serve as coordinator for implementation of the VA Pollution
Prevention Strategic Goal.
6. REFERENCES
a. Executive Order 12856 "Federal compliance with Right to Know Laws and Pollution
Prevention Requirements"
b. VA Circular 00-92-5 "Emergency Planning and Community Right to Know Act" 1992
7. FOLLOW-UP RESPONSIBILITY: DIRECTOR, ENGINEERING MANAGEMENT AND FIELD
SUPPORT OFFICE (138).
8. RESCISSIONS: THIS DIRECTIVE SHALL EXPIRE
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VA DIRECTIVE
ATTACHMENT A
SUMMARY OF THE EPCRA REQUIREMENTS AS THEY IMPACT THE VA
A summary of the EPCRA requirements as they impact the VA is as follows:
1. Section 301-303 of the Act (Emergency Planning)
a. Appoint an ERC (Emergency Response Coordinator) as a point of contact for the LEPC (Local
Emergency Planning Committee). The ERC should either be someone familiar with environmental and safe-
ty concerns, such as the facility Industrial hygienist or Safety Official, or should work closely with these indi-
viduals to accomplish the tasks listed below.
b. Determine if any chemicals at the VA facility which are listed as "extremely hazardous'' have a potential for
release into the environment in such a manner as to be a threat to the safety and health of the community.
(1) Research and hospital laboratories are exempt from the reporting requirements of Section 302
of EPCRA, the "hazardous chemicals" list. VAMCs would be required to report non-laboratory
storage of bulk chemicals that are stored in quantities of 10,000 pounds or more; however, it is
unlikely that VAMCs store more than 10,000 pounds of any of the chemical on the "hazardous
chemicals" list.
(2) Research and hospital laboratories are not exempt from the reporting requirements for
chemicals on the "extremely hazardous chemicals" list (Sections 311 and 312 of EPCRA) if the
quantities of these chemicals stored at a facility equal 500 pounds or more, or exceed the TPQ
(Threshold Planning Quantity) for a specific chemical, whichever is less. There are a few
pesticides that have a TPQ of 1 pound or less. VA plans to review the use of these listed
pesticides and use suitable substitutes when feasible. This will reduce pollution that could result
from use of these chemicals. It would also reduce the reporting requirements that may be
associated with storage of these chemicals.
(3) Ethylene oxide (ETO) is used as a sterilant at most VAMCs. The Reportable Quantity (RQ) for an
accidental release of ETO is 10 pounds. Routine releases of ETO when used as a sterilant do not
have to be reported under the Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA) regulations (40 CFR 302.8(b)). Most medical centers have permits to discharge ETO
or have installed devices to prevent discharge into the atmosphere, and are, therefore, exempt from
reporting this chemical.
(4) The toxic chemical release reporting requirement (Section 313 of EPCRA) has a reporting requirement
that is based on the use of chemicals on the "toxic chemical" list in quantities of 10,000 pounds or more
of any one chemical. There are no VA facilities that store or use such quantities of toxic chemicals.
c. Provide to the LEPC a list of those chemicals which may be a potential threat and be prepared to provide
MSDS (Material Safety Data Sheets) for chemicals upon request.
2. Section 302 and 303 of the Act (Storage Reporting Requirements). The ERC will provide the LEPC
with the location of the bulk chemical storage (indicated on a map of the facility with building numbers and
roads) of "extremely hazardous" chemicals to be reported to the LEPC in the event of a release.
3. Section 304 of the Act (Release Reporting Requirements - Emergency Notification)
a. The VA ERC shall report to the State Emergency Response Commission and the LEPC uncontrolled
releases of listed "extremely hazardous" chemicals:
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(1) That exceed the agreed upon reportable amount for the chemical and leave the physical
boundaries of the installation, or
(2) May represent an imminent or substantial endangerment to public health or the environment.
b. Chemicals subject to this requirement are substances on the list of "extremely hazardous" chemicals and
substances subject to the emergency notification requirements under the CERCLA (Comprehensive
Environmental Response, Compensation and Liability Act) Section 103 (a).
NOTE; The National Response Center must also be notified for releases exceeding the reportable quantity
for substances listed under CERCLA Section 103 (A) even if the substances do not leave the physical
boundaries of the facility.
c. Information to be immediately provided in the emergency notification is as follows:
(1) The chemical name or identity of any substances involved in the release.
(2) An indication of whether the substance is on the SARA title III (Superfund Reauthorization Act) title
III list of "extremely hazardous" chemicals
(3) An estimate of the quantity of release into the environment.
(4) The time and duration of the release.
(5) The environmental medium (air, water, land) into which the release occurred.
(6) Any known or anticipated acute or chronic health risks associated with the emergency, and where
appropriate, advice regarding medical attention necessary for exposed individuals.
(7) Proper precautions to be taken as a result of the release (such as evacuation).
(8) Name and phone number of the contact person.
d. Follow-up written emergency notice after the release shall include the following information:
(1) Update of information included in the initial notice.
(2) The actual response actions taken.
(3) Any known or anticipated data or chronic health risks associated with the release.
(4) Advice regarding medical attention necessary for exposed individuals.
4. Section 311 of the Act: Material Safety Data Sheets, (Community-Right-to-Know). Provide MSDS
information on the nature, amount, and location of "extremely hazardous" substances used or stored within
the confines of our facilities, if requested by the LEPC.
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5. Section 312 of the Act; Emergency and Hazardous Chemical Inventory Forms, (Community-Right-
to-Know). This section applies to hazardous chemicals stored at or aoove 10,000 pounds and "extremely
hazardous" substances at or above 500 pounds or the Threshold Planning Quantity (TPQ), whichever is less
( 40 CFR 370.20, 370.21, 370.40). VA facilities are unlikely to meet tr 10,000 pound or the 500 pound
threshold of the listed chemicals with the exceotion of some pesticides whicn have a TPQ lower than 500
pounds, and may be used in NCS or VAMCs.
6. Section 313 of the Act: Toxic Chemical Release Forms. Applies to the manufacturing and or import-
ing, or processing of 25,000 pounds per year, or otherwise using 10,000 pounds per year of one or more
listed toxic chemicals. (40 CFR 372.25). VA facilities are not required to fill out and submit EPA Form 9350-1
"Toxic Chemical Release Inventory Reporting form," since VA facilities do not meet the chemical quantity cri-
teria of this section.
7. Compliance With State and Local Right-to-Know and Pollution Prevention Requirements. E.O.
12856 states that "Federal agencies are further encourages to comply with all state and local right-to-know
and pollution prevention requirements to the extent that compliance with such laws and requirements is oth-
erwise already mandated."
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APPENDIX 4
Pay Back Analysis for PureFoim 2000 Formalin Recycling System
53
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2/26/08
ฆo-
B/R Instrument Corp.
PureForm* 2000 Formalin Recycling System
Pay Back Analysis
Prtptrvdfor:
Monthly Usage
Unit Cost
Monthly Cost
Recovery
CMftia bowman
bviroomtifjl Eigiattr
Tclra Tech EM Lac
I Off Utb Street
Suite 1969
Denver CO
PHONE: (303)312-MSO
Formalin
100
$8.75
1075.00
80%
80202
FAX: (303)2*5-2818
Monthly
Cost Reduction $540.00
Monthly Formalin Coat Reduction
$141.00
Disposal Costfpor oaHon
Formalin
None
Monthly Disposal
Cost Eliminated N/A
Monthly Formalin Diepoeat Cost Reduction
BUFFERING KIT , COST PER LITER ($0.25)
Monthly Not FonnaNn Coat Reduction
$0.00
$20.00
$920.00
Annual Net Formalin Coat Reduction
14,240.00
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2/26/08
PUREFOftM(R) 2090 FORMALIN RECYCLING SYSTEM 113,121.00
F-470 FLOOR STAND $711.00
Total Cost of System f 13,121.00
The above system Is complete and ready to set up for operation.
Installation and Training included.
A dedicated 115V AC outlet, tap water and drain, or CFT-33, and proper ventilation,
are required for Installation. A CFT-75 wll operate 2 systems simultaneously (220V. 15A).
The purchase price also Includes the following:
* Follow-up support and technical advice by telephone from
B/R Instrument Corp. via our 800 line.
* B/R Rtcycfor newsletter with helpful Information, tips and
articles about recycling.
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2mm
Capital Cost Recovery Analysis
Ln
crป
Thli analyall It prtptnd to datarailna tha capital coal recovafy
puM for B/R InMnimanra Purafatmcfl) 2M0 Fonnalln RacycRng System.
Payback Period
PurchaM prtca of Puraform* 2008 Formafin Recycling Syttom
Payback Partod In Month* 17
Payback Parted liปYoara 2.11
For omtertng hrfonwatton ploaaa contact:
B/R Instrument Corp.
9119 Ccntreviito Road and now...
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M (BOO) 922-9206 www.brfnalrunHmtcom
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