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Environmental concerns in healthcare
  • Environmental concerns in healthcare settings can include the handling of wastewater, hazardous waste management, air emission control, toxic substance control, and more.

The healthcare industry is affected by multiple federal environmental statutes. In addition, the industry is subject to numerous laws and regulations from state, tribal, and local governments. A high-level overview is provided below.

Wastewater sources include sinks, drains, showers, toilets, and tubs; photographic development drains from radiology (X-rays), other imaging, and dentistry; and stormwater. The healthcare industry is subject to various provisions of the Clean Water Act (CWA), including:

  • Wastewater discharges;
  • Stormwater permits (municipal separate storm sewer systems such as those from hospitals and construction activities are subject to stormwater permitting requirements); and
  • Oil pollution prevention requirements (for hospitals that have a total aboveground oil storage capacity exceeding 1,320 gallons or a completely underground storage capacity exceeding 42,000 gallons).

Safe Drinking Water Act (SDWA) regulations protect drinking water. A hospital, for example, would be considered a public water system if it regularly serves at least 25 of the same persons six months per year from its own water source. The hospital would be required to comply with SDWA monitoring and reporting requirements. Healthcare facilities that have their own drinking water treatment could generate hazardous or radioactive waste.

Under federal hazardous waste laws, most healthcare facilities are hazardous waste generators. The Environmental Protection Agency (EPA) regulates facilities that generate, transport, treat, store, or dispose of hazardous waste.

Emergency planning and community right-to-know laws establish reporting obligations (such as emergency planning notification, Tier II reporting, safety data sheet reporting, and release reporting) for facilities that store or manage specified chemicals, including many chemicals commonly found at healthcare facilities.

Air emissions may come from air conditioning and refrigeration, boilers, medical waste incinerators (if onsite), asbestos, paint booths, ethylene oxide sterilization units, emergency generators, anesthesia, laboratory chemicals, and laboratory fume hoods. Under the Clean Air Act (CAA), states develop plans to identify sources of air pollution and to determine what reductions are required to meet federal air quality standards.

Healthcare facilities may also be subject to the Toxic Substance Control Act (TSCA) through:

  • Lead hazard reduction regulations;
  • Hexavalent chromium regulations;
  • Polychlorinated Biphenyls (PCB) hazard reduction regulations; and
  • Asbestos hazard reduction regulations.

In healthcare settings, EPA regulates disinfectants that are used on environmental surfaces (housekeeping and clinical contact surfaces). Disinfectants intended for use on clinical contact surfaces (e.g., light handles, radiographic-ray heads, or drawer knobs) or housekeeping surfaces (e.g., floors, walls, or sinks) are regulated under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Similary, pesticides used on the healthcare facility grounds are subject to FIFRA.