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Environmental requirements for healthcare
  • The healthcare industry is affected by multiple environmental statutes.
  • Environmental requirements in healthcare settings may cover wastewater discharges, drinking water, waste, emergency planning and community right-to-know, air emissions, toxic substance control, and pesticides.

The healthcare industry is affected by multiple federal environmental statutes. In addition, the industry is subject to numerous environmental laws and regulations from state, tribal, and local governments. Let’s take a high-level look. The table is not comprehensive, and there may be other environmental issues.

Environmental issueOverview
Water dischargesWastewater 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 — Hospitals that are indirect dischargers are subject to regulations by the local sewer authority. Most municipalities have established local prohibitions that apply specifically to medical waste discharges. Hospitals that are direct dischargers of process and sewer wastes must obtain a permit (from EPA or the state) for any point source discharge of pollutants to waters of the U.S.
  • Stormwater permits — Municipal separate storm sewer systems (MS4s), such as those from hospitals and construction activities, are subject to stormwater permitting requirements.
  • Oil pollution prevention requirements — Hospitals that have a total aboveground oil storage capacity exceeding 1,320 gallons or a completely underground storage capacity exceeding 42,000 gallons are subject to spill prevention, control, and countermeasure (SPCC) plan requirements.
Drinking waterSafe Drinking Water Act (SDWA) regulations protect human health from contaminants in 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.
WasteUnder federal hazardous waste laws, most healthcare facilities are hazardous waste generators. EPA regulates facilities that generate, transport, treat, store, or dispose of hazardous waste. Important waste requirements for healthcare facilities include:
Emergency planning and community right-to-knowEmergency planning and community right-to-know laws establish reporting obligations (such as emergency planning notification, emergency release notification, annual Tier II reporting, safety data sheet reporting, and annual toxics release inventory (TRI) reporting) for facilities that store or manage specified chemicals, including many chemicals commonly found at healthcare facilities.
Air emissionsAir 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 that qualify as a major source are required to have a Title V permit, and may be required to submit information about emissions, control devices, and the general process at the facility in the permit application.
The CAA also sets forth a list of regulated substances and thresholds, requirements for owners or operators of stationary sources concerning the prevention of accidental releases, and accidental release prevention programs. These requirements are codified in the Risk Management regulations at 40 CFR 68.
Toxic substances controlHealthcare facilities may be subject to the Toxic Substances Control Act (TSCA) through, for example:
PesticidesIn 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).
Similarly, pesticides, including insecticides, herbicides, fungicides, rodenticides, and antimicrobials, used on the healthcare facility grounds are subject to FIFRA.

For further guidance, visit: