Top Banner
Chemical Minimization -3- OVERVIEW “Hazardous” chemicals are defined by a number of regulatory agencies. Although similar, and often overlapping, each agency has its own definition. OSHA (the Occupational Safety and Health Administration) has definitions and lists of “hazardous substances”. DOT (the Department of Transportation) has definitions and lists of “hazardous materials”. The Joint Commission on Accreditation of Healthcare Organizations’ (JCAHO) hazardous materials definition includes all of the regulated chemicals. The United States Environmental Protection Agency (EPA) under the Resource Conservation and Recovery Act (RCRA) has defined many hazardous chemicals/substances/materials as hazardous waste when they are to be disposed of. For the purposes of this document, American Hospital Association (AHA) & EPA have proposed the following general definition for Hazardous Chemical Waste (HCW): Healthcare institutions generate a number of hazardous chemical wastes. Any chemical that is a “health hazard” on a Material Safety Data Sheet (MSDS) may be a hazardous chemical waste when it is disposed of. Hazardous chemical wastes due to their inherent danger to human health and the environment require, under JCAHO Standards, EPA, state and county hazardous waste rules, special handling and disposal similar to regulated medical waste. However, hazardous chemical waste is not the same as regulated medical waste and should not be handled in the same manner. The different waste streams from healthcare facilities require different management and disposal. Generally, the more toxic the waste, the more stringent the regulatory requirements and the higher degree of treatment for proper disposal. Table 1 illustrates this concept by showing the appropriate management method for the mixed wastes generated in healthcare facilities. Note the hierarchy requires the waste be treated for the most toxic form in the waste. Generally the toxicity hierarchy, from most to least toxic is: high-level radioactive waste > low-level radioactive waste > hazardous chemical waste > regulated medical waste > solid waste. So, if hazardous chemical waste is mixed with regulated medical waste then the entire mixture must be managed as hazardous chemical waste. Generally it is very difficult to find a treatment facility that can handle mixed wastes. Disposal of mixed waste is difficult and will be expensive. It is best to properly identify and segregate all waste streams from a healthcare facility before disposal. “ Waste which due to its quantity, concentration or characteristics may cause or significantly contribute to increased mortality or an increase in serious irreversible, or incapacitating reversible illness; or pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed”.
37

Chemical Minimization Plan - Practice Greenhealth

Feb 09, 2022

Download

Documents

dariahiddleston
Welcome message from author
This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
Transcript
Page 1: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization -3-

OVERVIEW“Hazardous” chemicals are defined by a number of regulatory agencies. Although similar, and oftenoverlapping, each agency has its own definition. OSHA (the Occupational Safety and Health Administration)has definitions and lists of “hazardous substances”. DOT (the Department of Transportation) hasdefinitions and lists of “hazardous materials”. The Joint Commission on Accreditation of HealthcareOrganizations’ (JCAHO) hazardous materials definition includes all of the regulated chemicals. The UnitedStates Environmental Protection Agency (EPA) under the Resource Conservation and Recovery Act (RCRA)has defined many hazardous chemicals/substances/materials as hazardous waste when they are to bedisposed of.

For the purposes of this document, American Hospital Association (AHA) & EPA have proposed thefollowing general definition for Hazardous Chemical Waste (HCW):

Healthcare institutions generate a number of hazardous chemical wastes. Any chemical that is a “healthhazard” on a Material Safety Data Sheet (MSDS) may be a hazardous chemical waste when it is disposed of.Hazardous chemical wastes due to their inherent danger to human health and the environment require, underJCAHO Standards, EPA, state and county hazardous waste rules, special handling and disposal similar toregulated medical waste. However, hazardous chemical waste is not the same as regulated medical waste andshould not be handled in the same manner.

The different waste streams from healthcare facilities require different management and disposal. Generally,the more toxic the waste, the more stringent the regulatory requirements and the higher degree of treatmentfor proper disposal. Table 1 illustrates this concept by showing the appropriate management method for themixed wastes generated in healthcare facilities. Note the hierarchy requires the waste be treated for the mosttoxic form in the waste. Generally the toxicity hierarchy, from most to least toxic is: high-level radioactivewaste > low-level radioactive waste > hazardous chemical waste > regulated medical waste > solid waste.

So, if hazardous chemical waste is mixed with regulated medical waste then the entire mixture must bemanaged as hazardous chemical waste. Generally it is very difficult to find a treatment facility that can handlemixed wastes. Disposal of mixed waste is difficult and will be expensive. It is best to properly identify andsegregate all waste streams from a healthcare facility before disposal.

“ Waste which due to its quantity, concentration or characteristics may cause or significantlycontribute to increased mortality or an increase in serious irreversible, or incapacitatingreversible illness; or pose a substantial present or potential hazard to human health or theenvironment when improperly treated, stored, transported, disposed of, or otherwise managed”.

Page 2: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization -4-

Table 11

WASTE MIXTURE TREAT AS:Solid waste + Hazardous

Chemical WasteHazardous Chemical Waste

Solid waste + RegulatedMedical Waste

Regulated Medical Waste

Solid waste + Low-LevelRadioactive Waste

Low-Level Radioactive Waste

Hazardous Chemical Waste +Regulated Medical Waste

Hazardous Chemical Wasteand Regulated Medical Waste

Hazardous Chemical Waste +Low-Level Radioactive Waste

Low Level Radioactive Wasteand Hazardous Chemical

WasteRegulated Medical Waste +

Low-Level Radioactive WasteLow-Level Radioactive Wasteand Regulated Medical waste

WHAT IS HAZARDOUS CHEMICAL WASTE?The definition of hazardous chemical waste cited on page 2 is quite general. According to EPA, Hazardouswaste can be of one or two types:

Listed waste. Your waste is considered hazardous if it appears on one of four lists i.e., P, U, K, and F-listspublished in the Code of Federal regulations (40 CFR Part 261). Currently, more than 400 wastes are listed.Wastes are listed as hazardous because they are known to be harmful to human health and the environmentwhen not managed properly.

The following is a quick reference to Listed waste:

F: Hazardous Waste from non-specific sources, such as solvent mixturesK: Hazardous Waste from specific sources, such as certain manufacturing operations

U & P: Discarded commercial chemical products. Off-spec species, container residues, and spill residues.Even when managed properly, some listed wastes are so dangerous that they are called acutelyhazardous wastes and form the P-list.

If a hazardous chemical waste is on the F, K, U or P list it is assigned the corresponding code.

Characteristic wastes. If your waste does not appear on one of the hazardous waste lists, it still might beconsidered hazardous if it demonstrates one or more of the following characteristics:

Ignitable. It catches fire under certain conditions. Examples are paints and certain degreasers and solvents.

Corrosive. It corrodes metals or has a very high or low pH. Examples are rust removers, acid, or alkalinecleaning fluids, and battery acid.

1 Provided by the Florida Department of Environmental Protection Report #S97-15. Used with permission.

Page 3: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization -5-

Reactive. It is unstable and explodes or produces toxic fumes, gases, and vapors when mixed with waster orunder other conditions such as heat or pressure. Examples are certain cyanides or sulfide-bearing wastes.

Toxic. It is harmful or fatal when ingested or absorbed, or at leaches toxic chemicals into the soil or groundwaster when disposed of on land. Examples are wastes that contain high concentrations of pesticides orheavy metals such as cadmium, lead, or mercury.

The EPA and states list the F, K, U and P chemicals. The EPA listings (40 CFR 261.31-33) are located inAppendix A or at the EPA web site www.epa.gov/docs/epacfr40/chapt-I.info/subch-I/40P0261.pdf.Individual state and county listings may differ. The chemicals that are hazardous by characteristic areassigned a D code.

Universal Wastes (40 CFR 273) include batteries, thermostats, and fluorescent lamps. If generated by a smallor large quantity generator, these wastes are considered hazardous waste regulated by RCRA. However, theuniversal waste rule eases the regulatory burden associated with these wastes in order to promote recyclingand proper disposal of these wastes. While EPA has passed the universal waste rule, individual states maynot yet have adopted it. For more information, visit EPA’s web site atwww.epa.gov/epaoswer/hazwaste/id/univwast.htm

DEPARTMENTS THAT GENERATE HAZARDOUS CHEMICAL WASTEHospitals for a Healthy Environment (H2E) has identified a number of “listed” and “characteristic”chemicals and formulations in healthcare facilities. Departments most likely to use these hazardous chemicalsinclude:

ß DIALYSIS ß ENVIRONMENTAL SERVICES ß FACILITIES MANAGEMENT/ENGINEERINGß LABORATORY/HISTOLOGY/PATHOLOGY ß NUTRITION SERVICES ß PHARMACY ß RADIOLOGY ß STERILE PROCESSING ß SURGICAL SERVICES

HOW TO IDENTIFY HAZARDOUS CHEMICAL WASTEUse the Material Safety Data Sheet, product insert, technical bulletin or other resource to identify thechemical constituents present in the chemical/product you are working with. Other resources are listed inAppendix B.

1. If it is a pure chemical or sole active ingredient then check to see if the chemical is on the P or U lists.(See Appendix A) link

2. If you are using a solvent, check to see if it is on the F-list. (See Appendix A) link3. If the chemical is not in the listings, or is a formulation of multiple ingredients, it still may have a

characteristic that makes it a hazardous waste.

For more details on identifying hazardous waste by characteristic, refer to the “Identification ofCharacteristics” section below.

Page 4: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization -6-

CHARACTERISTICS

Ignitable (Waste Code D001):A chemical with a flashpoint of less than 140o F, it is an ignitable hazardous waste.

Examples: Mineral SpiritsEthanolD-LimoneneOil-based PaintsFormalinXylene

Aqueous Solutions:For aqueous solutions containing alcohol, any chemical or preparation with 24% or more alcohol is ignitable.

Examples: Rubbing alcohol (denatured ethyl and isopropyl)Benzoin TinctureRetin A® Gel

Listerine® Mouthwash (Original Formulation)

Non-aqueous Solution:Preparations with acetone, ether, flexible collodion or other solvents as a base may have a flash point lessthan 140o F and should be managed as a hazardous waste when discarded.

Ignitable Compressed Gas:Aerosols that use a flammable propellant (the label has the word “Flammable”) should be managed as ahazardous waste when discarded. A simplified approach is to consider all discarded aerosols as hazardouswaste.

Examples: Solarcaine® SprayRight Guard®Primatene® MistEthyl Chloride (chloroethane)Fluro-Ethyl (25% ethyl chloride, 75% dichlorotetrafluorethane)

Note: Although a propellant is not ignitable, it might contain chlorofluorocarbons, which may be a F or U listed hazardouswaste, or can cause problems in certain incinerators. It is important to discuss this waste stream with disposal facilities to ensurethat the facilities are properly permitted to dispose of chlorofluorocarbon waste. Also, large quantities of aerosols (such as casequantities) present a hazard in case of fire and should be stored in a secure, confined space.

Oxidizer (Waste Code D001)Oxidizers readily supply oxygen to a reaction in the absence of air. Examples of oxidizers include, but are notlimited to, oxides, organic and inorganic peroxides, permanganates, perrhenates (contain Rhenium), chlorates,perchlorates, persulfates, nitric acid, organic and inorganic nitrates, iodates, periodates, bromates,perselenates, perbromates, chromates, dichromates, ozone, and perborates. Bromine, chlorine, fluorine, andiodine react similarly to oxygen under some conditions and are therefore also oxidative materials.

Examples: Hydrogen peroxidePotassium permanganateSilver nitrate sticks

Amyl nitrite inhalantsSilver nitrate

Page 5: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization -7-

Corrosive (Waste Code D002)Corrosive hazardous wastes are defined as an aqueous solution1 having a pH less than or equal to 2 or greaterthan or equal to 12.5 or other chemicals that corrode steel or damage skin. See Appendix A for the completedefinition.

Examples: Phenol Glacial acetic acid Sodium hydroxide

Hydrochloric acid Mediplast® (40% Salicylic Acid)

Acidified specimens

Reactive (Waste Code D003):Chemicals that are unstable, explosive or will generate toxic gases or fumes are classified as reactive.Specifically, a reactive chemical will do one or more of the following:

ß react violently with water;ß form potentially explosive mixtures with water;ß when mixed with water, generate toxic gases, vapors, or fumes in a quantity sufficient to present a danger

to human health or the environment;ß be a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2.0 and 12.5 can

generate toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or theenvironment;

ß be capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heatedunder confinement;

ß be readily capable of detonation or explosive decomposition or reaction at standard temperature andpressure; or

ß be normally unstable and readily undergoes violent change without detonating;ß a forbidden explosive as defined in Code of Federal Regulations, Title 49.

Examples: (possibly) Cyanide-bearing waste from hemoglobin determinationsNitroglycerin products(Possibly) sodium-azide wastes

Incompatible mixtures such as ammonia and bleach (sodium hypochlorite)

ToxicA toxic waste is one which, when using the Toxicity Characteristic Leaching Procedure (TCLP), leaches anynumber of metallic, organic, or pesticide contaminants in concentrations greater than or equal toconcentrations specified by regulation. These contaminants cover approximately forty chemicals, includingarsenic, barium, cadmium, chloroform, chromium, lindane, cresol, mercury, selenium, and silver at specificconcentrations of mg/L. (For the complete list of the toxicity constituents refer to Appendix A.)

The Toxicity Characteristic Leaching Procedure is a laboratory test designed to mimic landfill conditions.The waste is pH adjusted, mixed and analyzed for the toxicity contaminants. For complete details of theprocedure, refer to Code of Federal Regulations 40 Part 260.11. If the resulting analyses exceed any of theregulatory levels, then the waste is hazardous due to the “toxicity” characteristic.

For example: A hospital laboratory test requires that chloroform be used as one of the reagents. Theresulting mixture of chloroform, patient specimen and other reagents may be EPA “toxic” for chloroform.To determine whether or not this specimen must be managed as hazardous chemical waste, the TCLP isused. If the chloroform concentration in the waste specimen is greater than or equal to 6.0 mg/L (ppm) thenit must be managed as hazardous chemical waste.

1 For the corrosive characteristic, “aqueous solution” is defined as 20% or more water.

Page 6: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization -8-

Note, the regulatory limit is measured in parts per million, which is extremely low. In the example above if the chloroform ispresent at percent (parts per hundred) concentrations, e.g. 10 mls in 100 mls total, it is likely that the resultant waste will behazardous chemical waste. Parts per hundred (percent) is ten thousand times larger than parts per million.

1% = 0.01 = 1/100 = 1/102

1 ppm = 0.000001 = 1/1,000,000 = 1/106

(x) 1/106= 1/102 or (x) 1/1,000,000 = 1/100

Rearranging to solve for x:

106/x = 102 or 1/1,000,000/x = 100

x = 104 = 10,000

It is important to remember this relationship when using a chemical that has a toxicity constituent listed onthe MSDS. When using a MSDS as a guide, remember that the concentrations of constituents are in percent.Toxicity Characteristic regulatory limits are in parts per million. To be sure that a hazardous waste toxicityconstituent is not present especially when it is expected in a chemical, ask the manufacturer for a Certificate ofAnalysis (see Mercury chapter).

Examples: Chromic Chloride 20mcg/mlThimerosal®-containing products. E.g. pharmaceuticals and lab reagentsPesticidesLab wastes containing any of the Toxicity Characteristic contaminantsPaintsDyes and Stains

Other CharacteristicsSome states and counties have additional characteristics for hazardous waste. Be sure to check with yourlocal authority.

OUR FACILITY HAS HAZARDOUS WASTES. NOW WHAT?Removal of hazardous chemical waste usually requires disposal at facilities specifically permitted for them byEPA. There are specific regulatory requirements for the management of the waste prior to disposal. Theserequirements include proper labeling, storage and training of employees. The number of requirements that ahealthcare institution may be required to comply with will vary depending on the amount of hazardouschemical waste that is generated on an annual and/or monthly basis.

JCAHO’s Environment of Care Standards EC 1.5 and EC 2.4 (see Appendix I link) require compliance withapplicable law and regulation regarding hazardous chemical wastes. Table 2 provides an overview of theFederal hazardous chemical waste requirements. Contact your state hazardous waste program for details inyour area.

Page 7: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization -9-

Table 2. HAZARDOUS CHEMICAL WASTE REQUIREMENTS

Generator Category Very Small Quantity orConditionally Exempt

Small Quantity (USEPA designation)

Small Quantity Large Quantity

Volume of HazardousWaste Generated

Less than 220 pounds(about half of a 55- gallondrum liquid) per monthNo more than 2.2 lbs. oftotal “P” listed chemicals

per month

More than 220 pounds butless than 2200 pounds

(about one-half drum to 4-55 gallon drums liquid) per

monthNo more than 2.2 lbs. oftotal “P” listed chemicals

per month

More than 2200 pounds (about4-55 gallon drums liquid) ormore than 2.2 lbs. of total “P”listed chemicals 1per month

Basic RequirementsEvaluation All solid wastes must be evaluated to determine whether or not they are hazardous chemical

wastes.Containers The waste must be kept in a leakproof container with a tight fitting lid that must be kept

closed except when adding or removing waste.Labeling All hazardous waste containers must be labeled with the words “hazardous waste”, a

descriptive name of the waste and the date waste was first put in the container.Storage Generally requires secure area where likelihood of damage or unauthorized access is limited.

Protection from the elements and release to the environment is also required. See localguidance for details.

Accumulation No more than 1000kilograms/2200 pounds(about 4-55 gallon drums

liquid2) on site

No more than 3300kilograms/6600pounds

(about 12-55 gallon drumsliquid2) on site

No limit. Waste must beshipped every 90 days.

Recordkeeping Track type and amount of hazardous waste generated. Keep tracking records, manifests,container inspection logs for minimum of 3 years.

Shipping Papers Use Uniform Hazardous Waste ManifestEPA Identification

NumberMay be required. Check

with state authorityRequired

License A license to generate hazardous waste may be required. Check with EPA or state authority.Disposal Use EPA permitted Hazardous Waste disposal facilities3.Transport Use EPA permitted hazardous chemical waste transporters.

Emergency Response Coordinator and Plan requiredHazardous WasteContingency Plan

Required4

Keep records for minimumof 3 years

Personnel Training &Documentation

Required5.Keep records for minimum of 3 years.

1 Some examples of p-listed chemical waste generated by hospitals include epinephrine and nitroglycerin.2 Assuming that 1 gallon of liquid weighs 10 pounds.3 Regulated Medical Waste disposal facilities usually do not have permits that allow them to properly dispose hazardous chemical waste. To identify aHCW disposal facility in your state, contact local authorities or a technical assistance program.

4A template for developing these plans can be found at www.pca.state.mn.us.5 A template for developing these plans can be found at www.pca.state.mn.us.

Page 8: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization -10-

PERSISTANT, BIOACCUMULATIVE, TOXIC CHEMICALS (PBTs)

WHAT ARE PERSISTENT BIOACCUMULATIVE TOXIC CHEMICALS?The United States Environmental Protection Agency (EPA) defines Persistent, Bioaccumulative and Toxicchemicals (PBTs) as:

Persistent - the constituent does not generally break down into other substances once they are released intothe environment.Bioaccumulative - The constituent accumulates in plant and animal tissue.Toxic - The constituent found in hazardous wastes regulated under the Resource Conservation and RecoveryAct (RCRA), has the potential to harm the environment or adversely impact human health.

PBT chemicals do not readily break down or decrease in potency after they are released to the environment,even if released in very small, legally permitted quantities. Over time, these chemicals accumulate in soils orother environmental media, are absorbed or ingested by plants and animals, accumulate in animal and planttissue, pass through the food chain, and potentially cause long-term human health or ecological problems(such as cancer and birth defects in humans or reduce ecological populations). For this reason, PBTchemicals are a national and international environmental and human health concern long after they are used,generated in hazardous waste, or released to the environment. 1

Because of the danger to human health and the environment that PBTs present, they are the focus of manynational and international initiatives including the Canada-United States Binational Toxics Strategy, the EPA’sPersistent, Bioaccumulative and Toxics initiative and the waste Minimization National Plan: Reducing Toxicsin our Nation’s Waste2. PBTs are targeted for elimination from our nation’s waste. The best way to eliminatePBTs from our waste is to eliminate their use.

The following persistent, bioaccumulative and/or toxic chemicals are found in chemicals and products usedin healthcare facilities. (Table 3) For the complete list refer to Appendix D link. Most of these chemicals arehazardous chemical waste when disposed of.

1 EPA530-F-98-028 Environmental Fact Sheet: EPA Releases RCRA Waste Minimization PBT Chemical List

2 For more information about these activities see www.epa.gov/pbt

Page 9: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization -11-

Table 3: PBTs Used and Healthcare

PERSISTENT, BIOACCUMULATIVE and/or TOXIC CHEMICALS USED inHEALTHCARE1,2

Chlorinated Solvents Chloroform1,1-Dichloroethane1,1,1-Trichloroethane

Metals and Cyanide Antimony, Arsenic, Beryllium, Cadmium, Chromium, Copper,Lead, Mercury, Nickel, Selenium, Zinc, Cyanide

Dioxins and Furans3

NonhalogenatedPhenolics

Phenol

Pesticides Aldrin/Dieldrin, Chlordane, DDT, alpha-Endosulfan, beta-Endosulfan, Heptachlor, Heptachlor epoxide,Hexachlorobenzene,gamma-Hexachlorocyclohexane , Methoxychlor, Mirex,Octochlorostyrene, Pentachloronitrobenzene,Pentachlorophenol, Toxaphene, 2,4,5-Trichlorophenol

Phthalate esters Di-(2-ethylhexyl) phthalate (DEHP), Butylbenzyl phthalate,Dibutyl phthalate

1 Source: US EPA Office of Solid Waste draft PBT Chemical List, 1998.2 US EPA Office of Pollution Prevention and Toxics amended the list to define “Priority PBTs” as lead, mercury,Aldrin/Dieldrin, Chlordane, DDT, Hexachlorobenzene, Mirex, Octochlorostyrene, Toxaphene, 2,4,5-Trichlorophenol,polychlorinated biphenyls (PCBs) and benzo (a) pyrene. However, the toxicity of the chemicals listed is still recognizedand they are retained as chemicals of concern in healthcare.

3Dioxins, while not found in chemicals and products used in healthcare are produced when medical waste is incinerated.

Page 10: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

HOW TO REDUCE HAZARDOUS CHEMICAL WASTE AND PBTsUnderstanding the hazards to human health and the environment, the complexity of the regulationsgoverning these chemicals and the potential liability, one can see that reducing hazardous chemical waste andPBTs is a wise strategy. Hazardous Chemical Waste is one of the most expensive waste streams for a facilityto manage. Waste reduction can be achieved using a set of methods and strategies to decrease the volume ofwaste generated at the source or in actual usage. The methods or strategies used to reduce hazardouschemicals will vary depending upon their application. Some examples of waste reduction methods include:

Substitution: using an alternative chemical that is less hazardous, such as replacing mercury thermometerswith digital thermometers. Eliminate the use of aerosols. Pump sprays can be just as effective.

Reduction: diminishing the amount of chemical used in a procedure. E.g. only use the smallest amount offormalin necessary to preserve a specimen. Purchasing a pint of paint rather than a gallon to paint a smallarea.

Reuse: prolonging the life of a material or chemical. Some chemicals such as formalin can be reused to fixanother specimen.Distillation of solvents such as formalin or xylene is reuse and waste reduction. It usually can reduce theamount of waste generated by 90%.

Proper evaluation & segregation: ensuring the wastes are properly identified and segregated prior todisposal. Mixing a hazardous chemical waste with refuse will cause the resulting mixture to requiremanagement as hazardous waste.

Good Housekeeping: ensuring that chemicals are used and stored properly to prevent spills and leaks. Putdrip pans under spouts; use the dripped chemicals. Put containers under bottles, drums, etc. to catch anydrips, spills or leaks.

Proper Materials Handling: Use appropriate equipment and containers. Ensure drips are contained andspills are properly cleaned up.

Inventory Control: Only order chemicals needed and ensure they are used up. Implement first-in, first-outpolicy.

Staff training: Train personnel on proper uses and procedures for chemicals.

Note: Recycling is not considered a “waste reduction” approach. Recycling is a management option forwaste or discarded materials. The waste is not reduced by recycling; it is diverted from the waste stream andmade into product..

POLYVINYL CHLORIDE PRODUCTS AND DIOXINSMany products used in healthcare contain polyvinyl chloride (PVC). Some of these products are intravenous(IV) bags and tubing, blood bags, oxygen or other flexible tubing, Venodyne sleeves, rigid packaging trays,mattress covers, x-ray folder holders and shower curtains.

The incineration of PVC products due to the chlorine in them are linked to dioxin formation. Dioxins arePBTs and strong carcinogens. Minimizing or eliminating the use of PVC products coupled with non-incineration disposal technology will reduce healthcare’s dioxin contributions.

Page 11: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

WHICH HAZARDOUS CHEMICALS SHOULD BE REDUCED OR ELIMINATED?Each facility should make its own determination regarding chemicals to target for reduction and/orelimination. Some of the factors to consider in the determination: regulatory burden, ease of elimination orsubstitution, efficacy of substitute, volume, and number of employee health related incidents. H2E hasdeveloped a Prioritization Tool to assist facilities with identification of those chemicals that should bereduced or eliminated from their facilities. A detailed description of the methodology used in prioritizingchemicals for this project is contained in Appendix F link. Table 4 summarizes the priority chemicalsidentified using the tool. The individual department chapters identify substitutions and alternatives for thesechemicals.

Table 4. HEALTHCARE PRIORITY CHEMICALS

Priority Chemical Department(s) UseAcetic acid Dialysis Membrane cleaner

Laboratory SolventAcetoneFacilities/Maint/Engr. Solvent, paints, adhesives, coatings

Acetylene Facilities/Maint/Engr. WeldingAmmoniumhydroxide

Nutrition Services Floor stripper, floor cleaner

Environmental Services PesticideArsenicLaboratory Test standardMany departments Sanitizer, cleanerBleach- (sodium

hypochlorite) Nutrition Services Sanitizer, cleaner, pre-soakEnvironmental Services Cleaning agentFacilities/Maint/Engr. Cleaning agent

2-butoxyethanol

Nutrition Services Cleaning agentLaboratory SolventEnvironmental Services Cleaning solvent

Chloroform

Pharmacy Compounding solventChlorinatedRefrigerants

Facilities/Maint/Engr. Cooling systems

Cyclohexylamine Facilities/Maint/Engr. Boiler amineCyclophosphamide Pharmacy Chemotherapeutic agentDaunorubicin Pharmacy Chemotherapeutic agentDi-(ethylhexyl)phthalate (DEHP)

All departments Intravenous, blood bags &tubing, other flexibletubing

Environmental Services Floor waxesDibutyl phthalateSurgical Services Nail polish remover

Diethylaminoethanol

Facilities/Maint/Engr. Boiler amine

Epinephrine Pharmacy Therapeutic agentEnvironmental Services Cleaner, floor stripperNutrition Services Oven cleaner, degreaser, floor stripper

Ethanolamine(mono-)

Facilities/Maint/Engr. CleanersEthyl alcohol(ethanol)

Laboratory Solvent, cleaner/disinfectant

Ethylene Oxide Sterile Processing Equipment sterilizationEnvironmental Services,Sterile Processing

Page 12: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

Priority Chemical Department(s) Use2-Ethoxyethanol(Ethylene glycolmonomethyl ether)

Environmental Services Floor stripper

Pathology/MorgueLaboratory

Fixative

Dialysis Sterilant

Formalin(formaldehyde andmethanol)

Surgical Services Fixative, Sterilant

Gasoline Facilities/Maint/Engr. Fuel, solventGlutaraldehyde Sterile Processing SterilantHexane Facilities/Maint/Engr. adhesives

Environmental ServicesHexylene glycolSurgical Services

Germicidal Detergent

Hydrogen Peroxide Dialysis Cold sterilant (Renalin™)Isopropanol Most Departments Topical DisinfectantLindane Pharmacy TherapeuticMercury Most Departments See Departmental Chapters & Mercury ChapterNicotine Pharmacy Therapeutic agentNitroglycerin Pharmacy Therapeutic agent

Dialysis Cold sterilant (Renalin™)Peroxyacetic AcidSurgical Services Cold sterilant (Renalin™)Facilities/Maint/Engr. Paint thinner, adhesives, coatings, paintPetroleum distillatesNutrition Services PesticidesEnvironmental Services Disinfectant

Laboratory Solvent

Pharmacy Compounding solvent, preservative, therapeuticagent

Phenol

Surgical Services Disinfectant

Environmental Services Preservative in detergents, cleaners, paintLaboratory Preservative in reagents, test standard

Phenylmercuricacetate (PMA)

Pharmacy Preservative in numerous preparationsPhosphoric acid Nutrition Services Sanitizer, floor cleanerPhysostigminesalicylate

Pharmacy Therapeutic agent

Potassium cyanide(see sodium cyanide

Facilities/Maint/Engr. cleanersPotassium hydroxideNutrition services Presoak, oven cleaner, floor cleaner

Propane/isobutane All departments Aerosol propellantSelenium andseleniumcompounds

Pharmacy Therapeutic agent (dandruff shampoos)Vitamin/Mineral Preparations

Sodium azide LaboratoryPharmacy

Reagent preservativePreservative

Sodium cyanidePotassium cyanide

Laboratory Test reagent(hemoglobin determinations, cyanidetesting)

Facilities/Maint/Engr. Boiler & other cleanersSodium hydroxideNutrition Services Oven cleaner, degreaser, detergent

Page 13: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

Priority Chemical Department(s) Use

Sodium nitrite Facilities/Maint/Engr. Boiler chemical (corrosion inhibitor)Environmental Services Floor cleaner, floor stripperSodium metasilicateNutrition Services Presoak, floor stripper, floor cleaner, detergentLaboratory Reagent preservativeThimerosal™Pharmacy Preservative in numerous preparationsEnvironmental Services Graffiti and other cleaners Laboratory Solvent

1,1.1Trichloroethane

Surgical services Spray cleanerXylene Laboratory SolventZinc oxide Environmental services Paint pigment

Page 14: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

HEALTHCARE PRIORITY CHEMICALS BY DEPARTMENT

DIALYSIS

This Chapter is designed to assist you in identifying and substituting or eliminating high priority dialysischemicals that have been elucidated with the H2E Prioritization Tool. These chemicals are problematic withrespect to toxicity, regulatory status, and volume.

PRIORITYCHEMICAL

USE ELIMINATION/REDUCTIONTIP

HydrogenPeroxide/PeraceticAcid (Renalin™ orActrilTM)

Cold sterilant ß Review disinfection/sterilizationpractices with respect tonecessity.

ß Use smallest amount necessary.ß Ensure complete degradation

before disposal.ß Reverse Osmosis (RO) units can

be made compatible withhydrogen peroxide/peraceticacid (HP/PAA) disinfectantsusing pre-treatment to removeiron. (The iron reacts with theHP/PAA and can form holes inthe RO membrane).

Acetic acid Equipment cleaning ß Use lowest dilution necessary.ß Use smallest amount necessary.ß Ensure complete neutralization

prior to disposal.Di-(ethylhexyl)phthalate (DEHP)

Intravenous and blood bags, flexibletubing

ß Purchase PVC-free products.

Glutaraldehyde(Cidex™)

High level disinfectant ß Substitute hydrogenperoxide/peracetic acidsterilants.1

Propane/isobutane Aerosol propellant ß Use non-aerosols.Formalin/Formaldehyde

High-Level disinfectant ß Substitute hydrogenperoxide/peracetic acidsterilants1

ß All waste solutions should becollected and disposed of ashazardous chemical waste.

1 Although hydrogen peroxide/peracetic acid (HP/PAA) sterilants have also been identified as priority chemicals, the occupational and environmentalhazards associated with HP/PAA are less than those of formalin (formaldehyde and methanol) are and glutaraldehyde.

Formaldehyde is considered a carcinogen by the National Toxicology Program (NTP). The OSHA permissible exposure limit (PEL) Time WeightedAverage (TWA) = 0.75 ppm. The NIOSH (National Institute of Occupational Safety and Health) exposure limit is lower (0.3 ppm). Formaldehyde isan environmental hazard due to its persistence in waste waters and aquatic toxicity (Handbook of Environmental Date on Organic Chemicals, 2nd Ed.1983).Glutaraldehyde is considers a suspect carcinogen by the NTP. Its OSHA PEL = 0.2 ppm. Because it too, is an aldehyde, glutaraldehyde is likely to betoxic in aquatic environments.

Page 15: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

OTHER CHEMICAL WASTE MINIMIZATION ACTIVITIES FOR DIALYSIS

ß When replacing dialysis equipment, look for heat-disinfected units.

ß Segregate waste. This allows for recovery, recycling, or may reduce the amount of waste that needs to bedisposed.

ß Implement First In First Out policy. Use the oldest, usable product first to avoid having to dispose ofout-dated products.

ß Implement “just-in-time” purchasing policy .

ß Train employees on waste reduction, how to use equipment properly, and proper procedures.

Refer to the Environmental Services Department section link for general cleaning chemical tips and pages 12-13 link for other tips.

Page 16: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

ENVIRONMENTAL SERVICES

This Chapter is designed to assist you in identifying and, substituting or eliminating high priorityenvironmental services chemicals that have been illuminated with the H2E Prioritization Tool. Thesechemicals are problematic with respect to toxicity, regulatory status, and volume.

PRIORITYCHEMICAL

USE ELIMINATION/REDUCTION TIP

Arsenic Herbicides/Pesticides ß Incorporate Integrated PestManagement (IPM) techniques1.

ß Substitute pesticide withoutarsenic.

Chloroform Spotting or dry cleaning agent ß Substitute an enzymatic cleaner.ß Substitute non-chlorinated solvent

such as mineral spirits.Coumarin/Warfarin Mouse and Rat Killer (“Rattex”) ß Incorporate Integrated Pest

Management (IPM) actions such aseliminate food and entrancesources.

ß Use mechanical traps.Dibutyl phthalate Floor finishes and waxes

Deodorizersß Substitute products without dibutyl

phthalate.ß Increase ventilation and remove

sources of odor.2-Ethoxyethanol(Ethylene glycolmonomethyl ether)

Cleaners, waxes, solvents,varnishes, stains

ß Substitute products without glycolethers.

Phenol DisinfectantWarming Mats

ß Carefully evaluate application. Useonly where tuberculocidal action isnecessary.

ß Peroxy compounds can besubstituted.

ß Propylene Glycol can besubstituted in the warming mats.

Phenylmercuricacetate (PMA)

Preservative in cleaners, waxes,etc.

ß Substitute products withoutPMA—ask manufacturer foralternatives.

Phosphoric acid Porcelain cleaner ß Look for acid-free porcelaincleaners.

ß Use mechanical action to clean.Propane/isobutane Aerosol propellant ß use non-aerosols1,1,1 Trichloroethane(TCA)

Graffiti removerStainless steel polish

ß Substitute products that arechlorinated solvent free.

ß Cover graffiti.ß Mechanically remove with

sandblasting, if feasible.ß Increase security in areas where

graffiti is prevalent.Zinc oxide Paint dye ß Substitute Zn-free. 1See Appendix H. link

Page 17: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

OTHER TIPS FOR HAZARDOUS CHEMICAL REDUCTION in ENVIRONMENTALSERVICES

ß Incorporate Integrated Pest Management (IPM) techniques and practices. See Appendix H link fortips.

ß Evaluate Disinfection Practices. Are disinfectants being used appropriately? Are the correct dilutionsbeing used? Is the correct disinfectant being used? Is disinfection necessary? See Appendix G forDisinfection Fact Sheets .

ß Eliminate products in aerosol cans. Most aerosol containers are flammable due to the propellants used inthem. Unless these containers are totally emptied of propellant and product, they are considered hazardouschemical waste. To completely empty an aerosol container, a special device must be used and the cancontents must be collected and managed as hazardous chemical waste. A much easier, safer and lessexpensive option is to use pump sprays. Pump spray bottles are frequently refillable allowing for bulkproduct purchase and reduction of solid waste volume.

ß Use rechargeable batteries. Whenever possible, purchase products and equipment that come withrechargeable batteries and battery recharger already installed. Most alkaline batteries still contain smallamounts (0.025%) of mercury and the thousands of batteries used by healthcare facilities contributesignificantly to mercury pollution. The rechargeables that are pre-installed recharge while the product isplugged in.

ß Eliminate odor-masking products and perfumes in products. Odor masking chemicals do not eliminateodor, they only mask it. Use of these products adds chemicals to the indoor air. The best way to eliminateodors is to eliminate the source of the odor and to increase ventilation.

ß Reduce the number of products that have similar ingredients. Purchase products with multiplefunctions such as multi-purpose cleaners.

ß Eliminate floor waxes and strippers that contain zinc.

ß Purchase proper equipment for transferring chemicals. Properly designed and fitted containers willreduce spills and having to dispose of material. Consider controlled dispensing units.

ß Use controlled dispensing units for chemicals.

ß Filter and reuse paint thinner. Make sure that filtered material is disposed of properly. If the paintcontains heavy metals or if toluene or methylene chloride is present, the filtered material will require disposalas hazardous chemical waste.

ß Investigate an ozone system in laundry instead of using standard bleaches.

ß Segregate waste. This allows for recovery, recycling, or may reduce the amount of waste that needs to bedisposed.

ß Train employees on waste reduction, how to use equipment properly, and proper procedures.

Implement First In First Out policy. Use the oldest, usable product first to avoid having to dispose ofout-dated products.

Page 18: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

Implement “just-in-time” purchasing. Buy only the amount you need.

Page 19: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

FACILITIES/MAINTENANCE/ENGINEERING

This Chapter is designed to assist you in identifying and, substituting or eliminating high priorityfacilities/maintenance/engineering chemicals that have been illuminated with the H2E Prioritization Tool.These chemicals are problematic with respect to toxicity, regulatory status, and volume.

PRIORITYCHEMICAL

USE ELIMINATION/REDUCTION TIP

Acetone Solvent ß Use water based adhesives, coatingsand paints.

Acetylene Welding ß Outsource welding jobsBoiler feed treatmentresidue; boilerblowdown; coolingtower treatmentresidue

By-product & accumulation solids ß Substitute phosphorus-free chemicals.ß Use alternative methods such as

ozonation.

2-butoxyethanol Cleaners ß Substitute cleaners without 2-butoxyethanol.

Cyclohexylamine Boiler amineCondensate pH & corrosioncontrol

ß Substitute other compoundsß Use alternative methods such as

ozonation.Dichlorodifluoromethane

Refrigerant ß Use non-halogenated, non-ozonedepleting refrigerants.

Diethylaminoethanol Boiler amineCondensate pH & corrosioncontrol

ß Substitute other compoundsß Use alternative methods such as

ozonation.Ethanolamine Cleaning products ß Substitute product without

ethanolamine.Gasoline Fuel, solvent ß Use alternative non-petroleum fuel

sources such as rechargeables, electricmotors, etc.

ß Use mineral spirits as solvent.Hexane Adhesives ß Use water based adhesives.Petroleum distillates(mineral spirits,naphtha)

Solvents, parts washing ß Evaluate need for cleaning.ß Use water-based products.

Potassium hydroxide Boiler chemicals, cleaners ß Substitute cleaners without potassiumor sodium hydroxide.

ß Report all waste discharges to localauthority. Monitor and neutralizewastes.

Propane/isobutane Aerosol propellant ß use non-aerosols.Sodium hydroxide Boiler chemicals, cleaners ß Substitute cleaners without potassium

or sodium hydroxide.ß Report all waste discharges to local

authority. Monitor and neutralizewastes.

Sodium nitrite Corrosion inhibitor (boiler) ß Substitute alternative products

OTHER TIPS FOR HAZARDOUS CHEMICAL REDUCTION inFACILITIES/MAINTENANCE/ENGINEERING

Page 20: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

ß Implement First-In, First-Out policy. Use the oldest, usable product first to avoid having to dispose ofout-dated products.

ß Implement “just-in-time” purchasing.

ß Properly store materials to avoid contamination and extend the life of the product. Keep lids tight oncontainers to avoid spills and prevent rust or other contamination of product. Keep aerosol containers awayfrom moisture and light and avoid extreme hot or cold temperatures.

ß Consider implementing centralized inventory management system for department. This will reducepurchases of multiple products for similar functions and allow for the contents of a container to becompletely used before a new container is dispensed. This also decreases the amount of material that has tobe disposed because the chemical is out-of-date.

ß Buy products in bulk and returnable containers. Buying in bulk reduces the number of containers thathave to be disposed. However, don’t buy in bulk if all the material won’t be used up.

ß Ensure that all chemicals and wastes have been evaluated, labeled, segregated, stored and disposedof properly. Many hazardous chemicals used in engineering/maintenance are disposed of inappropriately viathe sewer. Hazardous chemical wastes are best disposed of through a hazardous waste facility. Hazardouswaste brokers can facilitate this process.

ß Purchase products such as paint only on an as needed basis. Purchase only the amount you need.

ß Purchase proper equipment for transferring chemicals. Properly designed and fitted equipment willreduce spills and having to dispose of material.

ß Eliminate products in aerosol cans. Most aerosol containers are flammable due to the propellants used inthem. Unless these containers are totally emptied of propellant and product, they are considered hazardouschemical waste. To completely empty an aerosol container, a special device must be used and the cancontents must be collected and managed as hazardous chemical waste. A much easier, safer and lessexpensive option is to use pump sprays. Pump spray bottles are frequently refillable allowing for bulkproduct purchase and reduction of solid waste volume.

BATTERIESß Use rechargeable batteries. Whenever possible, purchase products and equipment that come with rechargeable

batteries and battery recharger already installed. Most alkaline batteries still contain small amounts (0.025%) ofmercury and the thousands of batteries used by healthcare facilities contribute significantly to mercury pollution.The rechargeables that are pre-installed recharge while the product is plugged in.

ß Used Batteries come from:ß lead acid from diesel generators;ß emergency helicopters and vehicles;ß sulfuric acid from uninterruptible power supplies and vehicles;ß alkaline from pagers, flashlights and common electrical items;ß nickel-cadmium from alarm systems, equipment, computers, and backup power for medical monitors;ß mercuric oxide from hearing aids, smoke detectors, and monitors;ß lithium from glycometers and cameras;ß zinc-air from hearing aids and pagers

ß Minimize battery consumption through battery testing, monitoring usage, and inventory controlß Recycle lead acid and nickel-cadmium batteries.ß Dispose other used batteries as hazardous waste

Page 21: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

WASTE OILSß Used in lubrication, vacuum pumps, motors, etc. should be collected, segregated and recycled.

PESTICIDESß Apply good Integrated Pest Management practices. See Appendix H link for tips.ß Use non-chemical pest control methods where possibleß Select or specify the least toxic pesticide products when chemical pesticides are necessary,ß Minimize pesticide use to carefully controlled, spot applications and apply the minimum required quantitiesß Reduce pesticide inventories to just-in-time use amounts.ß Use natural weed control techniques.ß Use organic fertilizers such as compost..ß Use mechanical root control methods.

ß PAINTSß Use paints with high solid, low-volatile organic content and with no metal pigmentsß Use high transfer efficiency equipment such as electrostatic spray guns and high volume-low pressure

gunsß Reduce “over-spray” and use the minimum required coating thicknessß Practice low-volume cleaning techniques to minimize solvent use.ß Return expired painting material to suppliers.ß Replace oil-based or solvent-based paints with water-based (latex) paint. This will reduce Volatile

Organic Compounds (VOCs) emissions as well as eliminate the need of organic solvents (e.g., paint thinners,mineral spirits) for cleaning.

ß Purchase a paint gun washer instead of manually cleaning methods. Manually cleaning can generateexcess paint thinner. Washers can reuse the paint thinner thereby reducing the amount of paint thinnerpurchased and disposed.Filter and reuse paint thinner. Make sure that filtered material is disposed of properly. If the paintcontains heavy metals or if toluene or methylene chloride is present, the filtered material will require disposalas hazardous chemical waste.

Page 22: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

LABORATORY/PATHOLOGY/HISTOLOGY

This Chapter is designed to assist you in identifying and substituting or eliminating high priority laboratorychemicals that have been illuminated with the H2E Prioritization Tool. These chemicals are problematic withrespect to toxicity, regulatory status, and volume.

PRIORITYCHEMICAL

USE ELIMINATION/REDUCTION TIP

Acetone Solvent ß Micro-or small-scale tests to usesmallest amount possible.

ß Ensure that acetone wastes aremanaged as hazardous chemicalwaste. They should not be sewered.

Arsenic ß Test standardß In Cacodylate buffer

ß Micro-or small-scale tests to usesmallest amount possible.

ß Wastes containing arsenic may behazardous and should be managedas such. Do not sewer.

Chloroform Solvent for analytical tests, e.g. L/S Ratio, extractions

ß Use alternate method.ß Substitute non-chlorinated solventß Micro-or small-scale tests to use

smallest amount possible.ß Chloroform wastes are likely

hazardous chemical wastes. Ensureproper management and disposal.They should not be sewered!

Di-(ethylhexyl)phthalate (DEHP)

Blood bags and tubing ß Substitute non-PVC products.

Formalin(formaldehyde andmethanol)

FixativeOva and Parasite tests

ß Reuse the formalin to fix otherspecimens.

ß Substitute phenoxy, glyoxal or othercompounds.

ß Use smaller specimen containers.ß Use smallest amount possible e.g.

just enough to cover specimens.ß Distill formalin for re-use.ß Do not sewer. Manage as

hazardous chemical waste.ß Check with your local authority

regarding treatment of formalin.

Page 23: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

PRIORITYCHEMICAL

USE ELIMINATION/REDUCTION TIP

ß Mercury Test reagent

Reagent preservative: (see Mercurychapter for specifics)SalineHematoxylin and Eosin (H&E)stainZenker’s and B5 solutionsElectrodesPolyvinyl Alcohol (PVA)

ß Micro-or small-scale tests to usesmallest amount possible. Ensurethat all mercury-containing reagentsare managed as hazardous chemicalwaste..

ß Request substitute preservativefrom suppliers (methyl paraben orpropyl paraben can be used).

ß Sodium iodate can be substitutedfor the mercury-oxidizing agent inthe H&E stain.

ß Use non-metallic fixatives1.ß Use ion-selective electrode (ISE) for

analysis of chloride instead ofcolormetric method2

ß Mercury-free PVA for O& Ps isavailable.

ß See Mercury Chapter. link

Phenol Solvent/Extractions ß Use alternative solvent.Phenylmercuric acetate(PMA)(Mercury)

Preservative in reagents. ß Request substitute preservativefrom suppliers (methyl paraben orpropyl paraben can be used).

ß Micro-or small-scale tests to usesmallest amount possible. Ensurethat all mercury-containing reagentsare managed as hazardous chemicalwaste.

ß See Mercury Chapter.Propane/isobutane Aerosol propellant ß Use non-aerosols.Selenium Cysteine broth ß Use selenium-free.Sodium azide Preservative in reagents ß Request substitute preservative

from suppliers (methyl paraben orpropyl paraben can be used).

Sodium cyanidePotassium cyanide

Hemoglobin determinations ß Use alternate methodß Wastes may be considered

hazardous. Check with localauthority before sewering.

Thimerosal Reagent preservative ß See Phenylmercuric acetate above.ß See Mercury Chapter.

1 Palo Alto Regional Water Quality Control Plant, Pollution Prevention for Hospitals and Medical Facilities, California,1994.

2 Ibid.

Page 24: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

PRIORITYCHEMICAL

USE ELIMINATION/REDUCTION TIP

1,1,1 Trichloroethane(TCA)

Solvent ß Use alternate method.ß Substitute non-chlorinated solvent.ß Micro-or small-scale tests to use

smallest amount possible.ß TCA containing wastes are

hazardous. Ensure propermanagement and disposal.

Xylene Solvent ß Substitute limonene or citrus-basedsolvent.

ß Distill spent xylene or limonene.ß Xylene wastes are likely hazardous.

Ensure proper disposal ashazardous chemical waste.

OTHER TIPS FOR HAZARDOUS CHEMICAL REDUCTION in the LABORATORY

ß Stains: Many contain alcohol as a solvent making them ignitable. Some, such as diaminobenzidine (DAB)are known carcinogens. Others are mutagens or reproductive toxins. Stains would be best managed ashazardous chemical waste.

ß Stain slides with drops instead of using a dipping bath or install an automatic slide stainer.

ß Ensure that all chemicals and wastes have been evaluated, labeled, segregated, stored and disposedof properly. Many hazardous chemicals used in clinical laboratories are disposed of inappropriately via thesewer. Hazardous chemical wastes are best disposed of through a hazardous waste facility.

ß Evaluate Disinfection/Countertop Cleaning Practices. Are disinfectants being used appropriately? Arethe correct dilutions being used? Is the correct disinfectant being used? Is disinfection necessary? SeeAppendix G link for Disinfection Fact Sheet.

ß Eliminate products in aerosol cans. Most aerosol containers are flammable due to the propellants used inthem. Unless these containers are totally emptied of propellant and product, they are considered hazardouschemical waste. To completely empty an aerosol container, a special device must be used and the cancontents must be collected and managed as hazardous chemical waste. A much easier, safer and lessexpensive option is to use pump sprays. Pump spray bottles are frequently refillable allowing for bulkproduct purchase reducing solid waste volume as well.

ß Use rechargeable batteries. Whenever possible, purchase products and equipment that come withrechargeable batteries and battery recharger already installed. Most alkaline batteries still contain smallamounts (0.025%) of mercury and the thousands of batteries used by healthcare facilities contributesignificantly to mercury pollution. The rechargeables that are pre-installed recharge while the product isplugged in.

ß Eliminate odor masking and perfumes in products. Odor masking chemicals do not eliminate odor, theyonly mask it. Use of these products add chemicals to the indoor air. The best way to eliminate odors is toeliminate the source of the odor and to increase ventilation.

Page 25: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

ß Review manual methods. Can lesser amounts of solvents/reagent/patient sample be used? For someprocedures the amount of chemicals can be reduced significantly (halved or reduced by thirds) withoutcompromising precision and accuracy.

ß Substitute non-extraction methods or minimize extraction sample sizes for those that use solvents.See “manual method” tip above.

ß Eliminate non-value work. Some testing/work is done out of routine, not necessity. Eliminate duplicationof tests or those whose results are of little value to the clinician. Reduce the amount of media used on sterilecultures, limit the number of repeat tests that are performed, consolidate and batch tests.

ß Use albumin method that does not use chromium reagent2.

ß Use stool sample preservatives and total protein method reagent that do not contain copper3.

ß Use glucose test that does not contain zinc4.

ß Use trays with lips to carry bottles between storage and lab bench5.

ß Use selenium-free cysteine broth.

ß Share chemicals between laboratories.

ß Keep containers closed to prevent evaporation or spills.

ß Use proper equipment for transferring chemicals. Properly designed and fitted containers will reducespills and having to dispose of material. Consider controlled dispensing units.

ß Train employees on waste reduction, how to use equipment properly, and proper procedures.

ß Use products for cleaning glassware that do not contain chromic or sulfuric acid.

Implement First-In First-Out policy. Use the oldest, usable product first to avoid having to dispose ofout-dated products.

Replace radioactive tests and research kits with chemiluminescent or other non-radioactivealternatives.

Substitute short-lived isotopes for long-lived isotopes.

2 Palo Alto Regional Water Quality Control Plant, Pollution Prevention for Hospitals and Medical Facilities, California,1994.

3 Ibid.4 Ibid.5 Ibid.

Page 26: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

NUTRITION SERVICESThis Chapter is designed to assist you in identifying and substituting or eliminating high priority nutritionservices chemicals that have been illuminated with the H2E Prioritization Tool. These chemicals areproblematic with respect to toxicity, regulatory status, and volume.

PRIORITYCHEMICAL

USE ELIMINATION/REDUCTION TIP

AmmoniumHydroxide

Floor stripperFloor cleaner

ß Use products without ammoniumhydroxide.

Bleach Cleaning and sanitizing ß Review practices, use only wherenecessary.

Butoxyethanol Floor stripperFloor cleaner

ß Look for products that don’t containglycol ethers.

Ethanolamine Oven Cleaner/DegreaserFloor stripper

ß Use products that don’t containethanolamine.

Isobutane, n-butane,Propane

AerosolsPesticides

ß Carefully evaluate pesticide use, onlyuse when necessary.

ß Use Integrated Pest Managementpractices.

ß Use pesticides in pumps instead ofaerosol cans.

ß Make spot applications.Petroleum distillates Pesticides ß Use Integrated Pest Management

practices.ß Make spot applications.

Phosphoric acid SanitizerFloor cleaner

ß Avoid sanitizers containing phosphoricacid such as ethanol-iodine orquaternary ammonium sanitizers.

Potassium Hydroxide PresoakOven cleanerFloor cleaner

ß Clean up spills in oven immediately.

Sodium Hydroxide Oven Cleaner/DegreaserDetergent

ß Use less toxic detergents,cleaners/degreasers that don’t containsodium hydroxide.

ß Clean up spills in oven immediately.Sodium Metasilicate Presoak silverware

Floor stripperFloor cleanerDetergent

ß Use enzymatic presoak or presoakcontaining sodium carbonate.

ß Look for non-caustic alternatives.

OTHER TIPS FOR HAZARDOUS CHEMICAL REDUCTION in NUTRITION SERVICES

ß Use proper equipment for transferring chemicals. Properly designed and fitted containers will reducespills and having to dispose of material. Consider controlled dispensing units.

ß Implement “just-in-time” purchasing policy.

Page 27: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

ß Properly store materials to avoid contamination and extend the life of the product. Keep lids tight oncontainers to avoid spills and prevent rust or other contamination of product. Keep aerosol containers awayfrom moisture and light and avoid extreme hot or cold temperatures. 1

ß Buy products in bulk, concentrates, and returnable containers. Buying in bulk reduces the number ofcontainers that have to be disposed. Refills typically are more concentrated and usually require lesspackaging.

ß Review material safety data sheets (MSDS) for products being used. Many products have similaringredient lists. It may be possible to reduce the number of different type of products purchased and buymulti-functional products in bulk.

ß Look for products that are biodegradable.

ß Eliminate products in aerosol cans. Most aerosol containers are flammable due to the propellants used inthem. Unless these containers are totally emptied of propellant and product, they are considered hazardouschemical waste. To completely empty an aerosol container, a special device must be used and the cancontents must be collected and managed as hazardous chemical waste. A much easier, safer and lessexpensive option is to use pump sprays. Pump spray bottles are frequently refillable allowing for bulkproduct purchase reducing solid waste volume as well.

ß Eliminate odor-masking chemicals and perfumes in products. Odor masking chemicals do noteliminate odor, they only mask it. Use of these products add chemicals to the indoor air. The best way toeliminate odors is to eliminate the source of the odor and to increase ventilation.

ß Segregate waste. This allows for recovery, recycling, or may reduce the amount of waste that needs to bedisposed.

ß Train employees on waste reduction, how to use equipment properly, and proper procedures.

ß Implement First-In, First-Out policy. Use the oldest, usable product first to avoid having to dispose ofout-dated products.

ß Eliminate floor waxes and strippers containing zinc.

1 California Environmental Protection Agency, Pollution Prevention Guide for Hospitals, 1998.

Page 28: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

PHARMACY

This Chapter is designed to assist you in identifying high priority chemicals used in the pharmacy that havebeen illuminated with the H2E Prioritization Tool and either substituting less toxic chemicals or, in the caseof therapeutic agents, minimizing waste generation . These chemicals are problematic with respect to toxicity,regulatory status, and volume.

PRIORITY CHEMICAL USE ELIMINATION/REDUCTIONTIP

Cyclophosphamide Therapeutic Agent ß Work carefully whenpreparing to reduce waste.

Daunorubicin Therapeutic Agent ß Work carefully whenpreparing to reduce waste.

Di-(ethylhexyl) phthalate(DEHP)

Intravenous bags and tubingRespiratorytherapy/Gastrointestinal tubing

ß Substitute non-PVC products.

Epinephrine Therapeutic agent ß Ensure proper management ofexpired, unused and partiallyused drug.

ß Is considered a hazardouschemical waste when disposedof.

Lindane Lice & Scabies treatment ß Substitute permethrins,pyrethrins, crotamiton and/orfine toothed comb.

Mercury (as Thimerosal™)or phenylmercuric acetate

Preservative in nasal sprays,vaccines, contact lense solutions,insulin, thermometers.

ß Use single dose vials ortreatment units.

ß Work with purchasingdepartment to identify andpurchase vaccines that do notcontain mercury as apreservative.

ß Send letters to manufacturers,Group PurchasingOrganizations requestingmercury-free formulations.See Mercury Chapter link forexamples.

Nicotine Therapeutic Agent ß Reduce waste generation.Nitroglycerin Therapeutic Agent ß Reduce waste generation.Phenol Therapeutic Agent

Preservativeß Use alternatives for both active

ingredient or preservative,Propane/isobutane Aerosol propellant ß Use non-aerosols when

available.Selenium Trace Mineral Supplement ß Reduce Waste generation.Selenium sulfide Shampoos ß Use alternative when possible.Warfarin sodium Therapeutic Agent ß Reduce waste generation.

Page 29: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

WASTE MINIMIZATION AND TREATMENT RECOMMENDATIONSPharmaceutical waste can be generated anywhere in the hospital due to spills and breakage, but will mostlikely occur in the nursing units, surgery suites, emergency room and, most commonly, in the pharmacy itself.Pharmaceutical waste will occur in the following situations:

ß Breakage and spillsß Partially used syringes,1 vials, creams, ointments, liquidsß Compounding residues, especially during IV preparationß Outdated drugs, including samples, if not properly managed.ß Discontinued, unused preparationsß Unused re-packs (unit dosed items)ß Discontinued in-dated pharmaceuticalsß Patients personal medications

The Pharmacy Department is unique in the area of hazardous chemical waste minimization in that pharmacypersonnel usually do not have the option to select a less hazardous chemical, from a waste perspective, to getthe job done. However, clinicians can be alerted by the pharmacy of its efforts to decrease the mosthazardous chemicals and suggest efficacious substitutes for them. For example, in the treatment of head lice,malathion, (Ovide‚, Medicis‚) while still a relatively toxic chemical, is a safer prescription alternative tolindane.2 Safer still mechanical removal of lice and nits using a fine toothed comb. Usually, in mostapplications the therapeutic effectiveness must, of course, take precedence. Generally then, hazardous wasteminimization efforts in the Pharmacy Department must usually focus on waste reduction rather thansubstitution of a less toxic item. The following strategies can be employed to accomplish this goal.

Chemotherapy Waste Management• Much confusion exists around proper chemotherapy waste management. Check the waste acceptance

protocols of vendors offering “chemotherapy waste” containers. Most will accept only EMPTY vials,syringes and IV bags and paraphernalia, often known as “residue or trace” chemotherapy waste. Bulkchemotherapy waste, e.g. any remaining contents that could be removed by normal means, must beevaluated as a possible hazardous chemical waste and stored in a hard plastic container labeled“Hazardous Waste.” (see the Hazardous Chemical Waste Identification link section of this plan). Thiswaste should be disposed of with other chemically hazardous waste generated by the facility. SeeAppendix F link for identification of U-listed chemotherapy agents.

• Professional judgment also suggests that prudent risk management of non-listed but equally toxicchemotherapy agents would involve inclusion of these items in the chemical hazardous waste stream.Again, these wastes stream should not be confused with “red-bag” or infectious hazardous waste.

Improve inventory control.ß Determine min/max order points for each item stocked in the Pharmacy Department ensure that

inventory is purchased in appropriate quantities and used prior to expiration.

ß Purchase vials and similar items in the smallest available package size needed based on usage. Ifpharmaceuticals routinely expire due to the size of the carton available, notify your group purchasingorganization and request that they negotiate for more appropriate manufacturer packaging.

1 Syringes containing epinephrine, which are contaminated through patient contact, must be treated as regulated medicalwaste under the Blood Borne Pathogens Act.

2 Retail Pharmacy News, August 2000, p. 14.

Page 30: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

ß Rotate potentially hazardous waste such as epinephrine syringes out of emergency carts and into moreactive areas such as the Emergency Room or Operating Suites prior to outdating (three months or moredating is recommended for emergency carts).

Outdated Inventory Management.ß Routinely remove outdated pharmaceuticals from patient care areas including clinics through monthly

audits by pharmacy personnel.

ß Ship outdated pharmaceuticals to a qualified reverse distributor every three to five months. If outdatesare sorted at the pharmacy, non-returnable items become waste at the facility and must be managed assuch, thereby possibly increasing the hazardous waste generator status of the facility. The EPAconsiders an outdated drug to remain a product until the decision is made to discard it. At that time andplace, the product becomes a waste and must be managed as such1,2. Due to the constantly changingnature of manufacturers’ return policies, by shipping all outdates as product to the reverse distributor,maximum credit can be obtained for the pharmacy and the reverse distributor becomes the wastegenerator if the item cannot be returned to the manufacturer. The facility does have the responsibility ofchoosing a reverse distributor that understands the EPA regulations and complies with them.3

Mercury ReductionWhere possible, mercury-containing products should be eliminated. In the case of mercury-basedpreservatives, the use of single dose vials or treatment units may significantly reduce the number of productscontaining mercury. Manufacturers have begun reformulating vaccines and other preparations using otherpreservative agents and should be encouraged to continue their efforts. For more information on mercury,refer to the Mercury Chapter.

I.V PreparationWhenever possible, waste from I.V. preparation should be kept to a minimum by using the appropriate sizestock vial, especially when preparing chemotherapy or other highly toxic preparations. Spillage should bekept to a minimum by encouraging efficient compounding procedures.

Patient Care AreasNursing personnel should be alerted to the dangers of spills and breakage of highly toxic pharmaceuticals.Med carts and other dosage preparation areas should be kept free of loose vials and ampules to avoidbreakage. When breakage does occur, procedures should be in place to avoid personnel or patient exposureand to insure appropriate spill cleanup and waste management.

Patients’ Personal MedicationsMedications brought to the facility by the patient are the personal property of the patient and should bereturned to the patient or the patient’s representative at the time of discharge. If the prescription has beendiscontinued or dosage changed, information to that effect should be communicated to the patient withinstructions to dispose of the medication at the patient’s residence.

1 Letter from Alan Corson, Chief, Waste Characterization Branch, Hazardous and Industrial Waste Division, Office ofSolid Waste, USEPA, to Steven Wittmer, Merck, Sharp and Dohme, May 13, 1981.2 Letter from Sylvia Lowrance, Director Office of Solid Waste, USEPA, to Mark Schulz, Pharmaceutical Services Inc.,Browning Ferris Industries, May 16, 1991.3 “Guidelines for Reverse Distributors: Minimum Federal Regulatory Standards” is a publication available from theReturns Industry Association, 8000 Towers Crescent Drive, Suite 1350, Vienna, Virginia 22182, 703-847-3696,www.returnsindustry.com.

Page 31: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

RADIOLOGY

This Chapter is designed to assist you in identifying and substituting or eliminating high priority radiologychemicals that have been illuminated with the H2E Prioritization Tool. These chemicals are problematic withrespect to toxicity, regulatory status, and volume.

PRIORITY CHEMICAL USE ELIMINATION/REDUCTION TIPChromium Developer cleaners ß Chrome-free developer/cleaners

are available.Di-(ethylhexyl) phthalate(DEHP)

Intravenous bags and tubingRespiratorytherapy/Gastrointestinal tubing

ß Substitute non-PVC products.

Lead Film canisters/shieldsAprons

ß Recycle

Propane/isobutane Aerosol propellant ß Use non-aerosols.Radioactive isotopes Special imaging ß Substitute non-radioactive if

possible.ß Ensure compliance with all

regulations.Selenium Toner ß Use selenium-free toner.Silver Spent processor solution

x-ray filmß Dry film techniques are available.ß Don’t mix spent processing

solution with cleaning solution1.ß Central treatment of spent

processing solutions.1ß Recover silver for recycling.

OTHER TIPS FOR HAZARDOUS CHEMICAL REDUCTION in RADIOLOGY

ß Ensure that all chemicals and wastes have been evaluated, labeled, segregated, stored and disposedof properly. Many hazardous chemicals used in healthcare are disposed of inappropriately via the sewer.Hazardous chemical wastes are best disposed of through a hazardous waste facility. A hazardous wastebroker can facilitate this process.

ß Extend the life of fixing baths by2:ß Adding ammonium thoisulfate,ß Using an acid stop bath prior to fixing, andß Adding acetic acid to lower pH.

ß Cover developer and fixer containers to reduce evaporation and oxidation3.

Use countercurrent washing4.

ß Implement “just-in-time” purchasing.

ß Use squeegees to remove excess chemicals from film.

1 San Francisco, Bay Guide2 U.S. EPA, Sector Assessment.3 Ibid.

4 Ibid.

Page 32: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

ß Use circular fluorescent tubes for view boxes instead of four fluorescent tubes5.

ß Segregate waste. This allows for recovery, recycling, or may reduce the amount of waste that needsto be disposed.

ß Train employees on waste reduction, how to use equipment properly, and proper procedures.

ß Implement First-In, First-Out policy. Use the oldest, usable product first to avoid having todispose of out-dated products.

ß Establish standard chemical mixing procedures.

ß Work with vendors so that only one developer and fixer are needed for black and whitedeveloping.

ß Purchase developer and fixer in freeze-dried packages.

ß Routinely check processing times and temperatures.

ß Use up out of date chemicals if they are still effective.

ß Use a developer that can be replenished.

ß Use developers that do not contain hydroquinone.

ß Check with vendor to see if equipment can be retrofitted with water saving and rinse waterrecycling features.

ß Upgrade to digital radiology.

ß Use cation exchange, electrolytic recovery and steel wool filtration to maximize silverrecovery from film processing. Make sure equipment is tested to ensure maximum recovery.

ß www.silvercouncil.org has more information regarding equipment maintenance, silver recovery andwaste reduction.

5 Minnesota Office of Environmental Assistance.

Page 33: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

STERILE PROCESSING

This Chapter is designed to assist you in identifying and, substituting or eliminating high priority sterileprocessing chemicals that have been illuminated with the H2E Prioritization Tool. These chemicals areproblematic with respect to toxicity, regulatory status, and volume.

PRIORITY CHEMICAL USE ELIMINATION/REDUCTIONTIP

Di-(ethylhexyl) phthalate (DEHP) Intravenous bags and tubingRespiratorytherapy/Gastrointestinal tubing

ß Substitute non-PVC products.

Ethylene oxide (EtO) Equipment sterilization ß Hydrogen peroxide or othersterilization systems areavailable.

ß Autoclave if possible.ß Ensure equipment is

functioning properly.ß Seal all leaks.ß Neutralize ethylene oxide

before disposal.ß Sterilize full loads—place

empty containers or bricks oncarts to displace EtO usingless.

ß See Ethylene Oxide Chapter.Glutaraldehyde Equipment sterilization ß Substitute hydrogen

peroxide/peracetic acidsterilants1

Propane/isobutane Aerosol propellant ß Use non-aerosols.

OTHER TIPS FOR HAZARDOUS CHEMICAL REDUCTION in STERILE PROCESSING

Ensure that all chemicals and wastes have been evaluated, labeled, segregated, stored and disposedof properly. Many hazardous chemicals used in sterile processing are disposed of inappropriately via thesewer. Hazardous chemical wastes are best disposed of through a hazardous waste facility.

Train employees on waste reduction, how to use equipment properly, and proper procedures.

Implement First-In, First-Out policy. Use the oldest, usable product first to avoid having to dispose ofout-dated products.

Implement “just-in-time” purchasing. Buy only the amount you need.

1 Although hydrogen peroxide/peracetic acid (HP/PAA) sterilants have also been identified as priority chemicals, the occupationaland environmental hazards associated with HP/PAA are less than those of formalin (formaldehyde and methanol) are andglutaraldehyde.

Formaldehyde is considered a carcinogen by the National Toxicology Program (NTP). The OSHA permissible exposure limit (PEL)Time Weighted Average (TWA) = 0.75 ppm. The NIOSH (National Institute of Occupational Safety and Health) exposure limit islower (0.3 ppm). Formaldehyde is an environmental hazard due to its persistence in waste waters and aquatic toxicity (Handbook ofEnvironmental Date on Organic Chemicals, 2nd Ed. 1983).

Glutaraldehyde is considers a suspect carcinogen by the NTP. Its OSHA PEL = 0.2 ppm. Because it too, is an aldehyde,glutaraldehyde is likely to be persistent and toxic in aquatic environments.

Page 34: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

SURGICAL SERVICES

This Chapter is designed to assist you in identifying and-substituting or eliminating high priority surgicalservices chemicals that have been illuminated with the H2E Prioritization Tool. These chemicals areproblematic with respect to toxicity, regulatory status, and volume.

PRIORITY CHEMICAL USE ELIMINATION/REDUCTIONTIP

Dibutyl phthalate Plasticizer in floor waxes, nailpolish remover

ß Purchase products withoutdibutyl phthalate.

Di-(ethylhexyl) phthalate(DEHP)

Intravenous bags and tubingRespiratorytherapy/Gastrointestinal tubing

ß Substitute non-PVC products.

Formalin (formaldehyde andmethanol)

Fixative ß Substitute phenoxy, glyoxal orother compounds.

ß Use smaller specimencontainers.

ß Use smallest amount possiblee.g. just enough to coverspecimens.

ß Distill formalin for re-use.ß Do not sewer! Manage as

hazardous chemical waste.ß Treating or neutralizing

formalin wastes may require apermit from the EPA.

Mercury ThermometersSphygmomanometersElectrodesBarometersCantor tubesBougie devicesOther, see Mercury Chapter

ß Request substitute equipment.ß See Mercury Chapter. link

Hexachlorophene Germicidal soaps and detergents ß Substitute products withouthexachlorophene.

Hexylene glycol Germicidal detergents ß Substitute products withouthexylene glycol or other glycolethers.

ß Assess need to use germicidaldetergent.

Phenol Disinfectant ß Peroxy (hydrogenperoxide/peracetic acid)disinfectants are efficaciousagainst spores and tuberclebacteria.

ß Ensure equipment iscompatible with peroxydisinfectants.

Page 35: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

Peroxyacetic acid (Steris ®) Cold sterilant ß Use smallest amountnecessary.

ß Ensure proper disposal,possibly as hazardouschemical waste if pH < 2.5.

Propane/isobutane Aerosol ß Substitute non-aerosolsSodium hydroxide Defoamer ß Use alternative product

without caustic.1,2,2-trichlorethane Aerosol cleaners ß Substitute similar product

without chlorinatedhydrocarbon solvents.

OTHER TIPS FOR HAZARDOUS CHEMICAL REDUCTION in SURGICAL SERVICES

ß Eliminate products in aerosol cans. Most aerosol containers are flammable due to thepropellants used in them. Unless these containers are totally emptied of propellant and product,they are considered hazardous chemical waste. To completely empty an aerosol container, aspecial device must be used and the can contents must be collected and managed as hazardouschemical waste. A much easier, safer and less expensive option is to use pump sprays. Pumpspray bottles are frequently refillable allowing for bulk product purchase and reduction of solidwaste volume.

ß Use rechargeable batteries. Whenever possible, purchase products and equipment that comewith rechargeable batteries and battery recharger already installed. Most alkaline batteries stillcontain small amounts (0.025%) of mercury and the thousands of batteries used by healthcarefacilities contribute significantly to mercury pollution. The rechargeables that are pre-installedrecharge while the product is plugged in.

ß Use low-leak anaesthetic equipment (e.g., scavenging equipment).

ß Reduce the number of products that have similar ingredients: purchase products withmultiple functions such as multi-purpose cleaners.

ß Use controlled dispensing units for chemicals.

ß Segregate waste. This allows for recovery, recycling, or may reduce the amount of waste thatneeds to be disposed.

ß Train employees on waste reduction, how to use equipment properly, and proper procedures.

ß Implement First In First Out policy. Use the oldest, usable product first to avoid having todispose of out-dated products.

ß Implement “just-in-time” purchasing. Buy only the amount you need.

Page 36: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

ACKNOWLEDGEMENTS

H2E wishes to thank the following individuals, associations and corporations for their extensive andthoughtful written contributions to this chapter.

John AllmanBJC HealthcareSt. Louis, MO

Mitch Blackman, RPhCapital Returns, Inc.Milwaukee, WI

Stephanie Busch, CoordinatorGeorgia Pollution Prevention ProgramAtlanta, GA

Cindy Johnson, Technical SupervisorBiochemical Genetics LabFairview-University Medical CenterMinneapolis, MN

Susan McLaughlin, DirectorAmerican Society for Healthcare Engineering(ASHE)Chicago, IL

Charlotte Smith, RPh, MSCapital Returns, Inc.Milwaukee, WI

Chen WenOffice of Pollution Prevention and ToxicsUS Environmental Protection AgencyWashington, DC

Catherine Zimmer, MS, ChairH2E Chemical Minimization WorkgroupThe Minnesota Technical Assistance Program(MnTAP)Minneapolis, MN

Page 37: Chemical Minimization Plan - Practice Greenhealth

Chemical Minimization Plan -39-

H2E wishes to thank the following individuals, associations and corporations for providinginformation for this chapter:

Harold CharlesOffice of Solid WasteUS Environmental Protection AgencyWashington, DC

Lynn EddyMLE Management ConsultingSouthboro, MA

Jorge Emmanuel, PhD, PE, CHMMEnvironmental Engineering and Research GroupRodeo, CA

Bill EricksonSt. Joe’s HospitalBrainerd, MN

Eugene Lau, CIH, CSP, CHMM, REHSUniversity of California, San FranciscoSan Francisco, CA

Amy Nichols, RN, BSN, CICAlta Bates Medical CenterBerkeley, CA

Michele PlanteNew England Medical CenterBoston, MA

Paul Reimer, Industrial HygienistNorth Colorado Medical CenterGreeley, CO

Pierre-George ZanoniMetropolitan HealthcareGrand Rapids, MI