c II

LEAD, CADMIUM AND MERCURY IN HOSPITAL SOLID WASTE: A SCOPING STUDY

Prepared for: The Northeast Waste Management Officials’ Association

(NEWMOA)

Project Manager: Terri L. Goldberg

Pollution Prevention Program Manager

Researchers and Writers:

Melissa K W i n d e r Nancy A. Thornton

Barry C. O’Melia Susan D. Henderson

David k Ferenz Advisor, David M. Gute, PbD., M.P.H.

July 1992

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c.

LEAD, CADMIUM AND MERCURY IN HOSPITAL SOLID WASTE: A SCOPING STUDY

In partial fulfillment of the Master of Science Degree requirements Department of Civil Engineering

Hazardous Materials Management Program Tufts University

Prepared for: The Northeast Waste Management Officials’ Association (NEWMOA)

85 Merrimac Street Boston, MA 02114

(617) 367-8558

Project Manager: Terri L. Goldberg

NEWMOA Pollution Prevention Program Manager

By: Melissa K. Winzeler Nancy A. Thornton Barry C. O’Melia

Susan D. Henderson David A. Ferenz

Advisor, David M. Gute, Ph.D., M.P.H.

July 1992

Trinfd a Qsychf Taper

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NEWMOA

The Northeast Waste Management Officials’ Association (NEWMOA) is a non- profit interstate governmental association whose membership is composed of the hazardous and solid waste program directors in Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York (hazardous waste only), Rhode Island and Vermont. NEWMOA was established by the New England Governors as an interstate regional organization and, in accordance with Section 1005 of the Resource Conservation and Recovery Act, has been formally recognized by the U. S. Environmental Protection Agency. NEWMOA is a forum for increased communication and cooperation among the member states, a vehicle for the development of unified positions on various issues and programs, and a source of research and training on hazardous and solid waste management and pollution prevention. NEWMOA works on a wide variety of issues including: hazardous waste capacity assurance planning; tires, demolition debris, white goods, and incinerator ash solid waste management; source reduction of heavy metals in municipal solid waste; and industrial pollution prevention. NEWMOA is supported entirely by state and EPA funding.

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For further information on NEWMOA activities call or write: NEWMOA, 85 1 Merrimac Street, Boston, MA 02114; (617) 367-8558.

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DISCLAIMER

This project was supported by a grant from the U.S. Environmental Protection Agency (EPA) and the NEWMOA member states. The views expressed in this report do not necessarily reflect those of EPA or the NEWMOA member states. Mention of any company, process or product name should not be considered as an endorsement by NEWMOA, any of its member states, or the U.S. EPA.

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TABLE OF CONTENTS

CHAPTER PAGE

LIST OF TABLES ACKNOWLEDGEMENTS EXECUTIVE SUMMARY

CHAPTER 1: INTRODUCTION

PURPOSE REPORT ORGANIZATION POTENTIAL HEALTH EFFECTS CATEGORIES OF WASTE

V

vi vii

CHAPTER 2: LEAD, CADMIUM AND MERCURY IN SOLID WASTE

LEAD 6 CADMIUM 8 MERCURY 10 POSSIBLE SOURCES OF TARGET METALS IN HOSPITAL WASTE 13

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CHAPTER 3: HOSPITAL CASE STUDY

INTRODUCTION METHODOLOGY METAL SOURCES AND CONTENT WASTE GENERATION AND DISPOSAL CURRENT RESEARCH RECOMMENDATIONS

CHAPTER 4: REGULATORY REVIEW

U.S. REGULATIONS STATE REGULATIONS IN THE NORTHEAST EUROPEAN REGULATIONS JAPANESE REGULATIONS SUMMARY

18 19 21 24 28 30

33 36 43 45 46

... 111

I

TABLE OF CONTENTS (continued)

CHAPTER

CHAPTER 5: OPTIONS AND FUTURE STUDIES

OPTIONS FOR ACTION

REFERENCES CONTACTS

PAGE

48

i 52 65

iv

, , . _-.~.. .I,.- .

LIST OF TABLES

TABLE

2- 1

2-2

2-3

2-4

2-5

2-6

3-1

3-2

3-3

4- 1

Household Sources of Lead in Municipal Solid Waste

Household Sources of Cadmium in Municipal Solid Waste

Household Sources of Mercury in Municipal Solid Waste

Discontinued Uses of Mercury

Products Containing Lead and Cadmium to Investigate During The Hospital Case Study

Products Containing Mercury to Investigate During The Hospital Case Study

Summary of Purchasing Records

Lead from X-Ray Shields

Estimated Lead, Cadmium and Mercury in Case Study Hospital Waste

Summary of Selected State Lead, Cadmium and Mercury-Related Laws

V

PAGE

7

9

12

14

16

17

20

25

27

47

. . . "

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ACKNOWLEDGEMENTS

This report includes a case study of a Boston-area hospital. The case study hospital has been assured confidentiality, so we cannot cite individual contributions. However, we would like to acknowledge the contributions of the case study hospital especially the purchasing department for their legwork and effort involved in obtaining hospital purchasing and use information.

Also, we would like to acknowledge Terri Goldberg of NEWMOA for supplying personal contacts, background information, and helpful comments. A special thank you is due Russel Briggs who volunteered his graphic expertise to develop the charts used at the presentation of the project.

We would like to acknowledge the following individuals for reviewing and providing helpful comments on a draft of this study: Carole Ansheles, Austine Frawley, Cynthia Greene, Dennis Lucia, Sally Mansur, and Sharon Yergeau.

Last, but certainly not least, we would like to thank Dr. David Gute, in special appreciation for his editing from the stratosphere. Above all, we thank him for all of the encouragement and support.

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1 3 s P I I 5 \I Y I I I I 1 1 1 I 1 I

LEAD, CADMIUM AND hfERCURY IN HOSPITAL SOLID WASTE: A SCOPING STUDY

Executive Summary

State officials in the Northeast are concerned about lead, cadmium and mercury in solid waste due to their toxicity and volume. Previous studies have focused on the presence of lead, cadmium and mercury (the target metals) in the household waste stream. Little research exists on the target metals in wastes from commercial facilities, such as hospitals. This report examines the contribution of products containing these metals from hospitals. Because the target metals have not been extensively studied in hospital solid waste, this project was designed to be a scoping study.

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c 1 i I li

1 1

This scoping study used available national information on lead, cadmium and mercury from household sources as a starting point. The background information indicated that batteries represent the largest potential source of the target metals from households. Batteries are projected to remain the largest single source of these metals into the next century despite manufacturers’ phase-outs of mercury in alkaline batteries and recycling of lead-acid batteries (EPA 1989 and EPA 1992).

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In order to understand the potential sources of the metals in hospital solid waste (HSW), a Boston-area hospital was recruited to serve as a case study. The data available from the case study hospital showed that lead shielding is potentially the main source of lead in the hospital’s solid waste. The case study hospital was not able to quantify the sources of cadmium. Alkaline batteries and medical mercury thermometers were identified as the main sources of mercury. identified in the case study hospital’s solid waste was estimated to bc approximately 113 pounds per year. This study was unable to evaluate such other potential sources of the lead and mercury as printed circuit boards, CAT scan film, and x-ray film.

The total quantity of I C . -i and mercury

Several of the sources of the target metals identified in case study hospital’s waste should be managed as hazardous waste, according to the referenced federal and state regulations. These are the sources of the metals that fail EPA’s toxicity characteristic leaching procedure (TCLP). Current practice indicates, however, that they are being disposed of in municipal solid waste facilities. This is a regulatory dilemma that hospitals and environmental agencies should address. 1

The study recommends that hospitals reduce the target metals content of their solid wastes through various pollution prevention and recycling initiatives. These could include: developing a pollution prevention policy; establishing a PP committee to develop and implement source reduction and recycling initiatives; collecting information on the target metals content of various products used by the hospital; educating hospital staff in pollution prevention techniques; centralizing purchasing to enable the hospital to identify

vii

opportunities for product substitution; substituting products that do not contain the target metals where possible; separating target metal-containing products from other wastes for reclamation; using suppliers that accept used products for recycling; identifying markets for the separated materials; and collaborating with other hospitals to exert pressure on suppliers and manufacturers to reduce the heavy metals contents of products used by medical institutions. A number of state legislative and regulatory initiatives support and complement these types of private programs.

In recent years state legislatures and regulatory agencies have focused on reducing and recycling the amount of the target metals entering the solid waste stream. All of the states in the Northeast, except Massachusetts, have passed laws requiring manufacturers to reduce the amount of the target metals in packaging. In addition, four of the Northeastern states have passed laws requiring manufacturers to reduce the amount of mercury in household batteries. These programs should result in reductions in the emissions of the target metals from municipal solid waste facilities.

State and federal environmental agencies have other options for reducing the amount of lead, cadmium and mercury in hospital solid waste. These include (1) phase- outs of the target metals in products in addition to packaging and batteries, (2) additional research on sources of heavy metals in hospital wastes, (3) educational programs to make consumers of products containing the target metals aware of their hazards, (4) reliance on market forces to lead manufacturers to reduce the target metals in their products because of buyers’ concerns about the high cost of disposal, and (5) development of comprehensive regulations on management of solid waste by hospitals. These options complement each other and each of them requires further definition and analysis. States and EPA should examine their feasibility and effectiveness to determine which options can cost effectively reduce the target metals in hospital solid waste. Finally, the authors recommend that an expanded, more detailed study be conducted in order to evaluate the contribution of the target metals to solid waste from hospitals on a regional and national basis.

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CHAPTER 1

INTRODUCTION

PURPOSE

State and federal agencies are concerned about lead, cadmium and mercury in solid waste due to their toxicity and concentrations. States are interested in reducing these metals in incinerator emissions and ash and landfill leachate. This report examines the contribution of products containing these metals from hospital solid waste to the municipal solid waste (MSW) stream.

Hospitals are an important industry in the Northeast. They provide essential services for the health and welfare of communities. They also produce a variety of waste streams because of the range of their services. Reducing and managing waste is a challenge for hospitals and state environmental agencies. State officials suspect that hospital and other institutional and commercial sources may contribute to the presence of

- . toxic metals in incinerator emissions and ash and MSW landfills. However, environmental agencies have not studied these sources extensively. Therefore, this project was designed to be a scoping study of potential sources of lead, cadmium and mercury (the target metals) in hospital solid waste (HSW).

REPORT ORGANIZATION

This report is presented in five chapters as follows:

Chapter 1 describes health concerns regarding lead, cadmium, and mercury and their fate in the environment to provide the reader with a brief summary of some of the literature. The chapter also provides a description of the regulatory classification of wastes.

Chapter 2 identifies and quantifies sources of lead, cadmium and mercury in municipal solid waste from households and identifies some potential sources in HSW. The researchers use data on sources of the target metals from households as a starting point since data regarding metals in HSW are not available.

Chapter 3 identifies and estimates some sources of lead, cadmium and mercury in hospital solid waste. To identify these sources of the target metals, the researchers conducted a case study of a Boston-area hospital. This chapter also suggests source reduction and recycling practices available to hospitals.

Chapter 4 provides a survey of U.S. federal and state legislation and regulations that affect HSW, including those concerning hazardous waste, air quality and source reduction initiatives. This examination also includes a description of some regulatory initiatives undertaken by European countries and Japan.

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Chapter 5 presents options for the reduction and proper management of the target metals in HSW.

The report ends with a bibliography and list of contacts.

POTENTIAL HEALTH EFFECTS

The impetus for this project was concern about potential adverse health effects resulting from human exposure to the target metals in HSW. The following sections briefly describe the potential health effects associated with the target metals and possible exposure pathways.

HEALTH EFFECTS

Heavy metals can exert a broad range of toxic effects. The most well documented r _ are the non-carcinogenic effects to the neurological, hepatic, renal, and hematopoietic

systems (Denison, 1988). Due to their stability, the target metals can accumulate in the environment and bioaccumulate in the body. Therefore, human exposure even at low levels over an extended period of time can have adverse impacts.

Low level lead exposure can result in neurological damage, particularly in young children. Exposure to high levels of lead can lead to abdominal cramps, headaches, loss of appetite, anemia, and motor-nerve paralysis. Children exposed to high levels of lead may experience encephalopathy and repressed neurodevelopment (Clayton, 1981).

Acute exposure to cadmium can occur through inhalation or ingestion. When inhaled at high levels, cadmium can cause severe pulmonary irritation, and when ingested at high levels the metal can irritate the gastrointestinal tract. Cadmium may accumulate in the body resulting in chronic exposure and possible damage to the kidneys (Waalkes, 1991).

Mercury exposure can be associated with neurological, kidney and immune system damage. Most of these effects can result from chronic occupational exposures. Death can result from acute exposures to high concentrations of inorganic mercury (ATSDR, December 1989). Fetal exposure to even low concentrations of mercury can be associated with delayed development (Murdock, 1990).

EXPOSURE PATHWAYS

Hospitals currently manage such metal containing wastes as spent batteries and electronic equipment by landfilling and incineration. This section briefly explores

2

possible routes of exposure during these waste management practices. In general products used by hospital are not recycled.

I Incineration

Approximately 70 percent of the U.S. biomedical waste stream is incinerated on- site and another roughly 15 percent is incinerated at regional facilities. This represents I roughly ten percent on a mass basis of the solid waste incinerated in the U.S. (Glasser et al. 1991). I

Incinerators do not destroy heavy metals. Incineration can volatilize heavy metals which condense onto the surface of fly ash or are emitted from the stack. For example, the Agency for Toxic Substances and Disease Registry (ATSDR) reports that incinerator stacks may emit cadmium if proper pollution control devices are not in place (ATSDR, March 1989). Although fly ash can be efficiently removed from modern MSW incinerators, most hospital incinerators do not have air pollution control equipment (Brunner, 1988). Biomedical waste incinerators using current incineration technologies may not meet the performance criteria for metals emissions that several states have proposed (Lee, 1991).

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I 1 1 I I I

I r..

The particles from incineration are usually under ten microns in diameter, and they can easily be ingested or inhaled (Denison, 1988). Exposure may occur through ingestion after the airborne metals have deposited onto crops, soils, and surface waters. Some studies have shown that this deposition route may be many times higher than exposure to airborne metals (Denison, 1988).

Incinerators concentrate lead and cadmium in bottom ash (Denison, 1988) (Lee, 1991). Bottom and fly ash is ultimately disposed in a landfill, where it can continue to pose a threat to the environment and human health. Contaminated leachate can form from landfilled incinerator ash and can enter groundwater and surface water. Exposure can occur through ingestion of the water, contact during agricultural irrigation, consumption of irrigated food or recreational activities. Exposure during recreational activities can occur through eating contaminated fish and other aquatic organisms caught in the contaminated water, direct ingestion of the water, or dermal contact (Clark, 1989).

A recent analysis of air emissions from biomedical waste incinerators found

i

elevated levels of the target metals. This study reported that these incinerators are often located in heavily populated areas and have comparably higher target metals emissions per unit volume of waste than other incinerators. The study concluded that the risks from emissions from biomedical waste incinerators are at least comparable to hazardous or municipal waste incinerators (Glasser et al. 1991).

Under the Clean Air Act Amendments of 1990, EPA will be proposing New Source Performance Standards (NSPS) for emissions from new medical waste combusters

3

and emissions guidelines for existing ones. Lead, cadmium and mercury and other toxic pollutants are among those that the Agency plans to regulate. The NSPS should reflect the maximum achievable control technology (MACT) while the guidelines may be equal to or less than the NSPS.

Landfilling

The metal leaching capability of hospital wastes disposed in MSW landfills has not been assessed; however, researchers are investigating this subject (Rathje, 1991). There is evidence of lead and cadmium in leachate from MSW landfills exceeding drinking water standards (MIT, 1990). There is no source data available to correlate this leachate with any particular components of solid waste.

Plants grown in soil that is contaminated either through ash deposition or leachate may take the metals into their root system (Desmarais, 1990). Contaminated crops may be ingested directly by humans or indirectly through animals used for meat and milk production who ingest the crops. Lead is more able to translocate into cow’s milk than cadmium and mercury (Stevens, 1991). r . -

Workers in close contact with solid waste and incinerator ash can be exposed to the target metals during their handling, treatment, and transportation. This may be a route of exposure that can be readily controlled by the use of personal protective equipment or through such other interventions as substitution and/or removal from the waste stream.

CATEGORIES OF WASTE

This study focuses on solid waste generated by hospitals. Hospital solid waste is considered to be a component of commercial solid waste. Commercial solid waste (CSW) combined with household solid waste make up municipal solid waste. The United States produced approximately 160 million tons of MSW in 1988 (EPA, February 1989). EPA and states may differ in their regulatory definitions of these various types of waste. However, this report uses such terms as hospital, commercial and municipal solid waste as they are commonly understood.

For the purposes of this study, CSW is defined as solid waste generated by establishments that are commercial in nature (DEP, 1990). Commercial establishments include wholesalers and retailers of merchandise, financial services firms, hotels, personal and business services firms, amusement and recreational facilities, medical and health services organizations and non-profit organizations. Hospital solid waste is a component of commercial solid waste. Hospitals in Massachusetts account for approximately three percent of the total CSW generated. A study of CSW in Kentucky found that medical and health services accounted for approximately four percent of their commercial solid

4

waste (Kentucky (University of Kentucky IIR, 1970). Hospitals can also generate hazardous and infectious wastes.

CSW significantly contributes to the MSW stream in the Northeast and other highly urbanized regions. In Massachusetts, CSW represented approximately 5 1 percent of the total annual MSW. If the percent contribution of CSW to MSW in Massachusetts is similar to other states, CSW is a major source of MSW across the country. However, CSW has received relatively little research attention as compared with waste generated by households.

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CHAPTER 2

LEAD, CADMIUM AND MERCURY I N SOLID WASTE

This chapter explores the houschold products that contain the target metals to provide insights into where these met: - may appear in HSW. The authors use information on household sources to 1 get their investigation of potential hospital sources. HSW may differ from MSW in the relative amount of various materials; however, it contains many of the same types of waste (Hickman, 1987). For example, HSW usually contains 20 percent plastics as compared with 7 percent in household waste (Doyle, 1985).

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The sources of heavy metals in solid waste described in this chapter are based upon studies that use the EPA material flow methodology to calculate household sources of solid waste (EPA, 1991). This methodology uses production data adjusted for imports,

c-. exports and recycling. However, EPA's disposal estimates may be high because short lifetime products (e.g. alkaline batteries) are assumed to be discarded in the same year that they are produced.

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- . LEAD

I Table 2-1 shows the relative quantities of lead contributed by major categories of household discards to the MSW stream for 1986 (EPA, 1989). The Table shows that batteries (primarily lead-acid batteries) are the largest source of lead. Approximately one-half of the lead-acid battery is lead or lead components. Trends indicate that in the immediate future the volume of lead-acid batteries in MSW should increase (EPA, 1989).

A recent study reports that 60 to 90 percent of lead-acid batteries are being recycled (EPA, 1990). However, these studies also reported that industrial and portable batteries have a recycle rate of 0 and 25 percent respectively. This indicates that battery recycling by consumers is more widespread than by industry (EP41989).

I I 1 Consumer electronics are the second largest source of lead in MSW in household

discards. According to EPA, the contribution of lead from electronic appliances to solid waste may increase over the next several years due mainly to an increase in discards of televisions (EPA, 1989).

Glass and ceramics contributed less than five percent by weight of the lead discards in 1986 (EPA, 1989). Leaded glass has a lead content that ranges from two percent in television face plates to 82 percent in radiation shield glass. Enamels and

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6

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Ca tepary

Batteries

Table 2-1

HOUSEHOLD SOURCES OF LEAD IN MUNICIPAL SOLID WASTE (EPA 1989)

Electrical & Electronic Devices

-- ~

Glass & Ceramics

Plastics

Pigments

Others

Products

Cars, buses, motorcycles, golf carts, fork lifts, wheel chairs, & portable equipment

Lead solder in televisions, radios, & VCRs & leaded glass in televisions

Glass containers, tableware, cookware, optical glass, & radiation shields

Sporting and recreational items, footware, handbags, luggage, credit cards, floppy disks jackets, shower curtains, window shades, blinds, awnings & garden hoses

Paints, printing inks & textile dyes

Leaded solder in cans, light bulbs, brass & bronze products, rubber products, used oil, collapsible tubes, & lead foil wrappers

Percent By Weight

65

27

3

I

J 4

1

2

0.5

1.5

7

. .. . . .~ _r . . ~ ... . I.

glazes applied to glass for decorative and labeling purposes typically contain roughly 50 percent lead oxide respectively (EPA, 1989).

Plastics accounted for a small percentage of lead discards in 1986. EPA reports that plastics containing lead in solid waste may increase slightly over the next several years due to increasing regulation of lead in certain products, such as toys and furniture (EPA, 1989).

Pigments used in paints, printing inks and textile dyes account for less than one percent by weight of lead discarded by households. According to EPA, lead-containing pigments may decrease in the future due to regulation of lead in paints (EPA, 1989).

Other sources of lead account for slightly more than one percent by weight of lead discarded by households as shown in Table 2-1. Of these products, only light bulbs may increase over the next few years (EPA, 1989).

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CADMIUM

Table 2-2 presents the relative contributions of different household products that contain cadmium to MSW (EPA, 1989). Nickel-cadmium (NiCd) batteries rank first among the household products that contain cadmium that enter the solid waste stream. According to EPA their contribution is expected to increase over the next several years. Unlike lead-acid batteries, there is no significant consumer recycling of NiCd batteries in the U.S. (EPA, 1989).

Silver-cadmium batteries are also used in portable televisions, cameras, medical electronics, and other instrumentation that require high energy density and constant voltage. According to EPA, this battery does not contribute significant amounts of cadmium to solid waste in comparison to NiCds (EPA, 1989).

Plastics are the next largest household contributor of cadmium to MSW. As with lead, this is attributable to cadmium's use as a stabilizer, primarily in polyvinyl chloride (PVC), and as a pigment. Cadmium-containing pigments include cadmium yellow, cadmium red, and cadmium-mercury red. Trends indicate that the amount of plastics that contain cadmium and discarded in MSW facilities may decrease over the next several years due to regulations of cadmium use in such products as toys and furniture (EPA, 1989).

Cadmium was historically used to plate television and radio chassis, but this practice became obsolete with the advent of the printed circuit board in the 1980s. In 1986, this source accounted for nine percent by weight of the cadmium discarded by

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Table 2-2

HOUSEHOLD SOURCES OF CADMIUM IN MUNICIPAL SOLID WASTE (EPA 1989)

Category Products

NiCd Batteries

r . -

Plastics

Rechargeables used in calculators, hand-held tools, flashlights, hand- held vacuums, electric shavers, alarm systems, lap-top computers, cellular phones, televisions, camera lighting, portable hospital equipment, & pinball machines

Stabilizers & pigments in non-food packaging, misc. durables, app- liances, misc. non- durables, furniture, & toys

Electrical & Electronic Devices radio chassis

Plate television and

Pigments Printing inks, textile dyes, & paints

Glass and Ceramics Yellow-orange light bulbs; photochromic glass; metal sealing solders & microsphere optics; pottery; & glass soft drink, beer & cosmetic bottles

Others Appliances, rubber products, used oil, electric blankets, & heating pads

9

Percent Bv Weight

52

28

9

4

2

5

households. Trends indicate that this source may continue to decrease over the next several years (EPA, 1989).

Pigments used in printing inks, textile dyes and paints accounted for less than five percent by weight of cadmium present in the solid waste stream in 1986. Trends indicate that this source may be fairly constant for the next several years. Similar to lead pigments, cadmium pigments are found in many applications. Cadmium-containing pigments are used in shades of yellow, orange, red, and maroon. The majority of cadmium pigments (approximately 54 percent) are used to manufacture cadmium yellows (EPA, 1989).

Glass and ceramics accounted for a small percentage by weight of the cadmium discards by households in 1986. Glass products, glazes, and phosphors are the major glass and ceramic products that contain cadmium. Trends indicate that these sources may remain constant or increase slightly for the next several years (EPA, 1989).

All other sources include appliances, rubber products, used oil, and electric -blankets and heating pads. Cadmium plating and plastics are the two main sources of cadmium in appliances. Due to its corrosion-resistant properties, cadmium plating has been used to protect steel nuts, bolts, and screws in dishwashers and washing machines. However, steel parts are being replaced by plastic substitutes. Cadmium is used in pigments, fillers, activators, vulcanizers and plasticizers associated with rubber products. Small amounts of cadmium (1.4 ppm median concentration) are preyi’nt in used automotive oil (EPA, 1989). The heating elements in electric blanker!. and heating pads have a synthetic fiber .,re that is wrapped with a one percent by weight cadmium alloy wire. The average blanket contains 0.00033 pounds cadmium. According to EPA, these sources are not major contributors of cadmium to solid waste (EPA, 1989).

MERCURY

Mercury is found in a number of items commonly discarded in solid waste. This chapter divides these sources into two categories: those that are currently used and those that are being discontinued. Table 2-3 shows the relative contribution by households to MSW of mercury-containing products that are currently in use. EPA reports that mercury in MSW will decline over 60 percent between 1989 and 2000. Most of this decline should be due to reductions in mercury in alkaline and other batteries.

EPA has classified over 98 percent of products that contain mercury as noncombustible. These include lighting, thermostats and batteries (EPA, 1992). Combustible sources comprise mainly plastics, paper goods or textiles coated with me rcury-con taining pigments.

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Table 2-3 also shows that batteries represent the most significant household source of mercury in solid waste (EPA, 1992). The battery industry is beginning to reduce mercury in alkaline batteries. This should lead to an overall reduction in mercury in MSW (Adamo et al. 1991). According to EPA, use of mercury in silver oxide, zinc air, and carbon zinc batteries may be discontinued by the year 2000. At that time, mercuric- oxide batteries may be the only significant battery-related household source of mercury in solid waste.

Electric lighting is the second largest source of mercury in solid waste (EPA, 1992). This includes ordinary fluorescent lamp bulbs commonly used in commercial buildings and such high intensity discharge (HID) bulbs as mercury vapor, metal halide and sodium lights more commonly found in outside lighting (EPA, 1992). According to EPA, the mercury content of lighting has been decreasing in recent years, however, marked increases in sales due to the cost and energy savings associated with these type of bulbs are projected to increase the amount of mercury in solid waste from this source.

EPA considers thermostats to be the only household electrical device that provides a significant source of mercury to MSW (EPA, 1992). Mercury thermostats, however, have begun to be replaced by electronic thermostats that do not contain mercury, particularly in commercial structures. However, this should not be a source of mercury in the near future as older mercury thermostats are replaced with new electronic ones (EPA, 1992).

Mercury is also found in other electrical devices because of its free flowing conductivity. The majority of those uses are in telephone switching systems and industrial temperature or pressure control systems. Mercury light switches, which have been used since the 1960s, contain approximately 3.5 grams per switch (EPA, 1992). They are long lasting (approximately 50 years), but they may appear in construction debris.

The only category of mercury instrumentation that has been widely identified in solid waste has been the mercury thermometer (EPA, 1992). However, mercury thermometers are being replaced by digital thermometers in most medical institutions.

Mercury sulfide compounds are presently used in orange and red pigments. Cadmium mercury pigments are widely used in plastics. They are also found in paints, enamels, printing inks, rubber and paper printing (Koephe, 1991). Because of pressures to remove heavy metals from pigments, EPA has predicted that household sources of pigments will contribute less than one percent by weight of the mercury in MSW within the next ten years (EPA, 1992).

Dental amalgams used to fill cavities contain approximately 50 percent mercury. Dentists commonly collect scrap fillings and shavings and sell them to mercury refiners (EPA, 1991). However, mercury from discarded teeth and fillings is likely to be disposed of in MSW landfills or incinerators. Because of increased cavity prevention and health

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Table 2-3

HOUSEHOLD SOURCES OF MERCURY IN MUNICIPAL SOLID WASTE (EPA 1992)

Percent Category Products By Weight

Batteries Alkaline, mercuric-oxide, carbon zinc, zinc air silver oxide, mercury indium bismuth, & mercury cadmium More than 85

Electrical Lighting Fluorescent lamp bulbs, & mercury vapor, metal halide & sodium lights 5

Electrical Equipment Electrical thermostats, c- -

telephone switching systems, & industrial temperature & pressure control systems 2

Instruments

Pigments

Dental Uses

Paper Coating

Pharmaceutical

Others

Mercury thermometer 2

Orange and red pigments, cadmium mercury pigments used in plastics, & paints, enamels, printing inks, rubber & paper printing 2

Dental amalgams 2-4

Cathode ray tubes in CAT scanners, newspaper publishing, & microfiche printers

Antiseptics, diuretics, & skin preparations

Plastic catalysts, cosmetics, & paints

12

0.1

Unknown

Less than 1

. - .

concerns over the use of mercury in fillings, the dental profession estimates that the amount of mercury in solid waste should continue to decrease (CODM, 1984).

The coating for the special paper used for scanning cathode ray tubes, such as CAT scanners, and newspaper publishing and microfiche printers contains mercury. EPA predicts that the use of mercury in these products may be eliminated by 1995 (EPA, 1992).

Mercury is found in a number of pharmaceutical products (Windholz, 1983). Most of these pharmaceuticals are antiseptics, diuretics and skin preparations; although, mercury used in skin preparations is declining (ATSDR, 1989). No attempt has been made to quantify this source.

A number of the household sources of mercury represent less than one percent by weight of mercury in MSW. These minor sources include plastic catalysts, cosmetics and paints.

r . ~ Mercury is found in plastic catalysts manufactured outside of the United States, The EPA predicts that this source will represent less than particularly polyurethanes.

one percent by weight of the total mercury in MSW by the turn of the century.

Mercuric-oxide and thimerosal, both mercury-containing compounds, are found in cosmetics. However, there is has been no estimate in the literature on the amount of this source in solid waste.

DISCONTINUED USES

Discontinued uses of mercury in products that have been disposed as MSW are listed in Table 2-4 (EPA, 1992). These products should not be contributing mercury to MSW any longer.

POSSIBLE SOURCES OF TARGET METALS IN HOSPITAL WASTE

The authors of this report screened data on the products that contain target metals in household sources of MSW that may also occur in hospital solid waste. Tables 2-5 and 2-6 compare these potential sources of lead, cadmium and mercury to determine what could occur in HSW. These tables are the basis for the type of data requested of the case study hospital. The following section briefly describes these tables and their implications

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Discontinue1

Table 2-4

DISC3NTINUED USES OF MERCURY (EPA, 1992)

;e Date D is con t . .I ued

Instant camera film pack batteries 1988 Silver coating in mirrors 1940s Specialized glass formation unknown Felt treatment 1950s Fungicidal treatment of outdoor fabrics unknown Slimicide treatment of paper products early 1970s Mercury in latex paints 1990

POSSIBLE LEAD AND CADMIUM SOURCES r. -

The product categories that contribute lead to MSW are the same as those that contribute cadmium. Therefore, the authors have grouped them together in this section. These are summarized in Table 2-5. Batteries are probably the most significant source of lead and cadmium from households and may be significant sources in HSW. Hospitals may use lead-acid batteries in building and grounds operations and portable generators. Hospital use of lead-acid and nickel-cadmium batteries may be significant because they have more industrial uses for these batteries than households. Similarly, silver-cadmium batteries have many more applications in hospitals than in households.

In addition to batteries, o t h x products include electronic components, glass and ceramics, plastics and pigments. There may be some differences in the glass and ceramics found in household waste than in hospital wastes due to laboratory glassware and ceramics as well as leaded glass for protective uses in x-ray operations. In comparison to the household waste stream, hospital solid waste may also contain a greater percentage of plastics.'

This assumption is based on a study that compared the levels of plastics in the bio- medical waste stream (combined general and infectious waste). The study found that 30 percent by weight of HSW is plastics as compared with 7 percent by weight from households (Hickman, 1987).

14

POSSIBLE MERCURY SOURCES

Table 2-6 shows a comparison of sources of mercury in household waste and their potential presence in HSW. The major source of mercury in household waste is batteries. Hospitals commonly use many types of equipment that contain batteries (e.g. smoke detectors, flashlights and hearing aids). Hospitals also use many specialized types of equipment (e.g. fetal heart monitors and EKG meters), which use mercury-containing batteries. Therefore, the authors assume that hospitals dispose of large quantities of these batteries.

The researchers also assume that hospitals use significant amounts of fluorescent lighting based upon their size and 24 hour lighting requirements. In addition, any older electrical mercury thermostats that are replaced in the hospital would probably be discarded in HSW. Mercury fever thermometers, although being replaced by digital thermometers, may still be discarded by hospitals. The authors of a recent study proposed that the only significant source of mercury from pigments in HSW is red bags used to dispose of infectious waste (Green, 1991). Mercury from discarded teeth, waste pharmaceutical and paper coatings from CAT scanners may also be common sources of mercury in the hospital solid waste stream.

-*

15

Table 2-5

PRODUCTS CONTAINING LEAD AND CADMIUM TO INVESTIGATE DURING THE HOSPITAL CASE STUDY

Products in Household Waste Products in Hospital Waste

I. Batteries

Lead-Acid (Pb) Nickel-Cadmium (Cd) Silver-Cadmium (Cd)

11. Electronics

Leaded Glass (Pb) Printed Circuit Boards (Pb)

111. Glass and Ceramics -. . .

Enameled Glass & Ceramics (Pb, Cd) Glassware Containers (Pb, Cd) Laboratory Ware (Pb, Cd) Optical Glass (Pb)

IV. Plastics

Packaging (Pb, Cd) Protective Clothing (Pb, Cd) PVC Products (Pb, Cd)

V. Pigments

Paints (Pb, Cd) Printing Ink (Pb, Cd)

VI. All Others

Light Bulbs (Pb) Lead Foils (Pb) Phosphor Lights (Cd) Rubber Products (Pb, Cd) Used Oil (Pb, Cd) X-ray Films (Pb)

16

Lead-Acid Nickel-Cadmium Silver-Cadmium

Leaded Glass Printed Circuit Boards

Enameled Glass/Ceramics Glassware Containers Laboratory Glassware Optical Glass

Infectious Waste Bags Surgical Gloves PVC Products

Paints Printing Ink

Fluorescent Light Bulbs Lead Foils Phosphor Lights Rubber Products Used Oil X-ray Films Lead X-ray Shield/Aprons

. "^

Table 2-6

PRODUCTS CONTAINING MERCURY TO INVESTIGATE DURING THE HOSPITAL CASE STUDY

Products in Household Waste Products in Hospital Wastes

I. Batteries

Alkaline Carbon Zinc Mercuric-Orride Silver Oxide Zinc Air

11. Electrical Equipment

Electric Thermostats Fluorescent Lamps High Intensity Lamps Mercury Light Switches

-- -

111. Pharmaceutical and Personal Uses

Antiseptics Cosmetics Dental Fillings Diuretics Skin Preparations

IV. Medical Equipment

CAT Scan Film Fever Thermometers

V. Pigments and Catalyst

Pigments Plastics (used as a catalyst)

17

Alkaline Carbon Zinc Mercuric-Oxide Silver Oxide Zinc Air

- Fluorescent Lamps

-

Antiseptics

Dental Fillings Diuretics Skin Preparations

-

CAT Scan Film Fever Thermometers

Pigments Plastics

1 I I J 3 I 1 I I 1 i 1 1

1

I

CHAPTER 3

HOSPITAL CASE STUDY

INTRODUCTION

The purpose of this section is to investigate the sources and magnitude of lead, cadmium and mercury in hospital solid waste (HSW). State environmental officials suspect hospitals of generating solid wastes that contain these metals, but their wastes are not well characterized.

The researchers selected a case study approach to evaluate the target metals in wastes generated by a hospital within the Boston area. The group contacted the Massachusetts Hospital Association to aid in case study selection. Ultimately personal contacts with senior administrators secured the participation of the case study hospital. The group chose the case study hospital based on some key characteristics that make it similar to many other hospitals within Massachusetts. For example:

The case study hospital has approximately 300 beds while the average Massachusetts hospital has approximately 215 beds (AHA, 1990 and AHA Guide, 1990).

Both the case study hospital and the average Massachusetts hospital have a patient occupancy rate of approximately 75 percent (AHA Guide, 1990).

0 The case study facility is also a nonfederal institution as are 97 percent of the state's other hospitals (AHA, 1990 and AHA Guide, 1990).

The facility is a teaching hospital and classified as a short-term length of stay (less than 30 days) institution. The hospital offers a wide range of services, including inpatient care for AIDS and AIDS Related Complex (ARC), open-heart surgery, obstetrics, x-ray radiation therapy, occupational therapy and various psychiatric services (AHA, 1990). To encourage participation, the case study hospital was assured complete confidentiality. Hereafter, the case study hospital is referred to as "the hospital" in this report.

To conduct the case study, the researchers visited the hospital to gather information and determine the types and amounts of hospital wastes that contain lead, cadmium and mercury. The researchers focused on sources of metals generated by the hospital that were identified on Tables 2-5 and 2-6. Using the case study information, the researchers estimated the aggregate amounts of certain metals in HSW per year.

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METAL SOURCES AND CONTENT

This section reviews the available data on the products listed in Table 3-1. In addition, this section identifies products that were found to be either free of the metals or products for which purchasing records were unavailable. The final part of this section describes the data on products that were found to contain the target metals.

PRODUCTS FREE OF THE METALS

Manufacturers of waste disposal bags and surgical gloves reported that these products do not contain the target metals. However, this does not mean that other brand names, models and colors used in other hospitals are also free of the metals.

Infectious Waste Baps

The researchers reviewed the hospital’s purchasing records from October 1, 1990 r . to July 1, 1991 to determine the number of bags ordered by the hospital. By

extrapolating from the available data, the researchers estimate that the hospital used and discarded approximately 128 cases or 121,300 red and clear disposal bags during the base year (Smith, 1991). Materials safety data sheets (MSDS) obtained from the manufacturer stated that neither the bags, the red pigment nor the lettering ink contained lead, cadmium or mercury (Gentile, 1991 and Smith, 1991).

Surgical Gloves

The hospital’s supplier of protective surgical gloves reported that the gloves do not contain lead or cadmium from stabilizers or pigments. The manufacturer uses iron oxide and titanium to color their natural latex rubber gloves (Moore, 1991).

Laboratory Ware

According to information provided by the suppliers, none of the glass or plastic laboratory ware investigated contains cadmium.

UNAVAILABLE PURCHASING RECORDS

Records for CAT scan film, x-ray film and NiCd batteries were requested, but the purchasing department was unable to retrieve this information. The hospital provided no reason for their inability to retrieve records for purchasing CAT scan or x-ray film.

21

1 I I i 1 I P I I I 1 I I I 1 I 1 I I

NiCd Batteries

The researchers attempted to determine, through purchasing records, the n imh - - of NiCds purchased for use in medical equipment. For example, NiCd batteries are used as a source of backup power for various medical monitors, and they are also found in portable medical equipment (EPA, 1989). However, purchasing records were not available from the hospital. Since NiCd batteries are rechargeable and found in specialized equipment, they are not purchased directly from a battery supplier and enter the hospital already installed in the units. The purchasing departmen1 was unwilling to estimate how many machines in the hospital had a backup NiCd batte:,r (Materials Management Secretary, 1991).

PRODUCTS THAT CONTAIN LEAD, CADMIUM AND/OR MERCURY

Lead

Batteries

The battery purchasing records examined by the researchers indicated that the hospital did not order lead-acid batteries. Further inquiries were mad;. with the purchasing department, but no additional information was provided. Lead-acid batteries should be found in the hospital’s service vehicles, although they may be returned to the supplier. The research team assumed that some lead-acid batteries are used by the hospital, however, they could not estimate their quantity.

Laboratory Ware

The hospital’s laboratory ware was made of both plastic and glass, including disposable tubes, frosted microscope slides, cover glasses, cytojars, tubes, pipettes and sample vials.

The hospital has three different suppliers of laboratory ware. Of the three suppliers, only one would divulge the manufacturers’ catalog numbers. The catalog numbers were necessary to dete. ‘ ;ine the composition of the products from the manufacturers. The single cooperative supplier ordered glass and plastic products from four different manufacturers. The researchers contacted all four manufacturers who answered questions about their products’ composition.

Of the seven glass products investigated, only pipettes were found to contain traces of lead (under one percent) (Kimble Glass, 1991). The three plastic products did not contain any metals.

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X-Ray ShieldindAprons

The lead aprons and shields used in the radiology department of the hospital are made of latex rubber impregnated with lead. The lead in the front of the shield is 0.55 millimeters (mm) and 0.25 mm in the back. Each shield is approximately 87 percent lead by weight (Schwartz, 1991).

If the shields become worn they can be returned to the manufacturer for repair, but if the shield is "cracked" or pierced, the hospital discards it in the regular solid waste stream (Radiologist, 1991). The manufacturer is unable to recover lead from damaged shielding (Schwartz, 1991). Theoretically the lead aprons and shields should last 20 to 25 years if they are handled and stored properly (Schwartz, 1991). A hospital contact stated that the shields usually have a variable, shorter lifetime (Radiologist, 1991).

The hospital does attempt to reuse damaged shielding by cutting off the damaged portions and using the intact portions to protect infants from x-rays (Radiologist, 1991). The hospital does not purchase new shielding on a regular basis, therefore the yearly amounts of shielding entering the case study's waste stream varies. r . -

Fluorescent Light Bulbs

The manufacturer of the hospital's fluorescent lighting told the researchers that the bulbs do not contain lead (Zielinski, 1991).

Cadmium

Batteries

As indicated above, the hospital's purchasing records did not show whether NiCd batteries were ordered or used by the hospital. Further inquiries were made with the purchasing department, but no additional information was provided. Although NiCds may be present in the hospital's waste, the researchers could not estimate their quantity.

Mercury

Batteries

The purchasing records showed that alkaline batteries were purchased by the hospital. The researchers contacted two vendors who provided information on the batteries' mercury content. The Battery Products Alliance and Duracell also provided MSDSs that indicated that the batteries contain less than one percent mercury (Donahue, 1991 and Nicholson, 1991). In order to conservatively quantify the mercury content of the hospital's spent batteries, the researchers assumed that all alkaline batteries contained one percent mercury by weight. By extrapolating from the available records,

23

R I I d I I I I I ! 1 1 1

! 1 I

1

the researchers estimated that the hospital purchased 11,852 AAA, AA, C, D, and 9 volt alkaline batteries during the base year.

Mercury Thermometers

Records from June 1990 to June 1991 showed that a total of 1,470 rectal and oral mercury thermometers are purchased by the hospital during that year. According to the available information, the thermometers contain two percent mercury by weight. Used thermometers directly enter solid waste; the hospital does not segregate them or send them offsite for mercury recovery.

Fluorescent Light Bulbs

According to the hospital records, the hospital purchases approximately 3,000 fluorescent bulbs per year (Maintenance Staff, 1991) (Pierce, 1991).

WASTE GENERATION AND DISPOSAL

This section discusses the estimated amount of metals in the hospital’s solid waste. The researchers were not able to determine the life cycle of the products and therefore assumed that all of the products purchased in a single year would be discarded in the same year. Some products have longer life times, such as several years for x-ray shielding, while other products such as waste disposal bags are used once before being discarded. A break down of the amounts from each metal is provided in the following sub-sections.

LEAD

Lead shielding contains 87 percent lead by weight. Other materials in the aprons and shields include latex rubber, velcro and fabric. The weights of the x-ray shields varies due to the different sizes and uses. For instance, full frontal coverage aprons weigh 9 to 13 pounds, front and back coverage shields weigh 13 to 23 pounds, and thyroid and head coverage weigh approximately 1 pound (Schwartz, 1991).

The radiology department does not regularly order x-ray shields. Between October 1, 1990 and June 1, 1990, the hospital ordered 14 x-ray shields. Table 3-2 shows the total weight of the types of shields purchased by the hospital.

Table 3-2 also shows the total weight of all the shields purchased during the nine month period when records were available. Assuming that the lead content of each shield is 87 percent, the researcher estimate that there was approximately 100 pounds of

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Table 3-2

LEAD FROM X-RAY SHIELDS (Pounds)

Items Ordered

3 Single Lead Gloves 3 Lead Kilt Vest 3 Lead Aprons 1 Maternity Lead Apron 4 Thyroid Shields

Total Weight for Each Type of Shield

3 53 33 30 4 -

TOTAL Weight of 14 Shields 123

r . -

lead in the 14 x-ray shields purchased by the hospital. For the purposes of this study, the researchers assumed, therefore, that the hospital disposes of approximately 100 pounds of lead from x-ray shields per year. However, this estimate is uncertain because the hospital sporadically purchases x-ray shield. Nevertheless, a significant amount of lead can enter the HSW stream over a short period of time from this source.

From the available information on laboratory ware, the group determined that this source contributed no cadmium and very little lead to the HSW stream. are not considered a significant source of lead since the glass contains less than one percent lead and the pipettes are not purchased in large quantities (Kimble Glass, 1991).

Glass pipettes

CADMIUM

The review of purchasing records and follow-up contacts with suppliers and manufacturers revealed that the waste disposal bags, laboratory ware and surgical gloves used by the hospital do not contain cadmium.

As stated above, the researchers were unable to obtain information on the number of NiCd batteries purchased by the hospital. Therefore, the researchers could not estimate the amount of cadmium in wastes generated by the hospital.

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MERCURY

As stated above the researchers found that the hospital purchased approximately 11,852 alkaline batteries in the base year. The researchers estimated the amount of mercury from alkaline batteries by multiplying the weights of the various types of batteries by one percent (by weight mercury content) (Donahue, 1991 and Brand, 1991). The weights for the various battery sizes ranged from 0.4 ounce for AAA size batteries to 4.7 ounces for D size batteries (Donahue, 1991). Based on these weights, the researchers estimate that alkaline batteries contributed approximately 10.4 pounds of mercury to the HSW stream.2

The fluorescent bulbs used by the hospital contain 50 milligrams of mercury (Zielinski, 1991). As stated above, the hospital reported that they used 3,000 fluorescent bulbs per year. Therefore, these bulbs contribute approximately 0.3 pounds of mercury to the hospital’s wastes annually.

-- - TOTAL METALS GENERATED

Table 3-3 shows that approximately 113 pounds of lead and mercury entered the solid waste stream in the base year. This is an uncertain estimate of the metals content of the hospital’s wastes since the researchers were unable to obtain any estimates of NiCds, mercuric-oxide button batteries, and other sources noted above.

SOLID WASTE DISPOSAL

A review of the hospital’s waste disposal records indicated that their solid and infectious waste is transported by a commercial hauler, Browning Ferris Industries (BFI) to a commercial landfill. The hospital’s records, DEP records and conversations with hospital personnel indicated that the facility does not incinerate its solid waste on-site (Engineering, 1991), although the hospital owns an approved on-site incinerator (DEP, Air Quality, 1991). None of the waste is taken off-site to be incinerated (Engineering, 1991).

The hospital initiated a recycling program in November 1990 that collects cardboard and office paper. Due to the cost savings realized by collecting paper

* This is a highly conservative estimate of the mercury content of alkaline batteries. In recent years, several battery manufacturers have reported that their alkaline batteries contain 0.5 to 0.025 percent mercury. However, the battery manufacturers contacted for this study, reported that their batteries contain one percent mercury.

26

products for reuse, the hospital is considering an expansion of the recycling program to include other materials such as polystyrene (Director of Material Management, 1991).

The researchers estimate that approximately 824 tons of solid waste was generated by the hospital from October 1990 to October 1991. This was a reduction of approximately 83 tons from the approximately 907 tons in the previous year. This reduction may have been due to the facility’s recycling program for cardboard and office paper. The approximate amount of infectious and hazardous waste generated from October 1990 to October 1991 was 114.8 tons.

Table 3-3

ESTIMATED LEAD, CADMIUM AND MERCURY IN CASE STUDY HOSPITAL WASTE

-- - Category

Total Metal Quantity Uni tsmear in Waste JMetalKJnit) JEx tra pol a ted 1 JPou nds)

Lead X-Ray Shields 87 percent 14 100

Glass Pipettes <1 percent NA NA

Alkaline Batteries 1 percent 11,852

Fluorescent Bulbs 50 mg 3,000

Fever Thermometers 0.61 grams 1,470

TOTAL

10.4

0.3

2

112.7 pounds

Waste generation rates vary between hospitals as a function of the number of occupied hospital beds, the number of intensive care beds and the presence of any specialty laboratories or facilities (Brunner, 1988). The estimated total waste generation (including hazardous and infectious waste) is 13 Ib/occupied bed/day. In addition, the presence of laboratories and cafeterias add approximately 0.5 Ib/patient/day and two lb/meal/day respectively (Brunner, 1988). Approximately 85 percent of all hospital waste is solid waste (Doyle, 1985). The remainder is infectious (ten percent) and hazardous waste (five percent).

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I I 1 I 1 1 I --

I 1 I 1 I I I I 1 1

Currently in the United States, HSW is disposed in solid waste landfills and incinerators except for wastes that are recycled (Lee 1991). Approximately 67 percent of all hospitals in the U.S. have on-site incinerators (Hershkowitz, 1990). There are approximately 128 pathological and hospital incinerators owned by hospitals within Massachusetts (DEP, Air Quality, 1991). Not all of the approved incinerators are used regularly. Although these incinerators are intended for destruction of infectious waste, they often are used for the disposal of other solid waste (Brunner, 1988). Such use may be encouraged if the hospital generates heat from the incinerator (boiler).

CURRENT RESEARCH

There are a number of hospitals around the country that have developed waste reduction and recycling programs (Nelson and Steinberger, 1990). At least two hospitals in New England are currently involved in investigating the content of their HSW. The University Medical Center in Vermont and the Dartmouth Hitchcock Medical Center in New Hampshire are improving their waste management of the target metals. In addition, a group of hospitals in Minnesota have been collaborating on their medical waste reduction efforts. The programs at these hospitals may serve as models for others.

THE UNIVERSITY MEDICAL CENTER

The University Medical Center is a 500 plus bed hospital, which has initiated an ongoing trash sorting project called "Med Cycle". The project involves sorting two tons of non-patient contact trash generated in the operating room into 18 categories, including a metals category. Preliminary results show that the trash contains 89 percent plastics, 10 percent paper products, and 1 percent metals.

The University Medical Center Hospital has also developed a collection and tracking system for a-11 batteries from their institution. Regulatory compliance was the primary incentive for the hospital to initiate this waste sort (Clayton, 1991). Vermont has stringent regulations for incinerator emissions and the resulting ash. The batteries are managed as hazardous waste.

In 1990, the hospital disposed of one 55 gallon drum and 20 pounds of batteries. By the middle of 1991, two 55 gallon drums and one 20 gallon drum of batteries had been collected. At present the program only collects the batteries and monitors the amounts; however, there is a proposal to examine possibilities for separation and recycling (Clayton, 1991). This program may serve as a model to other health care facilities that wish to track their solid waste and improve management of heavy metal- containing products.

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DARTMOUTH HITCHCOCK MEDICAL CENTER

The Dartmouth Hitchcock Medical Center is currently trying to reduce the metals content of their waste stream. The hospital’s manager of BioSafety and Environmental Programs cited environmental and regulatory concerns, particularly air emissions from its incinerator, as an incentive for their proactive stance on waste management (Jas, 1992).

The hospital has been separating batteries from the rest of its waste since January They would like to find markets for their stockpiled batteries. However, they 1991.

have not been able to find a recycler for their alkaline batteries and are currently disposing of them at a hazardous waste landfill in South Carolina. They generate approximately one 55 gallon drum (approximately 4200 batteries) of spent alkaline batteries per quarter. They are currently sending lithium and mercuric-oxide batteries to the Mercury Refining Company in New York for recycling. They have begun to replace such products as beepers that use disposal batteries with ones that use rechargeables. They are also stockpiling a small amount of NiCd batteries found in their wastes to determine their source (Jas, 1992).

They are replacing most of their mercury thermometers and blood pressure units with digital models. Mercury thermometers and blood pressure units tend to be more accurate than digital units and are used in medical units requiring a high level of accuracy, such as pediatrics. The liquid mercury left from these thermometers and blood pressure units is sent to the Mercury Refining Company for recycling (Jas, 1992).

In addition, the Medical Center uses tubes to remove intestinal blockages on an emergency basis that contain a tablespoon of mercury. The Center ships the mercury from these tubes to Mercury Refining for recycling and the tubes are sent to a hazardous waste landfill. The other major source of mercury at the hospital is in refrigeration equipment. The Center removes the mercury from this source and ships it to Mercury Refining for recycling (Jas, 1992).

A source of lead and cadmium in the Center’s waste is a lead, cadmium and tin alloy used to make blocks for radiation therapy. The Center makes these blocks using the alloy and a Styrofoam mold. Once the blocks have been used and the patient is healthy, the Center melts them and reuses the alloy. The Styrofoam and filing wastes generated during the molding process are filtered and sent back to the alloy manufacturer for reuse (Jas, 1992).

The Dartmouth Hitchcock Medical Center has instituted a centralized purchasing system for all products containing hazardous materials. These items must be approved prior to purchasing. This provides an opportunity for substituting products that contain less hazardous constituents. The hospital’s manager of BioSafety and Environmental Programs works with a Waste Management Task Force on Center-wide issues and with small working groups to address specific wastes.

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t I t I E I I I I 1 I I 1 I 1 I I 1 1

MINNESOTA HEALTHCARE PARTNERS

The Minnesota Healthcare Partners (MHP) is a collaborative effort of hospitals in the Twin City area to develop and implement solutions to operational problems shared by the hospitals. They conducted a study of the member hospital’s infectious wastes to develop non-bum alternative technologies for managing those wastes. As part of their study, they examined the hospitals’ practices for managing non-infectious wastes. They surveyed 23 hospitals on their waste reduction and recycling efforts.

MHP found that all the hospitals were collecting x-ray films, 74 percent collected glass and over 50 percent collected other metals. The hospitals recycled 27-40 percent.of their total waste as part of a formally organized program. Approximately 83 percent of the hospitals separately collected batteries for return to their suppliers for disposal. In addition the hospitals had implemented such programs as returning materials to the original supplier; using or switching to reusable items rather than disposable ones; purchasing recyclable items ar items with less packaging; and purchasing materials with recycled content (Minnesota Healthcare Partners, 1992).

RECOMMENDATIONS

Hospitals that dispose of products containing the target metals should consider improvements in the management of these wastes. This section presents general source reduction, recycling and waste management opportunities available to hospitals.

As institutions that purchase large quantities of goods, hospitals could use their buying power to convince manufacturers and suppliers to reduce the metals content of various products where technologically and economically feasible. For example, hospitals could contact battery manufacturers and request only batteries with low mercury content. Hospitals could also make agreements with suppliers or manufacturers to accept spent metal-containing products. This would encourage the manufacturers to recycle the products or limit the amounts of metal within the products. For example, hospitals could contact manufacturers of lead shielding and request that they take back damaged shields and reuse the lead portion.

Hospitals could also devote a part or full time staffperson to pollution prevention and recycling programs (Nelson and Steinberger, 1990). This individual could help reduce metals in the solid waste stream by instituting the following:

0 A written pollution prevention policy for the hospital with support from top level management.

. Development of a hospital source reduction and recycling committee to develop and implement the pollution prevention policy.

30

Identification of products that contain toxic metals so that they can be reduced, recycled, or properly disposed.

Requests of material safety data sheets and metal content information from manufacturers and suppliers to aid in focusing waste reduction efforts.

Educational programs for the hospital staff in pollution prevention techniques.

Substitution of non-metal containing products where possible.

Centralized purchasing in order to examine opportunities for product substitution.

The use of suppliers that accept used products or encourage current suppliers to do the same.

Separation of the target metal-containing products from the waste stream for metals reclamation or disposal in a RCRA Subtitle C facility.

Identification of markets for separated materials.

Collaboration with other hospitals to exert pressure on suppliers and manufacturers to reduce the target metals contents of products used by medical institutions.

By funding this specialized waste reduction position, hospitals may be able to save money from the sale of separated metals, reduced disposal costs, reduced purchasing costs, and reduced costs of complying with environmental regulations (Nelson and Steinberger, 1990).

Hospitals and other senice institutions may also have an opportunity to source separate products containing the target metals. For several products, the metals are easily identified and separated, and they are often "clean" or not commingled with other refuse. Items that contain heavy metals that could be reclaimed include fever thermometers, batteries and lead shielding. Source separation could allow for easier recycling and reuse of the metals.

A manager of the case study hospital told the researchers that cost savings and environmental concerns are two important incentives for recycling within a commercial insitution. Many recycling programs are hindered by the undeveloped market for the collected goods. If these markets were developed, the economics of recycling would

31

! I I E I I\ 1 I I I 1 I I I 1 I I I I 1

improve and more institutions would be likely to implement recycling programs (Hazardous Waste Report, 1991).

If recycling is not possible, the separated materials can be sent to a RCRA Subtitle C disposal facility. Rather than disposing of metal-containing items in regular MSW landfills, the items may be more appropriately disposed in a hazardous waste landfill.

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I)

I 1 I I I 1 I I s I I I 1 I I I 3 I

CHAPTER 4

REGULATORY REVIEW

This chapter examines the federal waste policies and regulations of the United States, the member states of the Nortwast Waste Management c.‘zficials’ Association (NEWMOA), Western Europe, and Japan.

U.S. REGULATIONS

In the United States, federal and state waste management ~~.gulations a:: designed to protect the public health, safety, welfare. and the envi;tnnent. Co;:gress mandates that the Environmental Protection Agency (EPA) develop regulations that govern the disposal of solid and hazardous wastes. This section presents a review of the relevant sections of the Resource Conservation and Recovery Act (RCRA) and the Hazardous and Solid Waste Amendments (HSWA) to RCRA that address the disposal of items containing lead, cadmium and mercury. This section also covers the appropriate provisions in the applicable air quality laws and the Toxic Substance Control Act (TSCA).

At present no Federal program mmdates recycling of heavy metals. However, EPA has formed a Municipal Solid Waste Task Force in the Office of Solid Waste to develop a national strategy for the management of MSW. The scope of the Task Force’s work includes assessing the role and feasibility of source reduction, recycling, waste treatment, incineration/energy recovery and landfilling (53 Fed. Red. 78, p. 18880, 1990).

RCRA SUBTITLE C

Disposal of wastes containing the target metals by commercial entities, including hospitals, is regulated under RCRA Subtitle C. This Subtitle addresses the tracking and disposal of hazardous waste.

RCRA Subtitle C regulates the storage, collection, transportation, treatment, disposal, use, reuse, and recycling of hazardous wastes. The law requires companies3 that produce hazardous wastes to notify the EPA that they generate hazardous wastes, identify the wastes, determine the monthly production rate, and properly manage the waste.

Household wastes are exempt from federal regulation under RCRA regardless of the content of the waste generated [40 CFR 216(b)(l)].

33

There are two ways to identify waste materials as hazardous:

Listed - materials that are listed in the RCRA regulations; Characteristic - materials that fall into categories such as toxic (including lead, cadmium and mercury), ignitable, corrosive or reactive.

To determine if wastes that contain lead, cadmium and mercury are hazardous, firms are required to test them using the Toxic Characteristic Leaching Procedure (TCLP). If the extract from a representative sample of the waste contains a concentration equal to or greater than the following limits (40 CFR 261.24), the waste is considered to be hazardous:

Limits Waste Code Toxic Characteristic - .DO06 Cadmium DO08 Lead DO09 Mercury

1.0 milligrams per liter 5.0 milligrams per liter 0.2 milligrams per liter

When tested, many items, such as lead-acid batteries, some ground glass, thermometers, and nickel-cadmium batteries, fail the TCLP. If a facility generates 100 kilograms or more per month these wastes should be managed as hazardous wastes in accordance with RCRA Subtitle C regulations. (Several states in the Northeast have lower cut-off levels for what quantities of wastes must be managed as hazardous waste.)

A hazardous waste must be stored, handled, transported and disposed in accordance with RCRA Subtitle C regulations. As part of these regulations, EPA has established land disposal restrictions for the target metals. EPA has set concentJation levels and/or methods of treatment, called treatment standards, that substantially diminish the toxicity of the wastes or reduce the likelihood that hazardous constituents will migrate from the land disposal site. Wastes that do not meet the treatment requirements are prohibited from land disposal (EPA, 1991).

Under these restrictions,

RCRA also addresses hazardous materials that are hazardous wastes when recycled. The regulations require certain recycling facilities to file for a permit as a hazardous waste treatment facility. However, the law specifically exempts used batteries or cells returned to a battery manufacturer for regeneration from all Subtitle C regulations.

Hospitals generate several potential hazardous wastes as a result of medical treatment procedures, diagnostic tests, disposal of old chemicals and routine maintenance of hospital facilities. If a medica1 facility generates any combination of hazardous wastes that meet the characteristics (e.g. .toxic, ignitable, corrosive or reactive), the facility must obtain an EPA identification number. Many hospitals, including the case study hospital, are registered with EPA as generators (Allen, 1991). As noted in Section 3, hospitals

34

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I I

dispose of most target metal-containing wastes as solid waste; however these wastes may be hazardous.

RCRA Subtitle C directs generators of hazardous wastes to state on their hazardous waste transportation manifests that they have a waste minimization program. EPA has not established a system to monitor waste reduction, thus there is no way to assure compliance or enforcement of this provision. Hospitals and other hazardous waste generators may indicate on their manifests that they have a waste minimization program, but there are no federal mandates on the scope or features in these programs. EPA checks these signatures on all manifests. In addition, during inspections EPA staff ask facility contacts if a waste minimization program has been developed to verify the statement on the manifest.

CLEAN AIR ACT

The Clean Air Act Amendments of 1990 (Section 129) requires that EPA establish new source performance standards (NSPS) for municipal solid waste combusters that burn less than 250 tons per day, including small commercial incinerators at hospitals. These regulations should include standards for lead, cadmium and mercury and other toxic pollutants. Under this regulatory program, EPA plans to propose New Source Performance Standards (NSPS) for emissions from new medical waste combusters and emissions guidelines for existing ones. The NSPS should reflect the maximum achievable control technology (MACT) while the guidelines may be equal to or less than the NSPS. The NSPS standards and guidelines should be released for public comment in the fall of 1992.

In 1987 EPA established the national ambient air quality standards (NAAQS) for lead emissions. EPA restricts the lead emissions of smelters that recoter lead and incinerators. Although EPA has not made b:ittery recycling mandatory, the Agency is investigating lead emission controls at smelters and evaluating how increasing regulatory control may affect battery recycling. With the phase-out of lead in gasoline, EPA staff believe that the major remaining source of lead in air is from smelters. The Agency’s goal is to encourage recycling while minimizing lead emissions (Inside EPA, 1990).

TOXIC SUBSTANCE CONTROL ACT

The Toxic Substance Control Act (TSCA) of 1976 provides a regulatory mechanism to protect the public against dangerous chemical materials contained in consumer and industrial products. TSCA gives the EPA wide authority to ban or restrict the manufacture, processing, distribution, commercial use or disposal of any chemical substance that presents an unreasonable risk of injury to public health or the environment.

35

In August 1991 the EPA pesticide program prohibited all uses of mercury as a biocide in indoor latex paints using its authority under T S C k In May 1991 manufacturers of the two remaining mercury-containing outdoor latex paints voluntarily stopped production (Koephe, 1991).

In addition, EPA has begun a review of the production, use and disposal of lead under Section 6 of TSCA Under the Agency's proposal, the use of lead would be banned if there was a "compatible substitute" for the lead in the product. Further, new uses of lead could be banned if that use would result in "dispersion of lead into the environment." The review process required to make changes under TSCA is long, therefore this proposal may not be finalized for quite some time (Seeger, 1990).

STATE REGULATIONS IN THE NORTHEAST

The following section is arranged alphabetically by state. A brief review of the laws and regulations that could affect the target metals in HSW are presented for each state. The information is organized by regulation: hazardous waste, batteries, and other related legislation. The chapter concludes by comparing the states' rules and regulations for each regulatory subset and by providing a summary tables.

CONNECTICUT

Hazardous Wastes

Connecticut's hazardous waste regulations mirror the RCRA requirements. Connecticut has set more stringent regulations regarding the amount of wastes that can be stored at the point of generation prior to disposal than is required under RCRA (Devine, 1991).

Batteries

There are two laws that affect the disposal of batteries in Connecticut. The first law establishes lead-acid battery recycling regulations. These regulations prohibit the disposal of any lead-acid battery as MSW. The regulations require retailers to: (1) inform consumers about the law, (2) accept batteries for recycling, and (3) administer a refundable $5.00 deposit when a lead-acid battery is purchased without the exchange of a used battery. The deposit is refundable for a 30 day period with the return of an old battery. From October 1, 1990, to April 1, 1992, retailers must take back up to three batteries per customer with or without a purchase. After April of 1992, retailers must only accept the return of one-for-one batteries at the point of sale (BCI, 1990).

36

I I f

t I I d I I I I I 1 1 I I I I

i

I I

8 I

/I k

p jl I

The second law was passed in 1989 and concerns the reduction of packaging material and disposable products. This law requires in-state sales of household products containing a NiCd battery to be designed so that the rechargeable battery is removable. Further, the bill requires disposal information to be on the item's label and municipalities to recycle all NiCds after 1993. The law allows manufacturers to request exemptions for products where the redesign would cause a significant public health or safety risk or cause substantial job losses to the state (1989 CT Pub. Acts 385).

Other Reda t ions

In 1990 Connecticut passed legislation governing the use of toxic metals in packaging. With few exceptions the sale of packaging and any product contained in packaging that is "intentionally composed of any lead, cadmium, mercury or any hexavalent chromium" is prohibited after October 1992 (Thomas, 1990).

The law gives manufacturers and distributors four years to phase-out the sum concentration levels of cadmium, lead, mercury and hexavalent chromium in packaging or packing materials to 100 parts per million (ppm) used or sold within the State. The law cohtains two exemptions: (1) for products where lead is used for health and safety, and (2) for liquor and wine bottle wrappers, which utilize a tinbead wrapper. The law has enforcement provisions that include civil monetary penalties, criminal fines and jail terms for intentional misconduct (CONEG, 1991).

MAINE

Hazardous Wastes

Maine's hazardous waste regulations commonly referred to as the "Hazardous and Solid Waste Management Standards" mirror the Federal RCRA requirements (Whittier, 1991). Wastes containing heavy metals below the hazardous waste regulatory standards are regulated as special wastes. The landfilling of such special wastes as incinerator ash, non-liquid paint wastes, lighting and electrical components requires approval by the Maine Bureau of Hazardous Materials and Solid Waste Control. Potential leaching of heavy metals requires more exhaustive regulation of these materials, including specific testing and disposal requirements (Eliason, 1991 and 06-096 Code ME Regs. 400 -- 412).

Maine has a lead-acid battery recycling law that went into effect during the summer of 1989. The law prohibits the disposal of any lead-acid battery "by burial, incineration, deposit or dumping so that the battery or any of its constituents may enter the environment or be emitted into the air or discharged into any waters" (ME Rev. Stat. Ann. tit. 38 8 1604). While Maine supplies point of purchase signs disclosing the law,

37

.

retailers are required to accept batteries €or recycling and administer a refundable $10.00 battery deposit system. The deposit is refundable for a seven day period with the return of an old battery. In addition, the law contains provisions for regulatory inspection and civil penalties (Eliason, 1991).

In 1992 Maine enacted legislation mandating reductions in heavy metals in household batteries. The law bans the sale of mercuric-oxide batteries after 1993 in the state; mandates a reduction in the mercury-content of alkaline batteries to 0.025 percent by 1994; bans the sale of alkaline batteries containing any mercury after 1996; and bans the sale of nonremovable rechargeable batteries. In addition, after January 1994 all medical facilities employing more than 15 people will be required to collect mercury- containing and rechargeable batteries for recycling.

Other Regulations

The 1991 legislative session passed a toxic packaging bill, which sets limits on the amount of lead, cadmium, mercury and hexavalent chromium allowable in packaging (Versa, 1991). Maine adopted the legislation as proposed by the Coalition of Noriheastern Governors (CONEG) including:

0 A prohibition/schedule to reduce the amounts of cadmium, lead, mercury and hexavalent chromium (reduce the sum of the metals concentrations to 600 ppm by 1993, to 250 ppm by 1994, and to 100 by 1995);

0 Exemptions for packages and packaging (1) manufactured prior to the law, (2) made from recycled materials when the metals enter the packaging during the recycling process, and (3) containing metals added to comply with health or safety requirements;

0 Requirements that manufacturers supply a "Certificate of Compliance" no later than two years after adoption of the law to product purchaser; and

0 State enforcement provisions and review after 3.5 years to recommend future actions (CONEG, 1991).

D 1 I I L I I I I

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MASSACHUSETTS

Hazardous Wastes

The Massachusetts hazardous waste regulations (310 Code MA Regs. 30.000) are consistent with the Federal RCRA Subtitle C requirements and are more restrictive. The Massachusetts hazardous waste regulations govern all hazardous wastes generated by industrial and commercial entities. Based on waste generation rates there are three categories of hazardous waste generators. Furthermore, Massachusetts defines hazardous waste to include “physical, chemical or infectious’’ materials.

The Massachusetts Department of Environmental Protection (DEP) regulates laboratories that may generate a hazardous waste as the result of procedures and experiments or when old chemicals are discarded. If the Laboratory is within a larger institution, the entire facility should be classified as a hazardous waste generator. A comprehensive audit of the site should be conducted before determining what rules for managing the hazardous wastes apply (MA DEP, April 1991).

Batteries

Massachusetts regulates lead-acid batteries under hazardous and the solid waste regulations. State hazardous waste regulations define open or leaking lead-acid batteries and electrolyte removed from lead-acid batteries as hazardous wastes. Batteries that are not leaking may be sent to a scrap yard or a distributor for recycling. The state regulations mandate stor ge, management, and permitting requirements for facilities that collect lead-acid batteries for the recycling. In addition, state solid waste management facility regulations ban the disposal of lead batteries in landfills or incinerators.

Other Regulations

The Massachusetts’ legislature is currently considering a bill that contains provisions similar to the CONEG model legislation adopted in Maine that would regulate toxic metals in packaging.

NEW HAMPSHIRE

Hazardous Waste

The New Hampshire Department of Environmental Services (DES) Waste Management Division enforces the state’s hazardous waste law. The state’s Environmental Waste Management regulations incorporate the Federal RCRA Subtitle C

39

c

requirements and are more extensive controlling all wastes generated by industrial and commercial entities.

Batteries

Wet cell batteries were banned from landfills and incinerators in the 1990 legislature. Legislation similar to Connecticut’s approach to dry cell batteries has been introduced in the 1992 session (Yergeau, 1992).

Other Reeulations

New Hampshire has passed a law to govern the use of toxic metals in packaging. The bill is the same as the CONEG toxic packaging reduction law passed by Maine with two differences, (1) an exemption for liquor and wine bottle wrappers that may contain lead, and ( 2 ) a requirement that the state conduct a risk assessment to evaluate additional toxic substances in packaging for future regulatory consideration (CONEG, 1991).

NEW JERSEY

Hazardous Wastes

The New Jersey hazardous waste regulations are similar to those in New Hampshire.

Batteries

In April 1991 New Jersey passed legislation that requires the recycling of lead-acid batteries. The law requires manufacturers and distributors to take back lead-acid batteries and recycle them. The law prohibits the disposal of any lead-acid battery by landfilling or incineration. Counties in New Jersey are responsible for disposal of batteries and are setting up collection centers for batteries not returned to the point of purchase (Davis, 1991).

The New Jersey legislature recently passed legislation that assigns the responsibility of recycling dry cell batteries, including mercuric-oxide, alkaline, and carbon zinc, to manufacturers and requires battery manufacturers to reduce their mercury content. The law prohibits disposal of batteries in MSW, and requires the redesign of products containing NiCds to make the batteries removable (unless the redesign would pose a health and/or a safety risk) (Adamo et al. 1991 and Winka, 1991).

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'I I 8 I

Other Regulations

In September 1990 New Jersey enacted the 'Toxic Packaging Reduction Act." The bill differs somewhat from the CONEG model especially in areas of definition, intent, compliance and interpretation (CONEG, 1991). The bill establishes a fee system to reimburse the New Jersey Department of Environmental Protection and Energy's (DEPE) administrative costs. The law's enforcement provisions also include administrative fines.

NEW YORK

Hazardous Wastes

New York hazardous waste regulations cover items containing the target metals (Taylor, 1991). New York regulates hazardous wastes based on both the rate of generation and the amount of wastes accumulated (stored) at the site of generation.

Batieries

New York regulates the collection and disposal of lead-acid batteries. The regulations require manufacturers and distributors to take back lead-acid batteries; prohibits the disposal of any lead-acid battery; requires retailers to accept batteries for recycling; and mandates a refundable $5.00 deposit system. The deposit is refundable for a 30 day period if an old battery is returned. In addition, the regulations require retailers to display a sign at the point of purchase informing customers regarding the law. The law also contains provisions for regulatory inspection and civil penalties (Taylor, 1991).

In the 1991 legislative session, four proposed changes to the states's environmental laws were considered, including bills requiring (1) battery manufacturers to collect and recycle household batteries, (2) reductions in the mercury content of batteries and removal of rechargeable batteries from solid waste; (3) household battery recycling; and (4) return of uncollected deposits on batteries to a state solid waste management fund.

Other Regulations

In 1990, New York passed a law based on the CONEG model legislation on the use of toxic metals in packaging (Reberia, 1991). The new law has enforcement provisions that include civil monetary penalties, criminal fines and jail terms for intentional misconduct. In addition, it mandates that the state conduct a risk assessment to evaluate additional toxic substances in packaging for future regulatory consideration (CONEG, 1991).

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RHODE ISLAND

Hazardous Wastes

Rhode Island’s hazardous waste regulations regulate all commercial and industrial generators of any amount of waste (Migliore, 1991).

Batteries

Rhode Island has a mandatory lead-acid battery recycling program. In the past three years, legislative initiatives regarding household battery collection and recycling have been unsuccessful. In 1991, the legislature considered a bill to require manufacturers and/or distributors of batteries to minimize metal content and provide disposal information on the battery label (Boulay, 1991).

Other Regulations

Rhode Island adopted the CONEG legislative proposal without any changes in i99r (CONEG 1991).

VERMONT

Hazardous Wastes

Vermont’s hazardous waste regulations mirror the Federal RCRA Subtitle C requirements and regulate wastes containing lead, cadmium and mercury (Gulka, 1991).

Batteries

Vermont has passed a law requiring the reduction of mercury in alkaline- manganese batteries, prohibiting the sale of mercuric-oxide button cell batteries, and prohibiting the disposal of dry cell batteries and commercially used lead-acid, mercuric- oxide, silver-oxide, nickel-cadmium batteries at landfills. This law was based on regulations developed in Mirmesota and Europe (Cohen, June 1991).

The Vermont Department of Environmental Conservation (DEC), is currently collaborating with consumers, recyclers, and manufacturers on implementing the program. This effort involves research to: (1) determine the harm created by use and disposal, (2) determine possible substitutions, (3) create a management system, (3) evaluate the effectiveness of a depositjreturn system and (4) define the manufacturer’s responsibility. The law provides deadlines if these cooperative actions are not successful (Cohen, June 1991).

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The law prohibits the disposal of rechargeable batteries in MSW landfills in any district or town where a collection program is in place. In addition, the law prohibits the sale of consumer products with rechargeable batteries unless the battery is easily removable. The manufacturer must label the product to inform the consumer that the battery must be recycled or properly disposed. The law prohibits the sale of alkaline batteries that contain more than 0.025 percent mercury by weight, except button batteries, after February 1, 1992; prohibits the sale of alkaline button batteries that contain more than 25 milligrams of mercury, after January 1, 1992; and prohibits the sale of any alkaline batteries that contain mercury after January 1, 1996 (Cohen, June 1991).

Background research for the law found that non-consumer users contribute a larger amount of batteries to the waste stream than consumers users. A New Hampshire study reported that over 70 percent of mercuric-oxide batteries were from non-consumer sources. The law mandates battery collection and recycling provisions for commercial users as follows:

1) Collection of batteries for recycling from commercial and industrial sources that follows the distribution network in reverse making the collection system cost effective.

2) Recycling of non-consumer batteries to develop the infrastructure and markets necessary to make consumer battery recycling feasible (Cohen, June 1991).

Other Rerrulations

Vermont has passed a law to govern the use of toxic metals in packaging. The bill is based on the CONEG toxic metals in packaging reduction law. However, the Vermont bill is unique because it contains an amendment that requires other states, with a combined population of 10 million to have toxic metals in packaging reduction laws before the law would become activated in Vermont (CONEG, 1991).

EUROPEAN REGULATIONS

In the early 1950s, European countries began expressing concerns over the toxicity of the target metals. In the mid-l960s, European governments started examining these concerns. In the 198Os, concerns escalated over the disposal of wastes generated at hospitals prompting increased regulation.

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._ , . .

MEDICAL AND INFECTIOUS WASTES

In Switzerland, West Germany and Sweden, national medical waste management regulatory policies are in place (Hershkowitz, 1990). These regulations govern all wastes generated by hospitals, including solid waste. The earliest regulations were enacted in the late 1960s by West Germany. These three countries have the following medical and infectious waste regulatory practices in common:

regulate small generators as well as large;

require pharmacies to accept expired medicines for disposal and keep records on collection and disposal;

define medical waste classifications;

require a knowledgeable hospital employee to sort the medical wastes into appropriate classifications (Switzerland, and West Germany require physicians to participate in sorting);

require tracking and documentation of each shipment in the form of a manifest;

regulate the transportation of all medical wastes;

regulate disposal methods and locations; and

establish enforcement provisions and penalties (in West Germany mis-classification can result in a license revocation, fines and jail sentences for physicians).

BATTERIES

At present Sweden, Switzerland, and West Germany include batteries in their definitions of hazardous wastes and control their collection, recycling and disposal. They promote recycling whenever possible. Austria and Denmark consider battery disposal in MSW unacceptable. These countries have proposed legislation that requires separation, recycling, labeling and deposits for batteries (Adamo et al. 1991)

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As a result of the MHW's study, "Guidelines for Medical Waste Treatment" were developed for proper treatment of all wastes generated at medical facilities (Takakura, 1991). The Guidelines list eleven categories of "Major Wastes Discharged from Medical Institutions [sic]". They include: industrial waste; ash; sludge; waste oil, acid, alkalis, plastics, glass and ceramics, pieces of metal, and rubber; soot and dust; and domestic wastes (Japan, 1991). The wastes containing the target metals, including spent batteries, generated by medical facilities are regulated as industrial wastes (Takakura, 1991 and Japan, 1991).

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JAPANESE REGULATIONS

Medical and infectious wastes, and heavy metals have been topics of regulatory interest in Japan. Thus, the Japanese government has established "Guidelines for Medical Waste Treatment" and regulations addressing the collection and disposal of all batteries.

MEDICAL AND INFECTIOUS WASTES

The Japanese government is specifically concerned about the disposal of heavy metals in the regulated medical and infectious waste streams.

Accidental viral infections and physical wounds are not the only risks rising from improperly disposed of medical wastes. Also present is the risk of contamination from toxic substances such as mercury. Unlike viral particles and pathogenic microorganisms, these contaminants can not htx treated by simple sterilization and incineration (Furuta, 1988).

In July of 1988, the Ministry of Health and Welfare (MHW) commissioned a two year survey of medical institutions to evaluate their waste disposal methods and to, "elucidate problem areas, determine optimal treatment procedures and anticipate future trouble spots" (Furuta, 1988). Initial reports indicate that:

... although many types of medical waste are classified as 'industrial waste'

... many of these items are discarded as general waste, usually mixed in with other types of innocuous garbage. Reportedly, the only items being processed correctly as industrial waste are those items with recycling value, such as waste oils, acids, alkalis, x-ray films, and glass (Furuta, 1988).

As early as September of 1988, the MHW considered requiring that hospitals dispose of wastes containing substances, such as mercury and cadmium, "at treatment facilities for general industrial waste" (Furuta, 1988).

BATTERIES

The Japanese have been recycling industrial and commercial (including hospital) sources of batteries for almost ten years. The government is not actively involved in this program. Sales agents and manufacturers mediate all recycling efforts, including educating the consumer, collecting and recycling the batteries. Spent batteries are collected when a new one is purchased. "[Mlercury batteries are collected by battery manufacturers ... through retail stores, involving 100 percent of the population" (Hershkowitz, 1987). smelter (Nishikubo, 1991).

The burden of the regulation is on the manufacturer and the

The Japanese government conducted a two-year study regarding the collection and recycling of "primary" batteries including household, rechargeable and button batteries. In 1985, they constructed a primary battery recycling plant in northern Japan (NEMA, 1989) to recover usable metals such as mercury, zinc and iron from waste household batteries. They recovered 0.05 percent mercury, 14 percent iron scraps, and 54 percent zinc residue by weight of metal to the weight of the batteries. The treatment costs are covered by those who dispose of the primary batteries and other wastes, and also by the sales of recovered usable materials (Clean Japan Center, 1988). As of 1987, a government-sponsored community collection of cylindrical batteries, involved over 72 percent of the Japanese population, more than 86 million people (Hershkowitz, 1987).

SUMMARY

Many states in the Northeast have more stringent hazardous waste regulations than the federal requirements because they are concerned about the toxicity of the target metals and other hazardous materials in wastes and their potential leachability in MSW 1 and f i 11 s .

There are a number of state initiatives that may affect the amount of metals entering municipal solid waste facilities. Table 4-1 summarizes the activities of the Northeastern states. The Table shows that a number of states have passed laws requiring mercury phase-outs in certain dry cell batteries, prohibitions on the disposal of certain dry cell batteries, and reductions of toxic metals in packaging and certain dry cell batteries.

The development of a national policy promoting source reduction of toxic metals in solid waste would help states to solve problems associated with the disposal of the target metals. In order to create incentives to foster pollution prevention of the target metals in HSW, regulatory policy should focus on source reduction incentives and requirements. In addition, commercial institutions and the regulatory community must work together to foster pollution prevention.

I II I I I r I I I I I

46

I I I I I I I B li 8 1 I I 1 t I I I I --

P .

State

cr

ME

MA

NH

NJ

NY

RI

VT

Table 4-1

SUMMARY OF SELECTED STATE LEAD, CADMIUM AND MERCURY RELATED LAWS

Batteries

NiCd Packaging Redesign, Label & Recycle

Hg Elimination in Alkaline & Mercuric-Oxide Batteries; Nonremovable NiCds Banned; Hospitals Collection of Hg Batteries and NiCds

None

State-Wide Recycling Plan Being Implemented

NiCd Packaging Redesign Label & Recycle, Hg Reductions in Alkaline, Mercuric-Oxide & Other Batteries

NiCd Collection & Packaging Redesign & Label; Hg Reductions in Alkaline, Mercuric-Oxide & Other Batteries

None

NiCd Packaging Redesign & Recycling; Hg Reductions in Alkaline, Mercuric-Oxide & Other Batteries

Packaging

CONEG Model Lead Wine Wrappers Exemption

CONEG Model

Pending CONEG Model

CONEG Model Lead Wine Wrappers Exemption Risk Assessment Addition

Substantially Changed from CONEG Administrative Service Fee for Government Agency Involvement

CONEG Model Risk Assessment Addition

CONEG Model

CONEG Model

CONEG = Coalition of Northeastern Governors proposed reduction of toxic metals in packaging. NiCd = Nickel-Cadmium Batteries Hg = Mercury

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CHAPTER 5

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OPTIONS AND FUTURE STUDIES

This report has focused on many of the difficulties in identifymg the sources of lead, cadmium and mercury in hospital solid waste. However, this study was intended as only the first step in developing an understanding of the generation of the target metals in these wastes.

The researchers recommend that expanded, more detailed studies be conducted in order to evaluate multiple hospitals of different size and range of services. Such studies should include hospitals that are already attempting waste identification programs, such as the Medical Center Hospital in Vermont. The research group suggests that future studies assess the financial and environmental benefits to the facilities of reducing or eliminating toxic metals in their wastes. These studies could also examine what hospitals are doing to reduce their use of products containing the target metals and their haprdous and solid waste as models for others. In addition, these studies could examine the following options for action in greater detail and conduct expanded analysis of the potential benefits and problems associated with pursuing them.

OPTIONS FOR ACTION

Although this report was designed as a scoping study, a primary task was to identify options for future public action for reducing the target metals in HSW. The researchers identified five options that could reduce metals in HSW: phase-outs and other technology-forcing actions, additional research, educational programs, market forces, and regulation. These options are described in the following sections.

PHASE-OUTS AND OTHER TECHNOLOGY-FORCING ACTIONS

Phase-outs and other technology-forcing actions are those that could be taken by government to encourage, create or force a change in technology to reduce metals in solid and hazardous waste. Voluntary or regulated phase-outs or other technology- forcing actions for products containing the target metals have been applied to a number of consumer items, some of which have been described in previous sections of this report. For example, lead and mercury in paints have been phased-out by EPA, and mercury in alkaline batteries is being reduced or phased-out by state requirements.

The benefits of phase-outs and technology-forcing activities include the reduction of hazardous substances disposed in solid waste and used in manufacturing products and consequently the reduction of amounts of toxic waste needing to be landfilled or

48

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incinerated. In addition to environmental benefits, economic benefits may include the development of new markets for reformulated goods and the creation of new jobs. Other benefits may include increased safety in the management, treatment and disposal of hazardous wastes; decreased liability; improved worker safety; and lower disposal and treatment costs.

However, such actions could also affect (1) development costs of new products; (2) toxicity of substituted materials; (3) consumer response to changes in the product; (4) replacement technology; and ( 5 ) jobs in industries trying to adapt to the new requirements. However, there are many cases of technology-forcing regulatory actions that result in both economic and environmental benefits.

The time period for phase-outs or other technology-forcing actions could be lengthy. If they are driven by regulations, there could be a public comment period and potential litigation from the manufacturers that use and/or produce the affected metals. These actions would be most successful in conjunction with other options for action discussed in this paper. Educating the public, conducting research into possible substitutes and identifying potential incentives may foster successful phase-outs or other technology-forcing actions.

RESEARCH

Research could expand the amount of information available on metals in hospital wastes. The waste sorting studies initiated by the University Medical Center in Vermont and the Minnesota Healthcare Partners are examples of research programs that provides actual waste composition data and allow for scientifically-based solutions to problems (Griffin, 1991).

Research requires significant capital funding. Therefore, funding for research should be carefully directed toward specific problems and questions. Unless well managed, additional studies may not provide useful answers or solutions to the problem under analysis.

However, research is an important building block for other options. Educational programs, phase-outs and policy change options should be initiated based on adequate research.

EDUCATIONAL PROGRAMS

Educational programs are key to addressing environmental issues because solutions often involve a change in public behavior. These changes may require public

49

1,

expenditures, regulatory alterations and phase-outs. The public should be educated about the reasons for making a change in order to foster its acceptance.

An educational program regarding metals in the hospital waste could be aimed at hospital staff, communities and manufacturers. Improved knowledge can lead to consumer awareness and pressure for waste reduction and recycling. Similarly generators may pressure manufacturers to offer products with lower metals content.

Educational programs require significant sustained funding over a long period of time. However, they are essential to successful implementation of source reduction policies and regulations.

MARKET FORCES

Relying on market forces to decrease metals in the waste stream is another option. This option may be driven by cost effectiveness, consumer: and purchasers’ desires, overall resource use, local conditions, and liability associated with the waste’s ultimate disposal (Postrel, 1991). Facilities, such as hospitals, may focus more attention on their solid wastes if they perceive an opportunity for cost savings. Source reduction has become increasingly popular as the costs at landfills and incinerators and liability for ultimate waste disposal increases. For example, hospitals now pay an average of $700 per ton for disposal of medical waste. Analysts predict that by the end of the decade these disposal costs will increase to $1,800 per ton (Hazardous Waste Report, 1991).

Commercial haulers charge hospitals by the weight of waste generated, usually by the ton. Therefore, hospitals have a cost incentive to reduce their waste generation. For example, the case study hospital recently initiated a recycling program for office paper and cardboard and reduced their wastes and disposal costs.

For hospitals with on-site incinerators or boilers that burn wastes, liability is a concern due to potential emissions containing, among other constituents, the target metals. Facilities could manage their wastes so that sources of lead, cadmium and mercury are reduced or removed thereby reducing or eliminating this potential liability.

Relying on market forces for pollution prevention and recycling can be the least expensive option for action since it is primarily driven by cost concerns. However, market forces can be slow to produce the desired change in generator behavior. In addition, secondary markets for recycled materials are constantly fluctuating, therefore metals reclamation may be cost effective one year but not the next.

A combination of relying on market forces in conjunction with the other options for action may be the most successful in reducing heavy metals in solid waste., For example, government-sponsored research programs investigating possible materials that

50

could be used as substitutes for the target metals would help promote changes in the market.

REGULATION

The federal and state governments could improve the compliance of hospitals with hazardous and solid waste provisions by adopting a more comprehensive or holistic regulatory approach to the problem. Such a program could be modeled on those in Europe and Japan. The Japanese national waste policy for the medical community appears to take a whole facility approach. Japan’s strategy provides the regulated community with the necessary guidance and information to assure proper management of the waste stream’s components. This policy aids compliance by eliminating misunderstanding regarding proper disposal methods and locations for the wastes generated by the medical community.

The benefits of this kind of holistic approach are numerous: the regulated community is educated, thus minimizing or eliminating the improper disposal of the metals of concern; unified enforcement standards are adopted; an educated populous prods market forces; and research programs are directed towards the minimization and/or elimination of toxic metal contaminants, forcing the creation of better alternatives.

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! !I I REFERENCES

1 I I I I I I I I 1 I I I I 1 I I

Adamo, Janeen M.; Dean R. Johnson; Carl M. Pawlowski; and Patricia B. Whiting, "Source Reduction of Toxic Metals in Household Batteries: Federal, State, and Industry Initiatives", Prepared for The Northeast Waste Management Officials' Association (NEWMOA), May 1991.

Agency for Toxic Substances and Disease Registry (ATSDR), U.S. Public Health Service, 'Toxicological Profile for Cadmium", ATSDWP-88/08, March 1989.

Agency for Toxic Substances and Disease Registry (ATSDR), U.S. Public Health Service, 'Toxicological Profile for Lead", Draft Document, February 1988.

Agency for Toxic Substances and Disease Registry (ATSDR), U.S. Public Health Service, 'Toxicological Profile for Mercury", Draft Document, December 1989.

Alleg, Karen, Environmental Scientist, Environmental Protection Agency (EPA), Resource Conservation Recovery Act Hotline, Personal Communication, June 26, 1991.

Allen, Susan, "Cadmium: A Human Exposure Assessment", Master of Science Degree Project, Tufts University, October 1989.

American Hospital Association, "AHA Guide to the Health Care Field", AHA, Chicago, 1990.

American Hospital Association, "AHA Hospital Statistics: A Comprehensive Summary of U.S. Hospitals 1990-1991", AHA, Chicago, 1990.

Battery Council International (BCI), Proposed Model Battery Recycling Legislation, Public Relations Information Package, April 1990.

Boulay, Lynn, Rhode Island Department of Health, Office of Environmental Health Risk Assessment, Personal Communication, July 1, 1991.

Brand, Kirby, President, Brand Company, South Hamilton, Massachusetts, Personal Communication, July 1991.

Brunner, Calvin R. and Courtney H. Brown, "Hospital Waste Disposal by Incineration", Journal of Air Pollution Control Association, October 1988.

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Clark, Marjorie, "Laboratory Research to Identify the Predominant Sources of Pollutant Precursors in MSW and Impact on Emissions, Ash and Leachate", Presented at NEAPCA Conference, Providence, Rhode Island, February 1989.

Clayton, G.E. and F.E. Clayton, editors, Patty's Industrial Hygiene and Toxicology, 3rd Revised Edition, Volume 2 4 John Wiley and Sons, New York, 1981.

Clayton, Jackie, Universal Medical Center Hospital, Burlington, Vermont, Hospital Administrator, June 19, 1991 and July 2, 1991.

Clean Japan Center, 'Test Report of Demonstration Plant for Recycling Mercury Containing Wastes", August 1988.

Coalition of Northeastern Governors (CONEG), Progress ReDort of the Source Reduction Task Force, 1990.

Coalition of Northeastern Governors (CONEG), 'Source Reduction Council of CONEG; Model Toxics Legislation - Summary", December 14, 1989.

Coalition of Northeastern Governors (CONEG), "Toxics Committee Source Reduction Council of CONEG; Model Toxics Legislation -Background", July 22, 1991.

Cohen, Andrea, Household Hazardous Waste Coordinator, Solid Waste Management Section, Vermont Department of Environmental Conservation, Letter to Terri Goldberg, June 19, 1991.

Cohen, Andrea, Household Hazardous Waste Coordinator, Solid Waste Management Section, Vermont Department of Environmental Conservation, Waterbury, Vermont, Personal Communication, June 1991.

Connecticut Regulations for Environmental Protection, Section 22a-209-15.

Connecticut (a), State of: Regulation of Department of Environmental Protection Concerning Biomedical Waste Management, Section 22a-209, 1989.

Connecticut, State of, Connecticut Public Acts 89-385, An Act Concerning Reduction of Packaging Materials and DisDosable Products, (1989).

Council on Dental Materials (CODM), "Recommendations in Dental Mercury Hygiene", Journal of American Dental Associations, Vol. 109, October 1984. (as reported in EPA, 1991).

Davis, New Jersey DEP, Hazardous Waste Section, Personal Communication, July 1991.

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53

Denison, Richard k and Ellen K Silbergeld, "Risks of Municipal Solid Waste Incineration Environmental Perspective", Risk Analvsis, Vol. 8, No. 3, 1988, pp. 343-355.

Derby, James, The Cadmium Situation from a Zinc-Cadmium Producer's Point of View, Second International Seminar of Battery Waste Management, Dearfield Beach, Florida, November 5-7, 1990.

Desmarais, Anne Marie, "Health Effects and Risk Assessment", Lecture, Tufts University, Fall 1990.

Devine, Bud, Environmental Engineer Connecticut Department of Environmental Protection, Hazardous Materials Management Group, Personal Communication, July 19, 1991.

Director of Material Management, Case Study Hospital, Personal Communication, June 1991.

Donahue, James, Public Affairs Representative, Duracell, Connecticut, Personal Communication, July 199 1.

Doyle, B.W.; D.A. Drum; and J.D. Lauber, 'The Smoldering Question of Hospital Wastes", Pollution Engineering, July 1985, pp. 35-39.

Ecology and Environment, Inc., "Waste Audit Study: General Medical and Surgical Hospitals", Prepared for Toxic Substances Control Program, California Department of Health Services, August 1988.

Eliason, Clifton, Bureau of Solid Waste Management, Maine Department of Environmental Protection, Augusta, Maine, Personal Communication, June 28, 1991

Engineering Department, Case Study Hospital, Personal Communication, July 1991.

Environmental Protection Agency (EPA), 40 CFR Parts 261, 264, 265, 268, 271, and 302, "Hazardous Waste Management System; Identification and Listing of Hazardous Waste; Toxicity Characteristics Revisions", March 29, 1990.

Environmental Protection Agency (EPA), 40 CFR Parts 261, "Hazardous Waste Management System: Identification and Listing of Hazardous Wastes; Hazardous Waste recycling", April 22, 1988.

Environmental Protection Agency (EPA), Environmental Criteria and Assessment Office, "Health Effects Assessment for Cadmium", EPA/600/8-89/087, August 1988.

54

Environmental Protection Agency (EPA), Inside EPA Weekly Report, July 6, 1990 and July 13, 1990.

Environmental Protection Agency (EPA), Municipal Environmental Research Laboratory, "Municipal Solid Waste: Resource Recovery", Proceedings of the Seventh Annual Research Symposium, EPA-600/9-81-002~, March 1981.

Environmental Protection Agency (EPA), Municipal Solid Waste Program, Office of Solid Waste, "Characterization of Products Containing Lead and Cadmium in Municipal Solid Waste in the United States, 1970-2000", EPA/530-SW-89-015A, January 1989.

Environmental Protection Agency (EPA), Municipal Solid Waste Program, Office of Solid Waste, "Characterization of Products Containing Mercury in Municipal Solid Waste in the United States, 1970 to 2000", OSW-EPA-530-R-92-013, April 1992.

Environmental Protection Agency (EPA), Municipal Solid Waste Task Force, 53 Fed. Reg. 78, 13316 (1988).

Environmental Protection Agency (EPA), Municipal Solid Waste Task Force, 53 Fed. Reg. 78, 1888 (1990).

Environmental Protection Agency (EPA), Subtitle J, 40 Code Federal Regulations 259 (1990).

Environmental Protection Agency (EPA), Office of Solid Waste and Emergency and Emergency Response, "Promoting Source Reduction and Recyclability in the Marketplace", EPN530-SW-89-066, September 1989.

Environmental Protection Agency (EPA), Office of Research and Development, "Mercury", July 1986.

Environmental Protection Agency (EPA), Office of Solid Waste and Emergency Response, "Characterization of Municipal Solid Waste in the United States, 1960 to 2000 (Update 1988)", EPA/530-SW-88-033, March 1988.

Environmental Protection Agency (EPA), Office of Solid Waste and Emergency Response (OSWER), "Land Disposal Restrictions: Summary of Requirements", February 1991.

Environmental Protection Agency (EPA), Office of Solid Waste, 'The Solid Waste Dilemma: An Agenda for Action", EPN530-SW-89019, February 1989.

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Environmental Protection Agency (EPA), Office of Solid Waste, "The Solid Waste Dilemma: An Agenda for Action", Background Document, PB88-25 1137, September 1988.

Environmental Protection Agency (EPA), Office of Solid Waste, "The Solid Waste Dilemma: An Agenda for Action", Appendices A-B-C, PB88-25 1145, September 1988.

Environmental Protection Agency (EPA), Office of Solid Waste and Emergency Response, 'Tracking Medical Wastes", EPN530-SW-89-020, May 1989.

Environmental Protection Agency (EPA), Office of Toxic Substances, "Use and Substitutes Analysis for Lead and Cadmium Products in Municipal Solid Waste", EPA-530-R-92-010 April 1992.

Environmental Protection Agency (EPA), Public Law 94-580, "Resource Conservation and Recovery Act of 1976", Amendments of Solid Waste Disposal Act (42 U.S.C. 3251), October 21, 1976.

Environmental Protection Agency (EPA), Resource Conservation and Recovery Act Amendments - Recycling, 40 Code Federal Regulations 266 (1990)

Environmental Protection Agency (EPA 'ublic Law 98-616, "Hazardous and Solid Waste Amendments of 1984", Sur;:..ie C of RCRA, January 23, 1984.

Environmental Protection Agency (EPA), 40 CFR 260 "Hazardous and Solid Waste Amendments of 1988", Subtitle J of Resource Conservation Recovery Act, 1988.

Environmental Protection Agency (EPA) Risk Reduction Engineering Laboratory, "Guides to 'Pollution Prevention: Research and Educational Institutions", EPA/625/7-90/010, June 1990.

Environmental Protection Agency (EPA), Risk Reduction Engineering Laboratory, "Guides to Pollution Prevention: Selected Hospital Waste Streams", EPA/625/7- 90/009, June 1990.

Environmental Protection Agency (EPA), Toxic Characteristic, 40 Code Federal Regulations 261 (1990).

"EPA Pushes Tougher Lead Air Rules to Pave Way for Battery Recycling", Inside EPA Weekly Report, Vol.11 N0.28, July 13, 1990.

56

Furuta, Yukari, "Ministry of Health and Welfare: Focusing Attention on Proper Disposal of Contaminated Medical Waste", Comline Dailv News Biotechnologv and Medical, (Comline News Service), September 20, 1988.

Gentile, Henry, Vice President, Ace-Lon, Malden, Massachusetts, Personal Communication, July 1991.

Glasser, H.; D.P.Y. Chang; and D.C. Highman, "An Analysis of Biomedical Waste Incineration", Journal of Air and Waste Management Association, September 1991, pp. 1180-1188.

Goldberg, Terri, Pollution Prevention Program Manager, Northeast Waste Management Officials' Association, Letter to Capstone Group, July 5 , 1991.

Green, Mary, Environmental Scientist, U.S. Environmental Protection Agency, Washington D.C., Personal Communication, May 1991.

GriSfin, Maura, "Medical Recycling Program May Set Example for Nation", Rutland Herald, May 27, 1991.

Gulka, Gary, Chief, Hazardous Waste Management Section, Vermont Department of Environmental Conservation, Waterbury, Vermont, Personal Communication, June, 1991.

Hazardous Waste Report, "Medical Waste Management Market Explored in Arthur Little Analysis", Vol. 12, No. 23, July 15, 1991, pp. 12.

Hershkowitz, Allen, "Doing it Better: Medical Waste Management in Switzerland, West Germany and Sweden", Presented at First U.S. Conference on Municipal Solid Waste Management, June 13-16, 1990.

Hershkowitz, Allen and Eugene Salerni, Garbage Management in Japan: Leading the w, Inform, Inc., 1987.

Hickman, Donald, "Cadmium and Lead in Bio-Medical Waste Incinerators", Master of Science Degree Project, University of California Davis, 1988.

Japan: Guideline for Medical Waste Treatment, supplied by Nobuyki Takajura, First Secretary Ministry of Health & Welfare, Embassy of Japan, Washington D.C., [June 19911.

Jas, Victoria, Manager of BioSafe.ty and Environmental Programs, Dartmouth Hitchcock . Medical Center, Hanover, New Hampshire, Personal Communication, July 1992.

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57

Smble Glass, Technical Services, Vineland, New Jersey, Personal Communication, July 1991.

I

Koephe, Robert, Environmental Scientist, Environmental Protection Agency (EPA), Office of Toxic Substance Control, Region I, Personal Communication, July 5, 1991.

Korzun, Edwin k and Howard H. Heck, "Sources and Fates of Lead and Cadmium in Municipal Solid Waste", Journal of Air Waste Management Association, September 1990, pp. 1220-1226.

Lead Industries Association, Inc. (LIA), "Potential Human Exposures from Lead in Municipal Solid Waste", Prepared by Industrial Economics, Inc., May 21, 1991.

Lee, C.C.; George L. Huffman; and Richard P. Nalesnik, "Medical Waste Management: The State of the Art", Environmental Science and Technolo~y, 1991, pp. 360-363.

Lockwood, Paul, Waste Management Specialist, New Hampshire Department of Environmental Services, Waste Management Division, Personal Communication, June 14, 1991.

Maine, State of, "Hazardous and Solid Waste Management Standards", 06-096 Code of Maine Regulations, Sections 800 through 871.

Maine, State of, Maine Revised Statutes Annotated Title 38, Section 1317.

Maine, State of, "Medical and Infectious Wastes", 38 Maine Revised Statutes Annotated 1310-X [1990].

Maine, State of, "Medical and Infectious Wastes", 38 Maine Revised Statutes Annotated 1604 (1989).

Maintenance Staff, Case Study Hospital, Personal Communication, July 1991.

Massachusetts, Commonwealth of, An Act Relating to Infectious Waste House Bill Document Number 1962 (1991).

Massachusetts, Commonwealth of, An Act Relative to the Collection, Tranmortation, Storage. Treatment, and Dis~osal of Infectious Waste House Bill Document Number 1963 (1991).

Massachusetts, Commonwealth of, An Act Relative to the Sanctions for the ImDroDer DisDosal of Medical Waste, House Bill Document Number 875, (1991).

Massachusetts, Commonwealth of, Chapter 310 CMR 30.000, Hazardous Waste Regulations, December 21, 1990.

Massachusetts, Commonwealth of, Chapter 310 CMR 19,000, Solid Waste Management Facilitv Regulations, September 28, 1990.

Massachusetts, Commonwealth of, Department of Environmental Protection, Division of Air Quality Control, Approved Hospital and Pathological Incinerators, July 10, 1991.

Massachusetts, Commonwealth of, Department of Environmental Protection, "Hazardous Waste Information for Laboratories", April 1991.

Massachusetts, Commonwealth of, Department of Environmental Protection, 'Toward a System of Integrated Solid Waste Management: The Commonwealth Master Plan", June 1990.

Massachusetts, Commonwealth of, "Hazardous Waste Rules and Regulations", 310 Code Massachusetts Regulations 30.000 (1990).

Massachusetts, Commonwealth of, Reduction of Toxic Metals in Packaging, House Bill Document Number 5922 (1991).

Massachusetts, Commonwealth of, Senate and House of Representatives Bill No. 1962, An Act Relatine to Infectious Waste, January 1991.

Massachusetts, Commonwealth of, Senate and House of Representatives Bill No. 875, Act Relative to the Sanctions for the ImDroDer Disposal of Medical Waste, 1991.

Massachusetts, Commonwealth of, "Solid Waste Management Facility Regulation", 310 Code Massachusetts Regulations 19.000 [ 19891.

Massachusetts, Commonwealth of, "State Sanitary Code Title VIII", 105 Code Massachusetts Regulations 480.000 [ 19901.

Massachusetts Division of Hazardous Waste and Solid Wastes Management, Department of Environmental Protection, "Infectious Waste Disposal and Transport", November 1989.

Massachusetts, General Laws of the Commonwealth of Massachusetts Chapter 706 (1986).

Massachusetts, "Hazardous Waste Management Act", General Laws of the Commonwealth of Massachusetts Chapter 21C (1976).

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Massachusetts Institute of Technology (MIT), "Household Hazardous Products and Waste in New Hampshire; A Technical Summary in Support of the Development of a Management Plan", June 1990.

Massachusetts, "Public Health", General Laws of the Commonwealth of Massachusetts Chapter 706 (1986).

Massachusetts, "Solid Waste Management Act", General Laws of the Commonwealth of Massachusetts Chapter 111 [1989].

Materials Management Secretary, Case Study Hospital, Personal Communication, June 1991.

Migliore, Beverly, Principal Engineer, Rhode Island Department of Environmental Management, Division of Air and Hazardous Materials, Personal Communication, July 5, 1991.

Minnesota Healthcare Partners, Inc., "Study of Non-Burn Technologies for the Treatment of Infectious and Pathological Waste and Siting Considerations", April 1992.

Moore, Robert, Sales Representative, Baxter Medical Supply, Pittsburgh, Pennsylvania, July 1991.

Murdock, Barbara S., "Mercury: An Atmospheric Hitchhiker", Health and Environment Digest, May 1990.

National Electrical Manufacturers Association (NEMA), '!Household Battery Disposal", written statement, 1990.

Nelson, M. and M. Steinberger, "Waste Reduction and Recycling at Hospitals: Building a Healthy Community", Resource Recvcling, November 1990, pp. 32-38.

New Hampshire, State of, Fact Sheet #WMD-1990-42, Infectious (Medical) Solid Waste Combustor Ash DisDosal Policy, December 1990.

New Hampshire, State of, New Hampshire Revised Statutes Annotated, Section 147 A through D [1990].

New Hampshire, State of, New Hampshire Revised Statutes Annotated, Section 403.05.

New Hampshire, State of, New Hampshire Code of Administrative Rules, Department of Public Health, 1901.03 (July 1991).

60

New Hampshire, State of, "Reduction of Toxic Metals in Packaging" Amendment to the Laws of New Hampshire Chapter 195, House Bill Document Number 1406, (1990).

New Hampshire, State of, Solid Waste Rules, He-P 1901, Public Health Law, 1989.

New Jersey, State of, "Hazardous Waste Regulations" New Jersey Administrative Code, Title 7:26).

New Jersey, State of, 'Toxic Packaging Reduction Act", Amending Chapter 13: 1E-199 to 13: 1E-207 sub-section 10.11, Chapter 94, Senate Document Number 2700, (1991).

New York, State of, Batterv ManaPement and DisDosal, Amendment to the Environmental Conservation Law Section 27-0719, Senate House Bill Number 4275-B (1991).

New York, State of, Household Batterv Collection and RecvcIinP Act, Senate House Bill Number 1055 (1991).

New York, State of, Mercurv, Alkaline. Nickel-Cadmium, Small Lead-Acid Batterv Handling - and DisDosal, Amendment to the Environmental Conservation Law Section 27-0719, Senate House Bill Number 3055 (1991).

New York, State of, New York Code of Rules and Regulations, Title 5, Section 70 [ 19891.

New York, State of, New York Code of Rules and Regulations, Title 6, Section 370 - 376 [ 19891.

New York, State of, New York Environmental Conservation Law, Title 3, 7, 9, and 15)

New York, State of, New York Public Health Law, Article 13, Title 13, [1990].

New York, State of, Senate House Bill Number 7308 (March 1991).

New York, State of, Solid Waste Management Fund, Senate House Bill Number 5121 (1991).

Nicholson, Frederick, Public Affairs Representative, Battery Products Alliance, Washington D.C., Personal Communication, July 1991.

Nishikubo, Hiro-hiko, Environmental Attache, Ministry of Health and Welfare, Embassy of Japan, Washington D.C., Personal Communication, July 10, 1991.

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Office of Technology Assessment, Facing America's Trash: What Next for Municipal Solid Waste? U.S. Government Printing Office OTA-0-452, 1989.

O'Melia, Barry and David Crosley, "Biomedical Waste Management Strategies", prepared for Hazardous Materials Treatment, Tufts University, Spring 1990.

Pierce, Richard, Sales Representative, Leasing Service Inc., Boston, Massachusetts, Personal Communication, July 1991.

Postrel, Virginia I. and Lynn Scarlett, "Talking Trash: There's a Solution to America's but it Isn't What You Think", Reason, AugustBeptember 1991, pp. 23-31.

Radiologist, Case Study Hospital, Personal Communication, July 1991.

Reberia, Gus, Solid Waste Management Specialist, New York Department of Environmental Conservation, Bureau of Pollution Prevention, Solid Waste, Personal Communication, July 22, 1991.

Ratkje, William L, "Once and Future Landfills", National Geographic, May 1991, pp. 1 1 6- 134.

Reutlinger, Nancy and Dan de Grassi, "Household Battery Recycling: Numerous Obstacles, Few Solutions", Resource Recycling, April 1991, pp. 24-29.

Rhode Island and Providence Plantations, State of, R23-17-INF, and R23-16.2-INF, Rules and Regulations Governinp the Management of Infectious Wastes in Health Care Facilities and Laboratories, April 1989.

Roberts, James, Massachusetts Division of Solid Wastes Management, Department of Environmental Protection, Personal Communication, June 10, 1991.

Rugg, Mack, "Reducing the Lead and Cadmium Content of Municipal Solid Waste and Residue", Camp Dresser & McKee, Inc., February 1989.

Rugg, Mack, "Sources of Lead and Cadmium in Municipal Solid Waste--A Survey of the Literature", Camp Dresser & McKee, Inc., August 1988.

Schwartz, Elaine, Sales Representative, Burlington Medical, Haverhill, Massachusetts, Personal Communication, July 1991.

SCS Engineers, Weston, Rhode Island Solid Waste Composition Studv: Final ReDort, for the Rhode Island Solid Waste Management Corporation, October 17, 1990.

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Seeger, Edwin, "Legislature/Regulatory Activities Regarding Lead in Washington", Second International Seminar of Battery Waste Management, Dearfield Beach, Florida, November 5-7, 1990.

Shifano, A. "Waste Management to Save You Money -- At Last!", Journal of Healthcare Materiel Manapement, April 1991, pp. 36-41.

Smith, Marlene, Sales Representative, Goldman Paper Co., Randolph, Massachusetts, Personal Communication, July 1991.

Stevens, Jeffrey B., "Disposition of Toxic Metals in the Agricultural Food Chain. 1. Steady-State Bovine Milk Biotransfer Factors", Environmental Science & Technolow, Vol. 25, No. 7, 1991, pp. 1289-1293.

Takakura, Nobuyki, First Secretary Ministry of Health & Welfare, Embassy of Japan, Washington D.C., Personal Communication, July 10, 1991.

Taylor, Michelle, Environmental Engineer 111, New York Department of Environmental Conservation, Bureau of Pollution Prevention, Personal Communication, July 22, 1991.

Thomas, Constance, Solid Waste: An Overview of 1990 State Legislative Activity, International Health Policy Project: The George Washington University in cooperation with Tufts University Center for Environmental Management, December 1990.

University of Kentucky (Institute of Industrial Research), "Kentucky-Indiana Metropolitan Region Solid Waste Disposal Study", Volume I. Jefferson County (Kentucky), 1970.

U.S. Department of Health and Human Services, "Guidelines for Protecting the Safety and Health of Health Care Workers", DHHS (NIOSH) Publication No. 88-119, September 1988.

Vermont, State of, Vermont Senate Bill Number 106, House of Representative Bill Number 296 (1991).

Vermont, State of, Vermont Statutes Annotated Title 10, Section 6621b, [ 19901.

Versa, Sheila, State of Maine Legislative Research Library, Researcher, Personal Communication, July 19, 1991.

Waalkes, Michael P., Tadmium and Human Health", Health and Environment Digest, May 1991.

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Watson, Tom, 'The Unsavory Side of Battery Recycling", Resource Recvcling, April 1991, pp. 46-50.

Weinberg, David, Bergeson & Newman, Renulatory and Legislative Overview: Lead-Acid and Nickel-Cadmium Batteries Remarks of David B. Wienbern. ESQ, Second International Seminar of Battery Waste Management, Dearfield Beach, Florida, November 5-7, 1990.

Whittier, Scott, Director, Division of Licensing and Enforcement, Bureau of Oil and Hazardous Materials Control, Maine Department of Environmental Protection, Augusta, Maine, Personal Communication, June 20, 1991.

Windholz, M., editor, The Merck Index. 10th ed., Merc and Co., Inc., 1983.

Winka, Michael, NJ DEP, Hazardous Waste Section, Personal Communication, July 1991.

Yergeau, Sharon, Administrator, New Hampshire Department of Environmental Services, . Waste Management Planning Bureau, Personal Communication, June 10, 1991.

Zielinski, A. M., Lighting Environmental Operation, General Electric Lighting, Cleveland, Ohio, Personal Communication July 1991.

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PERSONAL CONTACTS

Ayres, Thomas, Public Relations Officer, University Medical Center Hospital, Burlington, Vermont, June 14, 1991.

Bergstrom, Stephen, Environmental Engineer, Bureau of Waste Prevention, Division of Hazardous Waste, Recycling Section, MA DEP, July 1991.

Buogione, Paul, Data Manager for the DEP Manifest System, Bureau of Waste Prevention, Division of Hazardous Waste, Recycling Section, MA DEP, July 1991.

Continental Glass, Technical Services, Chicago, Illinois, July 1991.

Coming Glass, Technical Services, Corning, New York, July, 1991.

Dentch, Milton, Battery Research Section, Polaroid Corporation, Waltham, MA, July 1991.

Fa t in , Harry, Battery Research Section, Polaroid Corporation, Waltham, MA, July 1991.

Gagman, Susan, Public Relations, Polaroid Corporation, Cambridge Massachusetts, July 1991.

Ghent, Sandy, Sales Representative, Harris Hospital Care, South Berlin, Massachusetts, July 1991.

Hamilton, Louise, City of Boston Environmental Affairs, July 1991.

Holl, Denise R., Environmental Coordinator, Ampacet Corporation, Mount Vernon, New York, July 1991.

Kelly, James, Data Manager for the DEP Manifest System, Bureau of Waste Prevention, Division of Hazardous Waste, Recycling Section, MA DEP, July 1991.

Lambert, Geri, Solid Waste Management, Department of Environmental Protection, Boston, Massachusetts, July 3, 1991.

Leach, Connie, Environmental Consultant to the University Medical Center Hospital, Burlington, Vermont, June 19, 1991

McVay, Douglas, RI DEP, Incineration Information, July 1991.

Papettie, Lisa, Environmental Scientist, EPA RCRA Boston Region 1, July 1991.

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Phillips, Victoria, Environmental Analysts, Bureau of Waste Prevention, Division of Hazardous Waste, Recycling Section, MA DEP, July 1991.

Reifinger, Marty, Battery Information, NJ DEP, Hazardous Waste Section, July 1991.

Rilandi, Steven, Legislative Actions, NJ DEP, July 1991.

Shaner, Holly, Surgical Nurse, University Medical Center Hospital, Burlington, Vermont, June 19, 1991

Sirull, William, Environmental Analysts, Bureau of Waste Prevention, Division of Hazardous Waste, Recycling Section, MA DEP, July 1991.

Tepper, Joseph, Environmental Engineer, Bureau of Waste Prevention, Division of Hazardous Waste, Recycling Section, MA DEP, July 1991.

Terumo Corporation, Technical Services, Somerset, New Jersey, July 1991.

Werkley, Howard, Medical Waste Specialist, MA Department of Public Health, July 1991.

Willison, Mischell, EPA Headquarters Washington, D.C., OSW, Medical Waste Tracking Information, July 1991.

Wrenn, Nancy, Environmental Analysts, Bureau of Waste Prevention, Division of Hazardous Waste, Recycling Section, MA DEP, July 1991.

Yergeau, Sharon, New Hampshire Department of Environmental Services, Waste Management Division, 1992.

Zahadi, Nancy, EPA Headquarters Washington DC, Batteries Information, July 1991.

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