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Tribal Compliance Assistance Center

Healthcare Management

Background Information
Hospitals, Healthcare Workers and Emergency Response
Pollution Prevention and Healthcare Programs

Background Information

EPA's Profile of the Healthcare Industry (PDF) (155 pp, 1.4MB, About PDF) and the Healthcare Environmental Resource Center Exit EPA Disclaimer Web site provide detailed compliance and pollution prevention information on the healthcare sector. Tribes may also want to obtain information from the Indian Health Service Web site.

Tribes, the federal government (i.e., the Indian Health Service), and a variety of public and private parties operate hospitals and healthcare facilities in Indian country to support the healthcare needs of tribal communities and tribal members. These operations include small hospitals, clinics, physician and dentist offices, diabetes centers, home-based care, alternative medicine, nutritional counseling, pharmacies, dental and orthodontic care, substance abuse treatment, mental health counseling, and preventive care. These operations also include ambulatory healthcare services, nursing and residential care facilities, and social assistance.

Many healthcare activities also result in the generation of waste and air or water pollution. Healthcare operations can contribute to the presence of mercury, dioxin, and other persistent, bioaccumulative toxics (PBTs) in the environment. Healthcare operations also generate a wide variety of hazardous waste, such as chemotherapy and antineoplastic chemicals, mercury, solvents, formaldehyde, photographic chemicals, radionuclides, and waste anesthetic gases. In addition, healthcare providers produce tons of solid waste and may also own or operate hospital/medical/infectious waste incinerators (HMIWI), underground storage tanks, aboveground storage tanks, boilers, air conditioners, motor vehicle fleets, and engage in other activities associated with construction and property management. Pesticides, including but not limited to disinfectants, are also used in healthcare facilities.

Producing an exhaustive list of every healthcare activity that impacts the environment or is regulated would be extremely cumbersome and ultimately would distract the focus from those functions within the healthcare industry that create problem wastes and pollution. That said, EPA's Profile of the Healthcare Industry identifies key functions and activities that are the major sources of waste and pollution within health sector institutions.

After identifying environmental impacts by activity, healthcare facilities can begin to address the major waste streams and emission sources. Healthcare wastes can be categorized as follows:

Using environmentally friendly alternatives to normal products can help reduce a healthcare installations overall waste material.

In each case, healthcare providers may be subject to multiple federal and tribal environmental laws and regulations. Potentially applicable federal laws include: the CAA, CWA, EPCRA, and RCRA. Tribal governments should obtain EPA's Profile of the Healthcare Industry and review a variety of Tribal Profile sections, including those on Construction/Property Maintenance, Waste Management, and Pesticides Management to better assess their regulatory requirements.

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Hospitals, Healthcare Workers and Emergency Response

Producing an exhaustive list of healthcare activity that impacts the environment would be extremely cumbersome, even in a single hospital room there are numerous activites that can produce waste.

Hospitals are vital to the success of any emergency response plan. Ambulance crews and emergency room personnel must know how to transport and treat victims of exposure to hazardous chemicals. Without such knowledge, victims of chemical accidents can contaminate emergency rooms and cause hospitals to close temporarily.

Doctors, nurses, and trained medical professionals can be a valuable resource in emergency planning and response. They can also be an important source of information about risks to the public health in their communities. Some of the ways they can participate in emergency planning include:

In a more general sense, health professionals may be approached to provide and interpret information on chemicals and their impacts on patients. The law allows health professionals to gain access to chemical identity information, even if it is claimed as trade secret, in three different situations:

Except for medical emergencies, a written statement of need and a confidentiality agreement must accompany a health professional's request for a chemical's identity.

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Pollution Prevention and Healthcare

Web sites with resource information for source reduction include the Hospitals for a Healthy Environment (H2E) Exit EPA Disclaimer site and the Sustainable Hospitals Exit EPA Disclaimer project site. H2E is designed to help healthcare facilities enhance work place safety, reduce waste and waste disposal costs and become better environmental stewards and neighbors.

Within the healthcare industry, numerous opportunities exist to prevent pollution. By implementing well-planned pollution prevention strategies, facilities can improve efficiencies, save money, minimize adverse environmental impacts, and create a healthier workplace. Opportunities vary from facility to facility and relate to the volumes and types of activities. The Profile of the Healthcare Industry and the Healthcare Environmental Resource Center Exit EPA Disclaimer Web site provide an understanding of some of the most common pollution prevention opportunities available and highlight some examples of strategies by waste type.

The Healthcare Profile provides pollution prevention information on the following key topics:

The treatments chosen to address health issues also can have environmental impacts and less toxic treatments, where appropriate, can prevent pollution. For example, pharmaceutical use of lindane-containing products was banned in California because residues from these products were contaminating drinking water. Because lindane can be toxic to the brain and other parts of the nervous system, the Centers for Disease Control and Food and Drug Administration permit the use of lindane-containing products for treatment of head lice and scabies with caution and only when treatment with safer alternatives has failed.

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For related information visit EPA’s National Indian Country Enforcement and Compliance Assurance Priority site and EPA’s Enforcement and Compliance Assurance Program in Indian country site.

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