The U.S. Environmental Protection Agency signed the final rule regulating medical waste incinerators in the United States. This regulation affects over 2,000 on-site and commercial medical waste incinerators nationally.

The emission limit requirements are not the same for all incinerators but are dependent upon waste-burning capacity. Also, the provisions are more stringent for new hospital incinerators (construction begun after June 20, 1996) and for incinerators modified six months or after the new regulations' publication in the Federal Register.

Key provisions - crucial to understanding and staying compliant with the regulations, include:

Coverage: The regulation applies to all hospitals, nursing homes, research labs, other healthcare facilities, and commercial waste disposal companies operating or planning to operate incinerators primarily for hospital and/or medical/infectious waste. Exceptions: crematories, incinerators that burn only pharmaceutical, chemotherapy, low-level radioactive, or pathological wastes; and co-fired combustors that burn less than 10% by weight hospital and/or medical infectious waste.

Targeted Pollutants: Emission limits are promulgated for particulate matter (PM), carbon monoxide (CO), dioxins and furans, hydrogen chloride (HCl), sulfur dioxide, nitrogen oxides, lead, cadmium, and mercury. All incinerators are subject to a stack opacity limit of 10%. In general, emission limits for existing incinerators were based on the average of the best performing 12% of incinerators in a subcategory.

Compliance: Each facility must conduct an initial performance test using specified EPA test methods for opacity and for most of the pollutants listed above. Subsequent performance tests for opacity, PM, CO, and HCl must be conducted annually. Less stringent requirements exist for incinerators that meet the "rural criteria" or that demonstrate compliance for three consecutive years.

For a complete summary of the new clean air regulations, contact your EPRI HCI Regional Manager. Also available are databases and referrals to new and emerging alternative treatment technologies.

• Immunization for vaccine-preventable diseases;
• Isolation precautions to prevent exposures to infectious agents; and
• Management of healthcare personnel exposures to infected persons.

The two-part guidelines provide an overview of infection control processes and will ultimately replace the CDC Guidelines for Infection Control in Hospital Personnel.

The new guidelines will be addressed through the infection control committee. Both the infection control and employee health departments will be instrumental to its implementation.

HEALTH FACILITIES MANAGEMENT - November 1997

Burning issue--med waste rules tough but flexible

Fire up that incinerator! The EPA's final rules have been issued. The proposed rules, initially issued in 1995, were tough and would have forced most hospitals to shut down their incinerators. The new rules recognize differences among hospitals and call for strict but varying emission levels for new and existing units with different waste-burning capacities. Small, rural facilities that deal with small quantities of waste generally face less stringent emission standards. Within a year all states must adopt the federal rules or establish rules that meet or exceed the national guidelines.

Definition. The new regulations apply to "any device that combusts any amount of hospital waste or medical/infectious waste." In this rule, the EPA broadly defines "hospital waste" as "discards generated at a hospital." The EPA also adopted the Medical Waste Tracing Act's definition of "medical/infectious waste," which includes cultures and stocks of infectious agents, human pathological waste, human blood and blood products, used and unused sharps, and isolation waste. So all hospital incinerators and other incinerators that burn medical/infectious waste from hospitals are subject to these regulations.

The regulations do not apply to incinerators used only for pathological waste, such as disposed animal carcasses, as well as several other specialized incinerator applications. However, excluded facilities are or soon will be covered under the rules.

Emission limits. Relatively stringent emission limits are defined for nine specific pollutants. Different limits are established according to whether an incinerator is new or existing and according to size category. New incinerators are defined as those built after June 20, 1996, and existing incinerators are those built on or before June 20, 1996.

The regulations also include a special category for incinerators defined as "small, rural" facilities. That category includes incinerators with capacities of not more than 200 lbs/hr, which burn fewer than 2,000 lbs/wk and which are located more than 50 miles from the borders of Standard Metropolitan Statistical Areas. Emission limits and other requirements are less stringent for incinerators in this category than for those in the other categories.

Waste management plan. Hospitals with incinerators must prepare and submit a "plan" to increase medical waste segregation, recycling, reuse and other methods for possible reducing incinerated waste quantities. Such "plans" should consider different goals for achieving waste reduction on a site-specific basis.

Compliance, performance testing. All incinerator facilities are required to have an initial compliance test for regulated pollutants. Each year thereafter all facilities will be required to be tested for selected pollutants to verify continued compliance. Facilities passing such tests for the first three years will then require testing every third year.

Monitoring requirements. All incinerator facilities must have devices that continuously monitor and record all key system operating parameters.

Operator training and qualifications. Incinerator operators must be "trained and qualifies" by successfully completing a state-approved training course. At a minimum, such courses must comprise 24 hours of classroom training covering a comprehensive curriculum of environmental and incineration fundamentals. After completing the course, operators must pass a test administered by the course instructor.

Qualified operators must also complete an annual four-hour refresher course. The hospital should ensure and document that its incinerator system operators are qualified and that an appropriate review program is established.

Facility inspections. Incinerator facilities are required to be inspected annually to verify the operations and performance of the system and the condition of all its components and devices. Repairs and adjustments identified and determined necessary in the inspection report are to be completed within 10 days unless a different compliance schedule is negotiated.

Recording and recordkeeping. Operating data and records, test reports, inspection reports, and operator qualification records must be kept on file for at least five years. Incidents of emission violations or noncompliance should be reported immediately.

Be proactive.

If you operate an incinerator:

• Begin evaluating your waste management options now. Determine which rules apply to you (see chard on p. 36) and keep tabs on the time frame for these new requirements.
• Stay tuned to developments in your state on this issue. Your state and metropolitan associations are good resources.
• Look to the AHA and its personal membership groups--the American Society for Healthcare Engineering (ASHE) and the American Society for Healthcare Environmental Services (ASHES)-- for educational programs.

• Keep tabs on waste costs. These rules could affect the price structure of commercial vendors. Report updates to the AHA or your state and metropolitan associations.