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H2E Mercury Waste Virtual Elimination Model Plan

VIEWS: 44 PAGES: 184

									                        Hospitals for a Healthy Environment
                        Mercury Waste Virtual Elimination Model PLan

                                Table of Contents
List of Tables                                                                 v
List of Figures                                                                vi
Acknowledgments                                                               vii

1 . Introduction                                                               1
1.1     Background on Mercury                                                  2
1.2     Health Impacts of Mercury Exposure                                     3
1.3     Mercury in Medical Facilities                                          3
1.4     Mercury Pollution Prevention                                           4
    1.4.1 Benefits of Mercury Pollution Prevention                             4
2. How to Establish Mercury Pollution Prevention in Your Hospital              5
2.1     Get Started                                                            5
    2.1.1 Get Support From The Top                                             5
    2.1.2 Identify and Involve Staff                                           5
    2.1.3 Make It A Team Effort                                                5
2.2     Gather Data                                                            7
    2.2.1 Identify Mercury Sources                                             7
    2.2.2 Evaluate Current Handling and Disposal Techniques                    7
    2.2.3 Evaluate Current Policies                                            7
    2.2.4 Evaluate Mercury Product Alternatives                                7
2.3     Establish Realistic Goals and Implementation Plans                     8
    2.3.1 Institute Best Management Practices                                  8
    2.3.2 Eliminate Mercury-Containing Products                                8
    2.3.3 Make Mercury Pollution Prevention Easy                               8
    2.3.4 Establish Purchasing Policies                                        8
2.4     Educate Staff                                                          9
2.5     Measure and Document Success                                           9
    2.5.1 Evaluate the Status of the Mercury Pollution Prevention Program      9
2.6     Advertise Success                                                     10

                       Hospitals for a Healthy Environment
                      Mercury Waste Virtual Elimination Model PLan

                          Table of Contents, cont.
3. Best Management Practices for
    Mercury-Containing Products in the Hospital                             11
3.1     Introduction                                                        11
3.2     Fever Thermometers                                                  16
    3.2.1 Alternatives for Mercury-containing Thermometers                  16
    3.2.2 Take-home Thermometers                                            16
    3.2.3 Keep Mercury Thermometers out of Red Bags and Sharps Containers   16
    3.2.4 Recycling/disposal of Mercury-containing Thermometers             16
    3.2.5 Are Non-mercury Thermometers Adequate Diagnostic Tools?           18
3.3     Syphygmomanometers                                                  19
    3.3.1 Are Mercury-free Sphygmomanometers as Reliable and Accurate       19
             as Mercury-containing Sphygnomanometers?                       19
    3.3.2 Refilling Mercury-containing Sphygnomanometers                    20
    3.3.3 Recycling/disposal of Mercury-containing Sphygnomanometers        20
3.4     Gastrointestinal Tubes                                              21
    3.4.1 Recycling/disposal of Mercury-containing Gastrointestinal Tubes   21
3.5     Dental Amalgam and Mercury                                          21
3.6     Laboratory Chemicals                                                22
    3.6.1 Alternatives for Mercury-containing Laboratory Chemicals          22
    3.6.2 Recycling/disposal of Mercury-containing Laboratory Chemicals     23
3.7     Pharmaceutical Products                                             24
    3.7.1    Alternatives for Mercury-containing Pharmaceutical Products    24
3.8     Cleaners and Degreasers                                             25
    3.8.1 Mercury as a Contaminant                                          25
    3.8.2 Alternatives for Mercury-containing Cleaners and Degreasers       25
3.9     Batteries                                                           26
    3.9.1 Mercury-containing Batteries                                      26
    3.9.2 Alternatives to Mercury-containing Batteries                      26
    3.9.3 Recycling/Disposal of Batteries                                   27
3.10 Lamps                                                                  27
    3.10.1 Energy Efficiency of Mercury-containing Lamps                    27
    3.10.2 Recycling/Disposal of Mercury-containing Lamps                   28
    3.10.3 U.S. Environmental Protection Agency Green Lights Program        28
3.11 Electrical Equipment                                                   28
    3.11.1 Alternatives for Mercury-containing Electrical Equipment         28
    3.11.2 Recycling/Disposal of Mercury-containing Electrical Equipment    29

                        Hospitals for a Healthy Environment
                        Mercury Waste Virtual Elimination Model PLan

                             Table of Contents, cont.
3. Best Management Practices for
   Mercury-Containing Products in the Hospital (continued)
3.12 Take-Back Programs for Thermostats                                       30
3.13 Thermostat Probes in Gas Appliances                                      30
   3.13.1 Alternatives for Mercury-containing Thermostat Probes               30
   3.13.2 Recycling/Disposal of Mercury-containing Thermostat Probes          30
3.14 Industrial Thermometers                                                  31
   3.14.1 Recycling/Disposal of mercury-containing industrial thermometers    31
3.15 Pressure Gauges                                                          32
   3.15.1 Recycling/Disposal of mercury from mercury-containing gauges        32
3.16 Plumbing                                                                 33
3.17 Spills                                                                   33
   3.17.1 Mercury Spill Prevention                                            33
   3.17.2 Mercury Spill Response Plan                                         34
   3.17.3 Mercury Spill Preparation                                           35
   3.17.4 Storage Areas                                                       35
   3.17.5 Hospital Employee Health and Safety                                 35

4.      Costs and Benefits of Mercury-Free Alternatives                       36
4.1     Introduction                                                          36
4.2     Limitations                                                           37
4.3     Hospital Costs (Internal)                                             37
    4.3.1 Purchase Price (Mercury-Containing Products and Alternatives)       38
    4.3.2 Spill Cleanup Costs                                                 39
    4.3.3 Training                                                            40
    4.3.4 Storage and Disposal                                                40
    4.3.5 Ensuring Compliance                                                 41
    4.3.6 Potential Non-Compliance                                            41
    4.3.7 Human Health Risks                                                  41
4.4          Environmental and Health Costs (Societal Costs)                  42
    4.4.1 Cost of Polluted Lakes                                              43
    4.4.2 Health Effects                                                      43
    4.4.3 Societal Costs and Pollution Prevention                             43
4.5          Mercury Cost Savings and Cost Comparison Worksheets              45
4.6          Summary of Results                                               50

                        Hospitals for a Healthy Environment
                        Mercury Waste Virtual Elimination Model PLan

                              Table of Contents, cont.

5.      Mercury Reduction Case Studies                                     51
5.1     Strong Memorial Hospital, Rochester, New York                      51
5.2     F.F. Thompson Hospital, Canadaigua, New York                       62
5.3     Michigan Health Care Institutions                                  62
    5.3.1 Detroit Water and Sewerage Department                            63
    5.3.2 Butterworth Hospital (now Spectrum Health), Grand Rapids         64
    5.3.3 Corning Clinical Laboratory (now Quest Diagnostics), Wyoming     64
    5.3.4 Riverside Osteopathic Hospital, Trenton                          65
    5.3.5 University of Michigan Health System, Ann Arbor                  65
    5.3.6 Genesys Health System, Grand Blanc                               65
    5.3.7 Henry Ford Hospital, Detroit                                     66
5.4     Massachusetts Water Resources Authority / Medical, Academic and
        Scientific Community Organization (MASCO) Mercury Work Group       67
5.5     Newton-Wellesley Hospital, Netwon, Massachusetts                   68
5.6     Dartmouth Hitchcock Medical Cente, Lebanon, New Hampshire          78
5.7     Minnseota Health Care Institutions                                 80
    5.7.1 Mayo Clinic, Rochester                                           80
    5.7.2 St. Cloud Hospital, St. Cloud                                    80
    5.7.3 Hennepin County Medical Center, Minneapolis                      80
    5.7.4 St. Joseph’ Medical Center, Brainerd                             81
    5.7.5 Mercy Hospital, Moose Lake                                       81
    5.7.6 St. Mary’ Medical Center, Duluth                                 81
5.8              s
        Childen’ Hospital, Milwaukee, Wisconsin                            85
5.9     Kaiser Permanente, California                                      88

                           Hospitals for a Healthy Environment
                          Mercury Waste Virtual Elimination Model PLan

                               Table of Contents, cont.

Appendix                                                                              Page
A. Instruments and Products Used in Hospitals, That May Contain Mercury                A-1
B. Laboratory Chemicals That May Contain Mercury                                       B-1
C. A National Listing of State Regulatory Information Contacts                         C-1
D. Benefits of a Mercury Pollution Prevention Program in Your Hospital (Handouts)      D-1
E. Annual Assessment of the Hospital’ Mercury Pollution Prevention Program             E-1
F. Wastewater Sampling and Analysis                                                    F-1
G. Sample Letter Requesting Certificate of Analysis and Sample Certificate of Analysis G-1
H. Vendor Product Mercury-Content Disclosure                                           H-1
I. Educational Resources for a Mercury Pollution Prevention Program                     I-1
J. Prevent Mercury Pollution: Use Best Management Practices for Amalgam
   Handling and Recycling (Dental Section)                                              J-1
K. National Listing of Mercury Waste Recyclers                                         K-1
L. Infrastructure Control Measures                                                      L-1
M. Strong Memorial Hospital Mercury Spill Clean-Up Procedures                          M-1
N. Glossary of Terms                                                                   N-1
O. Bibliography                                                                        O-1

Table                                                                                Page
1. Mercury Waste Reduction Best Management Practices Tool                              12
2. Alternatives for Mercury-Containing Fever Thermometers                              17
3. Alternatives for Mercury-Containing Sphygmomanometers                               18
4. Alternatives for Mercury-Containing Gastrointestinal Tubes                          20
5. Alternatives for Mercury-Containing Laboratory Chemicals                            22
6. Pharmaceutical Uses of Mercury                                                      24
7. Mercury Content of Selected Cleaning Products: Information from
    MWRA/MASCO Mercury Work Group                                                       25
8. Batteries (Newly Purchased) That May Contain Added Mercury (1998)                    26
9. Mercury-Containing Electrical Equipment                                              29
10. Alternatives for Mercury-Containing Industrial Thermometers                         31
11. Alternatives for Mercury-Containing Laboratory Manometers                           32
12. Mercury Cleanup Costs                                                               40

                         Hospitals for a Healthy Environment
                         Mercury Waste Virtual Elimination Model PLan

                            Table of Contents, cont.

Figure                                                                  Page
1. Mercury Transport and Bioaccumulation                                   2
2. How to Establish Mercury Pollution Prevention in Your Hospital          6

                        This document was based upon
  Reducing Mercury Use in Health Care: Promoting a Healthy Environment,
            prepared by the Monroe County Department of Health,
     in cooperation with Strong Memorial Hospital, Rochester, New York
       and the Monroe County Department of Environmental Services,
         under a grant from the U.S. Environmental Protection Agency.
       This revision was prepared by the American Hospital Association,
         members of the Hospitals for a Healthy Environment Mercury
Virtual Elimination Workgroup and the U.S. Environmental Protection Agency,
        in cooperation with the Momroe County Department of Health.

                                  John D. Doyle
                                  County Executive

Chapter 1                                                                                         Introduction

     The purpose of this manual is to help hospitals start mercury pollution prevention programs or accelerate
programs that have already begun. The U.S. Environmental Protection Agency and the American Hospital Asso-
ciation have committed to a voluntary agreement to virtually eliminate mercury waste in hospitals and health
systems by 2005, and are asking healthcare providers to join with us in this effort to help reach these environ-
mentally sound goals.
     There are many reasons why it makes sense for hospitals to reduce their use of mercury. For example, new
federal air and water regulations greatly reduce the amount of mercury that is allowed to be discharged from a
municipal wastewater system or an incinerator. In addition, the capability to measure mercury at lower levelsmakes
it easier for regulatory agencies to identify those who are not in compliance. As a result of these developments,
regulatory compliance costs are rising. By implementing the best management practices described in this
manual, you can reduce the level of mercury in the environment and avoid the need to increase your investment
in pollution controls and waste disposal.
     The manual offers general guidance on how to initiate a program and technical guidance for implementing
the program. The manual includes:

Chapter 1
    • Information about mercury and its impact on           Chapter 4
      people and the environment                                • Costs of mercury-free alternatives and
    • Overview of pollution prevention strategies                 worksheets for comparing the costs of
Chapter 2                                                         replacing mercury-containing products
    • How to start a mercury pollution prevention                 versus keeping them
      program in your hospital                              Chapter 5
    • How to monitor your program, educate staff                • Case studies from hospitals that have
      and measure success                                         implemented mercury reduction
Chapter 3                                                         programs
    • Alternatives for mercury-containing                   Appendices
      products                                                  • Additional information and national lists
    • Best management practices for handling,                     of state contacts and mercury recyclers
      recycling and disposing of mercury-containing
      products still in use

                       MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                           1
Chapter 1
1.1 - Background on Mercury

    Mercury is a toxic metal that occurs naturally in the environment. There are both inorganic forms and organic
forms of mercury. As shown in Figure 1 below, many of the forms of mercury circulate in the environment, moving
from land or water to air and back again, and the forms of mercury may change from one to another as they
    Human activities significantly redistribute mercury and release it into the environment. They allow mercury
that was formerly unavailable to the biosphere* to be mobilized and carried to new areas via air and water. In
the water or soil, microorganisms can convert inorganic mercury into a more toxic organic form, methylmercury.
Fish take in methylmercury from their diet and from water passing over their gills. They bioaccumulate the
methylmercury in their bodies because the rate of intake of methylmercury is much greater than its elimination.
Methylmercury bioaccumulates in the tissues of a fish throughout its lifetime. It can build up to high levels in
predator fish at the top of the aquatic food chain -- levels that are tens of thousands to millions of times above
the level found in the surrounding water. Fish with high levels of methylmercury may be caught and consumed by
humans, waterfowl or other wildlife.

* Words in italics are defined in the Glossary (Appendix N).

                                                     Figure 1.

Chapter 1

1.2 - Health Impacts of Mercury Exposure                    1.3 - Mercury in Medical Facilities
                    All forms of mercury are toxic to hu-       The following lists show some of the common uses
               mans, but the various forms of organic       of mercury that may be found in hospitals.
               and inorganic mercury have different
               toxicity. Generally, organic forms are
               much more toxic than inorganic forms.        Medical uses:
                                                              • Thermometers
                    The organic forms of mercury are
                                                              • Sphygmomanometers (blood pressure
               primarily neurotoxins. Exposure (even
               to small amounts of mercury) can dam-
                                                              • Esophageal dilators (also called bougie
               age the brain and nervous system. The
               developing brain of a fetus or child is
                                                              • Cantor tubes and Miller Abbott tubes (used
               especially vulnerable to organic mercury,
                                                                to clear intestinal obstructions)
               so pregnant women should be espe-
                                                              • Feeding tubes
               cially careful to avoid exposuire. Inor-
                                                              • Dental amalgam
               ganic forms of mercury primarily affect
                                                              • Laboratory chemicals (fixatives, stains,
the kidney, but are also neurotoxins. Other organs
                                                                reagents, preservatives)
and systems of the body can be harmed by exposure
                                                              • Medical batteries
to mercury.
                                                              • Pharmaceutical preservatives
    A human can be exposed to mercury via all three
routes of exposure: inhalation, ingestion, and dermal.
The most likely routes of human exposure are inhala-        Nonmedical uses common in medical settings:
tion of inorganic mercury vapor after a spill or during
                                                              • Cleaning solutions with caustic soda or
a manufacturing process, or ingestion of methylmer-
                                                                chlorine that were contaminated with mer-
cury from contaminated fish. The fetus of a mother
                                                                cury during the production process
who eats contaminated fish can be exposed to me-
                                                              • Batteries
thylmercury via the mother’ blood, and an infant can
                                                              • Fluorescent lamps and high-intensity dis-
be exposed by ingestion of breast milk. Mercury can-
                                                                charge lamps
not be removed from fish before they are eaten be-
                                                              • Nonelectronic thermostats
cause methylmercury accumulates in the muscle, not
                                                              • Pressure gauges
the fat. Most of the states in the U.S. issue caution-
                                                              • Some electrical switches used for lights and
ary advisories about eating the fish caught in many of
their waterways because of the presence of mercury.
These advisories represent conservative measures
                                                                More complete lists can be found in Appendix A
to protect human health.
                                                            and Appendix B. There is minimal risk of mercury
    Because mercury spills in                               exposure during normal use of products that are
hospitals often occur in small, en-                         handled correctly. However, problems may occur if
closed spaces, employees should                             the mercury in a product is exposed to air, or if a
be aware of the proper clean-up                             product is not properly discarded so as to keep mer-
procedures and risks of mercury                             cury out of the environment.

                         MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                      3
Chapter 1
1.4 - Mercury Pollution Prevention                           Best Management Practices (BMPs) for the man-
                                                          agement of mercury within hospitals might involve:

    Concerns about the health impacts of mercury
                                                            • Developing a plan to purchase mercury-free
are leading to mercury pollution prevention pro-
                                                              products whenever possible
grams at the federal, state and local levels. The high-
                                                            • Use of alternatives for products that contain
est priority of any pollution prevention program is
source reduction, which means not using mercury
                                                            • Recycling of mercury-containing products
in the first place. For example, some states have
                                                              when they can no longer be used
banned the deliberate use of mercury in certain prod-
                                                            • Correct handling and disposal of mercury,
ucts for which alternatives are available.
                                                              mercury-containing equipment and laboratory
    When adequate mercury alternatives are not avail-         chemicals and pharmaceuticals
able and mercury must be used, it may be possible           • Proper cleanup of spills involving mercury
to recycle it. Recycling is the second priority of mer-     • Hospital policies that support BMPs
cury pollution prevention. Disposal of mercury should
be the last resort. It is expensive and increases the         The BMPs are intended to result in the greatest
potential of mercury being dispersed into the envi-       reduction in mercury discharge to the environment
ronment.                                                  that is currently feasible for hospitals. More detailed
                                                          information on BMPs is included in Chapter 3.

                                                           1.4.1 - Benefits of Mercury Pollution Prevention

                                                               Mercury pollution prevention in the hospital pro-
                                                           vides many benefits:

                                                            • Protection of human health and wildlife by
                                                              reducing occupational exposures and re-
                                                              leases of mercury to the air, water and land
                                                              from wastewater discharges, spills, landfilling
                                                              or incineration
                                                            • Avoidance of the costs associated with the
                                                              use of mercury, such as disposal or recycling,
                                                              collection and storage prior to disposal, paper
    Pollution prevention programs are driven by vol-          work for tracking hazardous waste disposal,
untary efforts and by increasingly strict federal and         training and equipment for spill response,
state regulations. Some of the regulations govern             training for hospital employees who handle
occupational exposures and waste disposal. Other              mercury-containing products, and liability for
regulations result from the federal Clean Air Act             environmental problems or worker exposure
Amendments of 1990. The 1995 federal Great Lakes            • Avoidance of increased regulation in the
Water Quality Guidance (also referred to as the Great         future
Lakes Initiative) sets strict water quality standards                                 s
                                                            • Increase in the public’ awareness about the
for mercury in the eight Great Lakes States.                  dangers of mercury through publicity about
     (For a national list of state regulatory contacts,                     s
                                                              the hospital’ program
see Appendix C.)                                            • Enhancement of the positive public image of
                                                              the medical facility due to publicity about
                                                              success stories

Chapter 2
How to Establish Mercury Pollution Prevention               2.1.2 - Identify and involve staff
in Your Hospital                                                The CEO should designate one or more project
                                                            leaders, including:
2.1 - Get Started                                             • A person to be responsible for developing
                                                                  mercury pollution prevention policy and
      This chapter describes and advocates the team-              confirming implementation. The CEO may
building approach as the best way to approach mer-                choose to accept this role or may designate
cury reduction in most healthcare systems. A lasting              another who is familiar with the workings of
pollution prevention program requires cooperation and             the entire hospital and the procedures for
consensus-building.                                               approval of policy.
      However, it is possible for a single person to make
a substantial impact on a hospital’ mercury use. For
example, there are many instances in which a pur-
chasing manager or systems engineer took the ini-
tiative and replaced mercury-containing devices with
non-mercury device throughout a healthcare facility
(See Chapter 5, Case Studies). An empowered em-
ployee can follow through on many of this manual’       s
suggestions without involving other people. There is
no one-size-fits-all solution for every health care fa-       • A person to be responsible for implementing
                                                                the program. This should be a mercury
cility in the United States.
                                                                pollution prevention “  champion”who will be
      (For a diagram of the steps involved in building a        enthusiastic about the program and will be
mercury pollution prevention team, see Figure 2 on              dedicated to it. He or she may well be the
the following page that corresponds with this sec-              one who proposed mercury pollution preven-
tion.)                                                          tion in the first place and who approached
                                                                the hospital’ administration about it. The
2.1.1 - Get support from the top                                implementor is often a staff member who is
                                                                involved in hazardous waste and medical
     Support from the hospital’ Chief Executive Of-
                                 s                              waste management as part of his or her job.
ficer (CEO) is one critical factor in ensuring the suc-
cess of a mercury pollution prevention program. A           2.1.3 - Make It A Team Effort
first step should be to communicate with the CEO on
the benefits of such a program and to request sup-              Because mercury appears in so many different
port. A partial listing of program benefits to use in       locations in a hospital, it takes a team effort to ef-
communicating with the CEO is shown in Appendix D.          fectively reduce or eliminate its use. The project lead-
When communicating with the CEO, it is important to         ers described above should select a contact from
be clear how the CEO can help. CEO designation of           each department who will help to build support for
highly respected, knowledgeable individuals to be re-       the program and who has the authority to make
sponsible for policy and operational leadership roles       changes in the department. It may be time-efficient
is one important action for the CEO.                        to hold a “ kickoff”meeting to introduce the mercury
                                                            pollution prevention program.

                           MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                        5
Chapter 2
                         Figure 2 - How to Establish Mercury Pollution Prevention in Your Hospital

     Get support from the top
     (materials in Appendix D).

     Identify and involve staff
     (staff list in Chapter 2).                                         Evaluate current handling
                                                                        and disposal techniques
                                                                        (assessment form in Appendix E,
                                                                        staff surveys in Chapter 5).

     Identify mercury sources
     (lists of mercury-containing                                       Evaluate current policies.
     products in Appendices A and B)

                                                                        Evaluate mercury product
                                                                        alternatives (Chapter 3).
     Establish realistic goals
     and implementation
     policies.                                                           Eliminate

                                                                         Make mercury pollution
     Implement best                                                      preveniton easy.
     management practices
     (Chapter 3)                                                        Establish purchasing

                                                                        Educate staff (list of
                                                                        methods in Chapter 2.)

                                                                        Identify mercury sources.

                                                                        Evaluate current handling
     Measure success                                                    and disposal techniques.
     (Appendices A, B, E and F).

                                                                        Evaluate current policies.

     Advertise success                                                  Document reductions.
     (suggestions in Chapter 2).

Chapter 2
       However, it would not be necessary to hold
meetings as long as the program leaders effectively
                                                        2.2 - Gather Data
communicate the objectives of the program to each
person who will be involved, and maintain commu-        2.2.1 - Identify mercury sources
nication until the mercury pollution prevention pro-
gram has reached its goal. Additionally, the mer-            The first task of the implementor is to create a
cury pollution prevention program could be ad-          baseline assessment from which progress can be
dressed during routine employee meetings, such          measured. The department contacts should assist
as Safety or Infection Control meetings.                in this effort. Use the checklist of possible mercury-
                                                        containing products (see Appendix A) and/or the
                                                        checklist of categories of possible mercury-contain-
    Staff persons that should be directly involved
                                                        ing laboratory chemicals (see Appendix B) as guide-
are those with the following functions:
                                                        lines. The department contacts should perform an
     Administrator/policy leader                        audit of all uses and sources of mercury in their own
     Safety officer                                     departments.
     Purchasing officer
                                                        2.2.2 - Evaluate current policies
     Director of Pharmacy                                   Department contacts can help to consolidate the
     In-service educator/trainer                                 s
                                                        hospital’ policies that pertain to mercury such as:
     Laboratory manager                                   • Handling of mercury-containing products
     Maintenance/facilities manager                       • Mercury spill management
     Engineer                                             • Recycling or disposal of mercury-containing
     Environmental Services/maintenance                       products
     Housekeeping/environmentalservices                   • Purchase of alternatives to mercury-contain-
     manager                                                  ing products
     Hazardous waste management coordinator                 Policies that address hazardous materials man-
                                                        agement and laboratory chemical management may
     Supply manager/logistics manager
                                                        be pertinent to mercury, even though mercury may
                                                        not be mentioned specifically. Hospital policies may
    (Note that titles of hospital personnel vary con-   be collected by either of the two project leaders. The
siderably from hospital to hospital.)                   implementor should also evaluate if the current poli-
                                                        cies are being implemented throughout the hospital.

                                                        2.2.3 - Evaluate current handling and disposal techniques

                                                            The program implementor, with the assistance
    All employees of the hospital need to be informed   of department contacts, should assess the status of
about the program, including employees at off-site      current hospital practices for handling mercury and
locations.                                              staff knowledge about mercury sources and spill pre-
                                                        vention and management. (See Appendix E for a
                                                        form for recording your hospital’ baseline assess-
                                                        ment and for yearly updates.)

                        MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                          7
Chapter 2
    If possible, wastewater sample results should be     2.3 - Establish Realistic Goals and
included in the baseline assessment. If the hospital
does not currently sample wastewater, work with the      Implementation Plans
hospital’ wastewater regulator to learn what data is
available or may be collected. Total discharges of           The long-term goal of the hospital may be to elimi-
mercury in pounds should be calculated. Total dis-       nate the use of mercury entirely. This is true pollu-
charges are a better indicator of the hospital’ im-      tion prevention. It will be easier and more satisfying
pact on the environment than concentration. ( S e e      to measure success if the hospital also develops short-
Appendix F for further information.)                     term goals, such as eliminating the use of mercury
                                                         sphygmomanometers within two years. The project
2.2.4 - Evaluate mercury product alternatives            leaders should get the support of the CEO for the
                                                         goals and create a comprehensive plan that lays out
     Use the information in Chapter 3 to learn more      how the hospital will achieve its mercury-free status.
about mercury-free substitutes for the mercury           Contacts from the departments should be key play-
sources noted on your baseline assessment. Hospi-        ers in establishing the plan. Key components of the
tal suppliers can also assist you in finding mercury-    plan could include:
free alternatives.                                          • Best management practices (see Chapter 3)
     Questions to ask when comparing a mercury-con-         • Policies for the medical departments, the
taining product and a mercury-free substitute include:         purchasing department and the waste
                                                               management department
  • Is the performance of the substitute as good
                                                            • Training and continuing education programs
       as the mercury-containing product?
                                                               for staff and administrators
  • If the performance is not as good, is it ad-
                                                            • A process to review progress regularly
       equate for the purpose?
  • What are the costs for purchase? For cali-
       bration (if applicable)? For accessories? For     2.3.1 - Institute Best Management Practices
       maintenance? For disposal?
  • Is added cost offset by lower handling,                                s
                                                             Obtain the CEO’ stamp of approval for all of the
       disposal and liability costs?                     best management practices that are selected to be-
  • Does the substitute introduce new problems                                    s
                                                         come part of the hospital’ mercury pollution pre-
       for maintenance, handling or disposal?            vention program.
     (For examples of cost/savings worksheets,
     see Chapter 3.)                                     2.3.2 - Eliminate mercury-containing products

     Once a decision has                                    The highest priority of the pollution prevention pro-
been made to introduce a                                 gram is the elimination of mercury. The hospital should
substitute, it can be decided                            phase-in alternatives if evaluation has demonstrated
how to implement the sub-                                them to be acceptable and cost-effective (taking into
stitution. Some hospitals re-                            account disposal costs).
place mercury-containing
products all at once. Some
make substitutions gradually,
                                                         2.3.3 - Make mercury pollution prevention easy
replacing mercury-containing
products when they become                                    Chapter 3 of this manual describes best man-
unusable.                                                agement practices to keep mercury out of the envi-
                                                         ronment. The chapter is organized by product (ther-
                                                         mometers, laboratory chemicals, electrical equipment,

Chapter 2
     The hospital can make proper disposal easy by             Investigate opportunities for reduction in the cost
creating convenient locations for disposal of mercury      of mercury-free products or reduction in recycling costs
products, as well as other hazardous materials. Es-        through group purchasing of products and services
tablish an internal “take-back”program for electrical      with other hospitals or clinics.
equipment by placing a collection box for old equip-
ment at the point where the new equipment is picked
up. Often, older equipment is considered to be haz-
                                                           2.4 - Educate staff
ardous waste. Find a way to label mercury-contain-
ing products so that                                           Employee education in mercury pollution preven-
each user is aware of                                      tion is an important component of successful pro-
his or her responsibil-                                    grams. Determine which groups within the hospital
ity for proper use and                                     need instruction and identify the most important topics
disposal.                                                  for each group. Each segment of the training pro-
                                                           gram should be adapted for the educational level of
2.3.4 - Establish                                          the group being trained and the intensity of training
purchasing policies                                        needed.
                                                               Try to incorporate mercury pollution prevention
     Consider a policy                                     into existing training programs such as new employee
that bans the pur-                                         orientation, safety training, right-to-know training, de-
chase of any mer-                                          partment meetings and grand rounds. Training should
cury-containing item                                       be continued on an annual basis until mercury-con-
if an adequate alter-                                      taining products are eliminated from the hospital.
native exists. The
policy could include a                                       Suggested educational materials include:
requirement for spe-                                         • Train-the-trainer programs
cific authorization by                                       • Presentations at meetings
the hospital CEO or other designated official for the        • Display in cafeteria or other common area
purchase of a mercury product. Authorize the pur-            • Survey about mercury awareness
chasing department to make “      mercury-free”a part        • Articles in hospital newsletter and other
of product specifications, to insist on mercury disclo-         existing publications
sures on all products coming into the hospital, to           • Articles from professional journals or
specify the use of recovered mercury in all products            newsletters
that do not yet have mercury-free alternatives, and          • Page in Employee Handbook on the guide-
to include disposal costs in cost evaluations.                  lines for handling and disposing of mercury
     It is becoming a competitive issue for vendors to       • Paycheck enclosure
ensure that their products do not create unneces-            • Recycling guide
sary waste or that they are made from recycled ma-           • Posters, fliers and stickers
terials. Your vendors need to know that mercury-             • Signs near red bags, sharps containers and
free alternative products are required by your hospi-           sinks, and in supply areas and disposal areas
tal. Ask them to verify in writing that their products       • Labels on instruments that use mercury
are mercury-free or that they will assist you in select-        materials
ing mercury-free products. For laboratory chemicals,         • Waste management materials
a Cerii e ofAnalss can be r
       tfcat          yi            equest ed. SeeAp-        • Video
pendix G for a sample letter requesting mercury in-          • E-Mail
formation and a sample Certificate of Analysis. For          • Verbal instruction from supervisors and from
other products, a vendor product mercury-content                medical engineers who work throughout the
disclosure can be requested (see Appendix H).                   hospital

                        MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                          9
Chapter 2
  Educational materials, cont.                                  Areas where the hospital should see
                                                                measurable reductions include:
  • Incentive program to reward workers with
    good ideas that make mercury pollution                    • Mercury products purchased, used and
    prevention easier                                           stored;
  • Reports on internal audits                                • Mercury spill incidents;
                                                              • Quantity of mercury shipped off-site for
    (See list of Educational Resources for a Mercury            recycling or disposal, and associated costs;
Pollution Prevention Program in Appendix I.)                    and
                                                              • Mercury concentration in wastewater and in
                                                                incinerator ash, because mercury is not being
2.5 - Measure and Document Success                              improperly disposed.
2.5.1 - Evaluate the status of the mercury pollution
prevention program                                              Prepare periodic progress reports to communi-
                                                            cate your mercury pollution prevention achievements
     Measurement of success is a vital component of         to staff and the community.
any hospital’ pollution prevention program. It al-
lows the hospital to evaluate the effectiveness of the
program and communicate this to the staff and the           2.6 - Advertise Success
community. Start by repeating the mercury source
identification that was done at the beginning of the            List entities inside and outside of the hospital who
program (see Appendix E), using the checklist of pos-       should share in the good news of your success. De-
sible mercury-containing products in Appendix A and         velop a communication plan that includes both for-
Appendix B. If it is not practical to repeat every mea-     mal reports and informal updates on progress.
surement, select a few good indicators from the table
to track from year to year. If possible, take wastewa-        Communicate with the following groups:
ter samples or have them taken by an independent              • The hospital board of directors through an
testing laboratory so that the total mercury discharge           annual report that describes accomplish-
can be calculated and compared with the baseline                 ments, upcoming actions and expected
assessment.                                                      outcomes.
     Document the sources and quantities of mercury           • Professional medical associations and groups
that have been eliminated and new policies or changes         • Other hospitals through hospital association
to former policies instituted since the baseline as-             meetings and mailings.
sessment. Determine if they are related to mercury            • Employees through individual letters, depart-
pollution prevention. Compute the costs or savings               mental letters that can be read at meetings,
to the hospital of the substitution of mercury-free prod-        a hospital newsletter or posters. Go beyond
ucts purchased since the baseline assessment (see                a progress report and include congratulations
Chapter 4).                                                      and awards for employees who have made
                                                                 useful suggestions for reducing mercury.
                                                              • Local officials, such as wastewater treatment
                                                                 plant officials and the health department,
                                                                 through formal letters.
                                                              • The general public through press releases,
                                                                 stories in local newspapers, participation in
                                                                 health and environmental fairs, and pam-
                                                                 phlets or posters available for doctors’

Chapter 3
  Best Management Practices for Mercury-Containing Products in the Hospital

                                                                                    Mercury-containing products
3.1 - Introduction                                                              can be found almost anywhere in
                                                                                the hospital. They range from
    “ Best management practices”                                                medical instruments and clinical
for mercury are the procedures that                                             laboratory chemicals to electrical
have been found by experience to                                                equipment, pharmaceuticals and
effectively prevent the release of                                              cleaning solutions. This chapter is
mercury into the environment. By                                                organized by product (thermom-
implementing best management                                                    eters, laboratory chemicals, etc.).
practices now, the hospital can help                                            For each product the chapter de-
stay ahead of increasingly stringent                                            scribes:
regulations on mercury use and dis-                                             • The alternatives for
posal. For most mercury-contain-                                                     mercury-containing
ing products in the hospital, the pre-                                               products
ferred best management practice is                                              • The best management
to replace the item with a mercury-                                                  practices for handling and
free product. However, it may not                                                    recycling or disposing of
be possible to replace all of the hospital’ mercury                                  mercury-containing
products at once and, in a few cases, there may not                                  products that are still in use
be a substitute that is considered to be reliable and        In all cases, when a mercury-containing product
cost-effective. For these products, best manage-                                         s
                                                        is still in use, the hospital’ hazardous waste man-
ment practices are effective procedures for handling    agement coordinator will have the ultimate respon-
and either recycling or disposing of the mercury-con-   sibility for its recycling or disposal. All personnel within
taining products. Recycling is recommended. Dis-        the hospital who handle mercury-containing products
posal should be the last resort.                        must cooperate with the hazardous waste manage-
                                                        ment coordinator to develop appropriate procedures
                                                        for the handling of items to be discarded, and their
                                                        transportation to the designated hazardous waste
                                                        collection point.
                                                             A list of recommended best practices generated
                                                        by the Hospitals for a Healthy Environment Best Man-
                                                        agement Practices Work Group is provided in table 1
                                                        on the next page for your reference.

                                          RECOMMENDATION # 1:

                       MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                          11
Chapter 3
                                                      TABLE 1

                        Mercury Waste Reduction Best Management Practices Tool

     This Best Management Practices Tool is provided for considering the implementation of various Best Man-
agement Practices at a healthcare facility. The scoring included with this Best Management Practices tool is
the opinion of the Hospitals for a Healthy Environment Work Group who gathered and edited this information.
It is recommended that each individual utilizing this tool consider all aspects relative to implementation of the
practice at a specific facility. Variations in implementation of a practice may cause variations in the results

BEST MANAGEMENT PRACTICES                                       COST
RATING DEFINITIONS AND GUIDELINES                               1.   Significant added operating expense or
                                                                     capitalization to implement
  VOLUME REDUCTION                                              2.   Minor added operational costs or coststo
  1.  Increases waste volume significantly                           implement
  2.  Slight increase in waste volume                           3.   No change
  3.  No change                                                 4.   Some savings as result of implementation/
  4.  Decrease in Volume                                             capital payback in 10 yrs
  5.  Significantly decreases waste volume                      5.   Significant savings from implementation/
                                                                     capital payback in 3 years
  1.   Increases toxicity                                       EASE OF IMPLEMENTATION
  2.   Slight increase in toxicity                              1.   Difficult to implement
  3.   No change                                                2.   Some difficulty in implementation
  4.   Decreases toxicity                                       3.   No change
  5.   Significantly decreases toxicity                         4.   Easy to implement
                                                                5.   Greatly favored, Very easy implementation
  1.  Increases hazard to employee                              QUALITY OF PATIENT CARE
  2.  Slight increase in employee hazard                        1.   Negative perceptions to patient care
  3.  No change                                                 2.   Minor decrease perceived to quality of
  4.  Improves employee safety                                       patient care
  5.  Significantly improves employee safety or                 3.   No change
      eliminates hazard                                         4.   Perceived improvement to patient care
                                                                5.   Significant improvement to patient care

Chapter 3
                                        Table 1 - Mercury Waste Best Management Practices Tool

                                              Volume      Toxicity   Employee                 Ease to              Totals
                                                                                   Cost                  Care
                                             Reduction   Reduction    Safety                Implement

 #       Best Management Practice            Ranking     Ranking     Ranking     Ranking     Ranking    Ranking   Ranking

       Replace Cantor tubes/dialators
 1                                              3            5          5           4            2        4         23
       with non-mercury equivalents.

     Institute a purchasing policy that
        discourages or reduces the
 2                                              3            5          5           3            2         3        21
      purchase of mercury-containing
          products and equipment.

       Use mercury-free hematoxylin
 3                                              3            5          5           2            3         3        21

      Replace mercury blood pressure
 4        units with non-mercury                3            5          5           2            2         3        20

      Discontinue practice of sending
 5   patients / new mothers home with           3            5          3           3            3         3
          mercury thermometers.

     Replace Gauges with non-mercury                                                                                20
 6                                              3            5          4           2            3         3

     Replace Esophageal dialators with                                                                              20
 7                                              3            5          4           3            2         3
         non-mercury equivalents.

      Replace mercury thermometers
 8                                              3            5          4           2            3         3        20
      with non-mercury equivalents.

       Use rechargeable batteries for
 9                                              4           4           3           4            1         3        19
       non-critical medical devices.

        Substitute zinc for mercury
10                                              3           4           4           2            3         3        19

        Substitute electronic sensing
11     devices for mercury containing           3            5          4           2            2         3        19

     Substitute mercury thermometers
     in lab ovens, water baths, paraffin
12                                              3            5          4           2            2         3        19
     baths, refrigerators and frezers with
      alcohol or digital thermometers.

                          MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                               13
Chapter 3
                                                  Table 1 - Mercury Waste Best Management Practices Tool

                                                                                                              Patien t
                                                   Volu m e    Toxicity    E m ployee              Ease to                Totals
                                                                                         Cost                  Care
                                                  Reduction   Reduction      S a fety             Implement

 #    Best Management Practice                    Ranking      Ranking     Ranking      Ranking    Ranking    Ranking    Ranking

      Develop proper protocol for
           labelin g m ercury-
13    contain ing equipment and                       4           4            4           2           2         3         19
        protocol for disposal of
          mercury products.

            Require vendors to
14           disclose mercury                         3           4            4           3           2         3         19

           Set up program to
15     m a n a g e /rec y c l e m e r c u r y         4           4            4           2           2         3         19
              oxide batteries.

          Replace mercury-
      containing Pharmaceutical
16                                                    3           4            4           3           2         3         19
      produ c t s w i t h n o n - m e r c u r y
        containing equivalents.

        Replace Lab chem icals
17        with non-mercury                            3           4            4           3           2         3         19
             equ ivalents.

        Replace mercury oxide
18    batteries with n o n - m e r c u r y            3           4            3           3           3         3         19
              equ ivalents.

       Replace Thermostats with
19                                                    3           5            3           2           2         3         18
       non-mercury equivalents.

20       Recycle used batteries.                      4           4            3           2           2         3         18

          Replace Equipment
21    swtiches with non-mercury                       3           5            3           2           2         3         18
             equ ivalents.

           Make mercury spill
22         cleanup kits readily                       3           3            5           2           2         3         18

       Preserve stool samples
23       with alternatives to                         3           5            3           2           2         3         18
      mercury polyvinyl alcohol.

          Set up program to
           m a n a g e /recycle
24                                                    4           4            3           2           2         3         18
        fluorescent bu lbs an d
      mercury-containing lamps.

Chapter 3
                                           Table 1 - Mercury Waste Best Management Practices Tool

                                              Volume       Toxicity   Employee                  Ease to              Totals
                                                                                     Cost                  Care
                                             Reduction    Reduction    Safety                 Implement

 #       Best Management Practice             Ranking     Ranking      Ranking     Ranking     Ranking    Ranking   Ranking

      Replace dental amalgam with non-
 25                                              3            5           4           2             2        2        18
            mercury equivalents.

        Develop effective mercury spill
 26                                              3            4           4           2             2        3        18
            cleanup procedures.

        Set up program to collect and
        segregate mercury-containing
 27                                              3            5           4           2             2        2        18
      dental amalgam from waste stream
                for recycling.

         Conduct mercury training or
 28       awareness programs (e.g.,              3            3           4           2             2        3        17
        thermometer exchange days).

          Analyze/upgrade purity of
      conditioning chemicals for boilers
 29    and cooling towers to eliminate           3            4           3           2             2        3        17
        trace mercury content. (I.e.,
        mercury content in caustics).

      Check/clean plumbing traps and
 30                                              3            4           3            1            2        3        16
      sumps for mercury from past use.

                           MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                15
Chapter 3
3.2 - Fever Thermometers                                   3.2.3 - Keep mercury thermometers out of red bags and
                                                           sharps containers
3.2.1 - Alternatives for mercury-containing thermometers
                                                               Mercury volatilizes easily. When a mercury ther-
                                                           mometer has been placed in a red bag or sharps
    See the table of alternatives for mercury-
containing thermometers following                           container that is incinerated or autoclaved, the mer-
                                                            cury becomes a gas and enters the air. Mercury
the “Fever Thermom-
                                                           that has vaporized in an autoclave may also condense
                                                           along with the steam and enter wastewater. Mer-
                                                           cury thermometers should not be placed in red bags
3.2.2 - Take-home thermometers                             or sharps containers, even in an isolation unit. The
                                                           hospital’ protocol for isolation units should make it
     If some units of the hospital send thermometers       clear that thermometers can be removed from the
home with their patients, hand out mercury-free ther-      unit as long as they are disinfected first. (See Chap-
mometers. The take-home thermometer might be               ter 5, Strong Memorial Hospital case study, for an
digital, chemical strips or a glass thermometer filled                     no
                                                           example of a “ mercury thermometers”label that
with a non-mercury liquid metal alloy. The use of a        can be placed on a red bag container or sharps con-
mercury-free alternative will prevent the release of       tainer.)
mercury into the environment when the family breaks
or otherwise discards the thermometer.
                                                           3.2.4 - Recycling/disposal of mercury-
     If an alternative has not yet been evaluated and      containing thermometers
chosen, and mercury thermometers are to be dis-
tributed in the meantime, educate patients about
                                                                Develop a procedure               for discarding
how to properly handle and dispose of the mercury
                                                           mercury thermom-                    eters. The ther-
after a thermometer has been broken or if one is to
                                                           mometers could                  be placed at a collec-
be discarded. A good resource for information is Health
                                                           tion station               that is convenient for nurs-
Care Without Harm’ Mercury and Your Fmaily bro-
                                                           ing and              environmental services person-
chure. A list of household hazardous waste facilities
                                                           nel and          that is designated specifically for the
would also be helpful. This can be done most easily
                                                           t e m p o - rary storage of hazardous materials.
by handing out written information with the thermom-
                                                           Make a container available at the collection station
eter. This information should also be available at the
                                                           for the thermometers and label it clearly. The con-
hospital’ information desk. Also, if the hospital wants
                                                           tainer could be emptied or picked up on a regular
to encourage mercury recycling, information on spill
                                                           basis or on an as-needed basis, according to the in-
kits and recycling methods should also be provided.
                                                           structions of the hazardous waste management co-
                                                           ordinator. (See Chapter 5, Strong Memorial Hospi-
                                                           tal case study, for an example of a label that can be
                                                           placed on a mercury thermometer collection con-
                                                                Develop a protocol for the cleanup of a broken
                                                           mercury thermometer and for transport of the spilled
                                                           mercury to the designated hazardous waste collec-
                                                           tion point. (See also Chapter 3, Spills, and Appendix

Chapter 3
                                                 Table 2. Alternatives for Mercury-Containing Thermometers

                         M erc u ry
 Ty p e                                         P ric e R a n g e   A c c u rac y            T i m e for R e a d i n g   C o m m e n ts
                         C o n ten t

                                                                                                                         B r e a k a b l e . A v e r a g e l i fe
                                                                    + /- . 2 F ( i n                                     e x p e c t a n c y, i f r e s u s e d ,
 M erc u ry              500 mg                 $.40                98-102 F                 5 - 7 M in u tes            equals 8 0 days in a
                                                                    Range)                                               hospital settin g . D isposal
                                                                                                                         is expensive.

                                                                                                                         A c c u racy is very
                                                $150-$300                                                                tec h n ique sensitive.
                                                plus cost of                                                             Need to train u sers on
 Ty m p a n i c
                                                disposable          + /- . 2 F ( i n 9 8 -                               proper tech n iqu e o f " P u ll
 (D i g i t a l /IR /-   M e r c u r y - free                                                Seconds
                                                covers              1 0 2 F Range)                                       a n d Tu g " m e t h o d .
 a u r a l /ear)
                                                ($ ~ . 0 2                                                               R o u tine calibration is
                                                each )                                                                   recom m ended at least
                                                                                                                         every 6 - 1 2 m onths.

                                                                                                                         C u rly cord between probe
                                                plus cost of
 Therm istor                                                                                                             and sensing unit.
                                                disposable          + /- . 2 F ( i n 9 8 -
 w / dig ital            M e r c u r y - free                                                4 - 1 5 S econds            R o u tine calibration is
                                                covers              1 0 2 F Range)
 readou t                                                                                                                recom m ended at least
                                                ($ ~ . 0 2
                                                                                                                         every 6 - 1 2 m onths.
                                                each )

                                                                                                                         S ingle use. Not intended
 C h emical                                                         + /- . 2 F ( i n
                                                                                                                         to be u sed for recordin g
 strip (dot              M e r c u r y - free   ~ $ .04 each        98-102 F                 1 - 3 M inutes
                                                                                                                         tem peratu res lower th a n
 m atrix)                                                           Range)
                                                                                                                         9 5 F.

                                                                    + /- . 2 F ( i n
 Galliu m /
                         M e r c u r y - free   ~$3                 98-102 F                 3 M inutes                  B reakable.
 In d i u m /Tin

3.2.5 - Are non-mercury thermometers adequate
diagnostic tools?
     There has been some controversy regarding the                                          Forehead thermometers are convenient and
accuracy of non-mercury containing thermometers                                        comfortable to use, but they are not very accurate.
versus mercury-containing thermometers. T he Ameri-                                    They may be handy for quick screenings, but for ex-
can Medical Association reviewed the benefits and                                      act readings use a glass thermometer or a digital
drawbacks of the more readily-available types of fe-                                   one.
ver thermometers and issued the following statement:                                        There may be rare instances when a mercury ther-
     “Both glass mercury thermometers and digital                                      mometer may be preferred for some types of pa-
thermometers will give you an accurate reading.                                        tients. Patients who are concerned about whether
What’ most important is that you choose a ther-                                        non-mercury thermometers are adequate for a par-
mometer that’ easy to use and read.”                                                   ticular circumstance should consult their physicians.
     The newest thermometers available are ear ther-                                        As with all categories, it is very difficult to deter-
mometers that quickly and easily measure tempera-                                      mine the lifetime cost of the different options of ther-
ture inside the ear canal. They are still fairly expen-                                mometers. Chapter 4, on costs and case studies,
sive compared with glass and electronic models, and                                    provides more detail on the associated costs, including
learning how to use them correctly takes some train-                                   disposal.
ing. But they can be quick and relatively comfortable
for children.

                                       MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                                         17
Chapter 3
                                                Table 2. Alternatives for Mercury-Containing Sphygmomanometers

 Ty p e o f S p h y g n o m a n o m e t e r       Content                Cost                                       Comments
                                                 (Ou n c es)

 A n e roid

                                                                                     N e e d s c a l i b r a t i o n a n n u a l l y. A c c u r a c y
                               Portable       M e r c u r y - fr e e   $54-$152      comparable to mercury .
                                                                                     ( S e e f e a s i b i l i t y i n form a t i o n i n C h a p t e r 4 )

                M obile with S tan d          M e r c u r y - fr e e   $225-$242     See above.

                      W all-m ounted          M e r c u r y - fr e e   $130-$146     See above.


                                                                                     Common where long-term continuous
                                              M e r c u r y - fr e e    ~$2000
                                                                                     monitoring is needed, such as intensive care.

 M ercury

                                                                                     R e q u i r e s a n n u a l r e fillin g a n d c a l i b r a t i o n .
                               D esktop             3 - 4              $124-$150     Easily broken . Disposal is expensive. N o t
                                                                                     r e c o m m e n d e d for c a r p e t e d a r e a s .

                M obile with S tan d            3 .3 - 4.4             $225-$282

                      W all-m ounted                3 - 4              $115-$133

3.3 - Sphygmomanometers                                                            It is highly recommended (no matter whether
                                                                                   mercury, aneroid, or electronic BP devices are
3.3.1 - Are mercury-free sphygmomanometers as reliable                             used) that:
and accurate as mercury sphygmomanometers?                                         • Appropriate size, placement, & snugness of
                                                                                   cuff placement is ensured
  In 1995, Louise O’Donnell , a RN and Clinical                                    • Integrity of all system components is
               Nurse Specialist, researched                                        ensured (via routine preventative mainte-
               sphygmomanometers in a literature                                   nance)
               review and concluded the following:                                 • Accurate calibration of the device is
                                                                                   ensured (via routine preventative mainte-
                       • For bedside use, there is no                              nance)
                       obvious accuracy benefit to using                           • Appropriate technique for inflation, deflation,
                       the mercury sphygmomanometer                                and auscultation is ensured
                       routinely.                                                  • The users are aware of, and efforts are
                       • In light of the health risk (and                          made to counteract, common error points
                       associated patient/staff safety as                          prone to cause inaccurate blood pressure
                       well as spill cleanup & waste                               determinations
                       management costs) associated
                       with use of mercury in the clinical                          -- 12/16/95 Louise O’ Donnell RN, MS
                       areas, it appears that it is most                           Neuroscience Clinical Nurse Specialist
                       appropriate to use non-mercury
                       systems on a broad scale.                                Please see Appendix O for the sources used in
                                                                                the literature review.

Chapter 3
                                                              7. Handle over a tray to contain any spills.
3.3.2 - Refilling mercury-containing sphygmomanometers
                                                                 Never handle mercury over a sink or floor
                   In order to ensure optimal perfor-         8. If the sphygmomanometer is an older wall-
              mance, manufacturers of sphygmoma-                 mounted Baum model, make sure that the
              nometers recommend that the mer-                   sphygmomanometer has a safety clip in-
              cury be removed and filtered at regu-              stalled to ensure that the mercury containing
              lar intervals. Once a year is a typical            tube is not accidentally released. Safety clips
              interval, but the mercury should also              for older sphygmomanometer may be ob-
              be removed and filtered any time there             tained for free from W. A. Baum by calling
              is a question about the performance                631-226-3940. Replacement tubes made
              of a sphygmomanometer. If a broken                 of shatter-proof mylar-coated glass can also
              device is to be repaired, it too must              be purchased from the manufacturer.
              have the mercury removed and filtered.          9. Carry the sphygmomanometer back to the
                   If it is not yet feasible for your hos-       patient room as described in steps 1-3 after
              pital to replace all of its mercury sphyg-         refilling.
              momanometers, make sure there is
              a protocol for their handling and refill-          (See the Chapter 3 section on Spills for other
              ing that is consistent with the                precautions.)
              manufacturer’ instructions and Oc-
cupational Safety and Health Administration (OSHA)

The protocol might include the following instructions:

  1. If the sphygmomanometer is mounted on the
     wall, the entire apparatus must be removed
     and taken to a safe workspace to refill. Do
     not attempt to remove the mercury until
     you have removed the sphygmometer from
     the wall and taken it to a safe workspace.
  2. Place the sphygmomanometer to be refilled in
     a clear plastic bag and seal the bag. Do not
     use a red bag or biohazard bag.
  3. Mark the bag: “  CONTAINS MERCURY.”
  4. Place the bag in a plastic basin to contain
     spills while transporting to the area where the
     sphygmomanometer is to be refilled.
  5. Wear appropriate protective clothing and
     work within a hood to provide ventilation.
  6. Make sure the sphygmomanometer is resting
     on its side when you remove the mercury-
     containing tube inside. Pressing the lever on
     older sphygmomanometers will cause the
     glass mercury tube to be released from the
     bottom of the apparatus. The glass tube is

                            MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                   19
Chapter 3
Gastrointestinal Tubes                                          Table 3. Alternatives for Mercury-Containing Gastrointestinal Tubes

        Type of GI Tube                                       Mercury-Free Alternative and Effectiveness
 Bougie tubes (esophageal dilators)          Tungsten. Considered to be as effective as mercury for this use.
 Cantor tubes (used to trace the GI tract)   Tungsten. Can be purchased empty of weighting and hospital adds the
                                             weighting material, either mercury or tungsten. Some feel tungsten weighting is
                                             not as effective as mercury for this use because it is not as heavy.
 Miller Abbott tubes                         Tungsten. Can be purchased empty of weighting and hospital adds the weighting
 (used to clear intestinal obstructions)     material. Tungsten replacement is considered to be as effective as mercury
                                             for this use.
 Feeding tubes                               Tungsten. Considered to be as effective as mercury for this use.

3.3.3 - Recycling/disposal of mercury-containing                         Please note that when sphtgmomonameters
sphygmomanometers                                                    ameters are disposed of, the shgmomanometer
                                                                     maintenance kits (which also contain mercury) should
     Develop a protocol for the preparation of mer-                  also be disposed of.
cury sphygmomanometers for recycling or disposal
that is consistent with U.S. Environmental Protection                3.4 - Gastrointestinal Tubes
Agency, state and local regulations, and other perti-
nent standards. (See Appendix C for a listing of na-
tional regulatory contacts.) Check with the manufac-                 3.4.1 - Recycling/disposal of mercury-containing
turer to see if a buy-back program is available for                  gastrointestinal tubes
older equipment. Contact your hazardous waste man-
agement coordinator for details about packaging, la-                     Gastrointestinal tubes typically have expiration
beling and transporting that are specific to your facil-             dates, after which their use must be discontinued.
ity. A suggested protocol might include the following                Make sure the hospital has a protocol for the han-
instructions:                                                        dling and recycling or disposal of mercury-containing
   1. Place the sphygmomanometer in a clear                          tubes that is consistent with U.S. Environmental Pro-
       plastic bag and seal the bag. Do not use a                    tection Agency, state and local regulations, and other
       red bag or biohazard bag.                                     pertinent standards. (See Appendix C for a listing of
   2. Mark the bag: “   CONTAINS MERCURY.”                           national regulatory contacts.) Contact your hazard-
   3. Place the bag in a plastic basin to contain any                ous waste management coordinator for details about
       spills during transport to the designated                     packaging, labeling and transporting that are specific
       hazardous waste collection point.                             to your facility. Also check with the manufacturer to
                                                                     see ithere is a buy-back program in place for older

                                                                     A suggested protocol for disposal might include the
                                                                     following instructions:

                                                                       1. Place the tube(s) in a clear plastic bag and
                                                                          seal the bag. Do not use red bags or biohaz-
                                                                          ard bags.
                                                                       2. Mark the bag: “  CONTAINS MERCURY.”
                                                                       3. Place the bag in a plastic basin to contain any
                                                                          spills during transport of the tubes to the
                                                                          designated hazardous waste collection point.

Chapter 3
3.5 - Dental Amalgam and Mercury                           3.6.1 - Alternatives for mercury-containing laboratory
                              Many hospitals do not
                                                               The mercury compound in a chemical formula-
                        have dental facilities. How-
                                                           tion may be an active ingredient, a preservative, or a
                        ever, some hospitals do have
                                                           contaminant introduced during the manufacture of
                        a clinic within the hospital or
                                                           one of the ingredients. The alternative depends on
                        as part of another facility with
                                                           the reason that mercury is present. If a mercury com-
                        which they are affiliated, such
                                                           pound is an active ingredient, the replacement may
                        as a nursing home. For the
                                                           be a compound of a less hazardous metal. If a mer-
                        benefit of hospitals that have
                                                           cury compound is a preservative, the formulation can
                        dental clinics, a booklet, “Pre-
                                                           often be replaced by a formulation that uses a non-
vent Mercury Pollution: Use Best Management Prac-
                                                           mercury preservative. If mercury is a contaminant, a
tices for Amalgam Handling and Recycling”can be
                                                           formulation can often be found with ingredients manu-
found in Appendix J. The mercury pollution preven-
                                                           factured by a different method. Examples of alter-
tion best management practices described in the
                                                           natives to mercury-containing chemicals common in
booklet were developed simultaneously with those
                                                           a clinical laboratory are shown in Table 4. In the
described in this manual.
                                                           table, mercury-containing products are indicated by
                                                           the shaded boxes, and they are followed by their mer-
3.6 - Laboratory Chemicals                                 cury-free counterparts in the unshaded boxes.
                                                               Because mercury may be present in very small
                                                           amounts as a preservative or contaminant, it may
     Whenever laboratories use mercury-containing          not be obvious whether or not a chemical reagent or
chemicals, there is the potential for the release of       stain contains mercury. Manufacturers might not list
mercury into wastewater. Once mercury in waste-            the ingredients of a reagent or stain if the formula is
water enters a wastewater treatment plant, most of         proprietary information. Material Safety Data Sheets
it concentrates in the sludge. The sludge may either       might not list mercury in a product if the formula is
be spread on land or incinerated. Either way, the          proprietary information or if the amount is less than
mercury in the sludge will eventually be released into     one percent. However, the contribution of many low-
the environment.                                           concentration sources accounts for a large fraction
     To phase out all nonessential uses of mercury in      of the mercury in the wastewater stream.
laboratories, hospitals may:

  • Eliminate the use of mercury-containing
    compounds in all clinical, research and
    teaching laboratories unless there is no
  • Eliminate all nonessential mercury devices,
    such as thermometers and barometers, and
    replace them with mercury-free devices; and
  • Clear laboratories and storage areas of
    unnecessary mercury compounds.

    See Appendix B for categories of laboratory chemi-
cals that may include mercury.

                        MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                21
Chapter 3
                                     Table 4. Alternatives for Mercury-Containing Laboratory Chemicals

           Compound                    Mercury Content                        Cost                          Com m ents

  Histological fixatives (such as
 B5 and Zenker's Solution) with
                                          3.7-4.5 g/L
 mercury (II) chloride as a tissue

                                                                                                    Other products are available
          Zinc Formalin                   Mercury-free                     ~$.068/oz              that are both mercury-free and

  Hematoxylin with Mercury (II)
                                           ~2.5 g/L
    chloride as an oxidizer

        Gill's hematoxylin                Mercury-free                  $.50 - $1.50/oz

 Hematoxylin with Sodim iodate
                                          Mercury-free                  $.51 - $1.20/oz
        as an oxidizer

                                                                                                    Gas chromatography/mass
 Chemical used for acidic drug
                                                                                                     spectrometry method. A
  analysis of barbituates and
                                                                                                    hospital may need to send
 benzodiazepines by thin layer
                                                                                                   samples to a lab that has the
                                                                                                     equipment and specially
    (such as Toxi-Dip B3)
                                                                                                       trained staff required.

                                                                                                  Preservative in stains and other
     Thimerosal (Trademark
                                                                           $3 - $7/g                 products in the pH neutral

      Methyl paraben, propyl

         Mercurochrome                    24% - 27 %                      $.75-$.90/g

            Neosporin                     Mercury-free

              Mycin                       Mercury-free

    The hospital purchasing agent should contact the                    Wherever possible, change methodologies to pro-
hospital’ suppliers and request that mercury-free                   cesses that do not involve mercury. Watch for new
reagents be supplied. If the usual supplier cannot                  products. Many reagents and stains that once con-
provide mercury-free reagents, it is often possible to              tained mercury have been reformulated so that they
locate one that can. Request that all vendors dis-                  are now mercury-free.
close mercury concentration by requiring them to                        The cost of mercury substitutes can be compa-
supply a Certificate of Analysis. Products with no or               rable and, in some cases, may be less than the cost
low mercury can then be selected for purchase. The                  of mercury-containing chemicals. Some substitutes
Certificate of Analysis should list mercury content in              may also carry some environmental risk, but it will
parts per billion (ppb), not as a percentage. (See a                probably be less than the risk associated with
sample letter requesting a Certificate of Analysis and              mercury.
a sample Certificate of Analysis in Appendix G.)

3.6.2 - Recycling/disposal of mercury-containing
laboratory chemicals

      Train laboratory staff on the proper use, handling
and disposal of hazardous materials, and the impor-
tance of keeping mercury out of wastewater. Make
the staff aware of laboratory products that are known
to contain mercury. To minimize the amount of haz-
ardous waste generated, keep laboratory chemicals
ready for recycling or disposal separate from each
other. Do not mix them!
      Mercury-contaminated waste should be collected
and disposed as hazardous waste. Check with your
local sewer district for information about the proper
disposal of mercury-contaminated rinse water.
      For plumbing in lab areas and dentist offices, there
filtration divices available that can be attached to the
plumbing. These devices separate and collect in-so-
lution mercury from wastewater and can save time
and money. Check the list of Mercury Recyclers in
Appendix C for contact information.
      Check for unused, nonessential mercury-contain-
ing chemicals in storage areas and dispose of them
as hazardous waste. Contact the hospital’ hazard-
ous waste management coordinator about transport-
ing the chemicals to the designated hazardous waste
collection point. Protective clothing, carpeting or de-
bris that is contaminated with a mercury compound
should be managed in accordance with U.S. Environ-
mental Protection Agency and state regulations.
        (See Appendix C for a national listing of regula-
tory contacts.)

Chapter 3
3.7 - Pharmaceutical Products                                  3.7.1 - Alternatives for mercury-containing pharmaceutical
    Mercury may be present in pharmaceutical prod-
                                                                    Be aware of changes in the pharmaceutical in-
ucts even when it is not listed on the label or on the
                                                               dustry. In many cases, products with mercury-free
product information sheet. As can be seen in the
                                                               preservatives are available, and additional alterna-
table below, the mercury is usually introduced as a
                                                               tives are likely to be available in the near future. In
                                                               the meantime, request mercury-free pharmaceuti-
                                                               cal supplies whenever possible. Ask your vendor to
                                                               assist the hospital in selecting mercury-free products
                                                               for the pharmacy. (See sample vendor product mer-
                                                               cury-content disclosure in Appendix H.)

                                           Table 5. Pharmaceutical Uses of Mercury

                            Product                                                    Notes
 Merbromin/water solution                                    Used in plastic/reconstructive surgery as a disinfectant
                                                             and marker
 Ophthalmic and contact lens products                        May contain mercury preservatives: thimerosal,
                                                             phenylmercuric acetate, phenylmercuric nitrate
 Nasal Sprays                                                May contain mercury preservatives: thimerosal,
                                                             phenylmercuric acetate, phenylmercuric nitrate
 Vaccines                                                    May contain thimerosal (primarily in hemophilus, hepatitis,
                                                             rabies, tetanus, influenza, diphtheria and pertussis

Chapter 3
3.8 - Cleaners and Degreasers                                    3.8.2 - Alternatives for mercury-containing cleaners and
3.8.1 - Mercury as a contaminant
                                                                      To learn the mercury content of the cleaners and
                                                                 degreasers used by the hospital, request Certificates
    The mercury-cell process is one of the processes             of Analysis from all suppliers when purchasing mate-
that may be used to manufacture common ingredi-                  rials. Choose mercury-free products, if possible. If
ents of cleaners and degreasers: sodium hydroxide                there are no mercury-free products that meet the
(caustic soda), potassium hydroxide, chlorine and hy-            needs of the hospital, choose those that are the low-
drochloric acid (muriatic acid). When these chemi-               est in mercury concentration.
cals are used to make other products, such as bleach
or soaps, mercury contamination can be introduced
into the final product.

                                                                        Table 6. Mercury Content of Selected Cleaning Products*

   Information from MWRA/MASCO Mercury Work Group
                              Product                                             Mercury Content (ppb)
                                 Ajax Powder                     0.17
                                 Comet Cleaner                   0.15
                                 Lysol Direct                    <0.011
                                 Soft Scrub                      <0.013
                                 Alconox Soap                    0.004 mg/kg, 0.005 mg/kg, <0.0025 mg/kg
                                                                 (3 tests)
                                 Derma Scrub                     <5.0, <2.5 (2 tests)
                                 Dove Soap                       0.0027
   Ivory Dishwashing Liquid                                      0.061
   Joy Dishwashing Liquid                                        <0.01
   Murphy’ Oil Soap                                              <0.012
   Soft Cide Soap (Baxter)                                       8.1
   Sparkleen Detergent                                           0.0086
   Sunlight Dishwashing Detergent                                <0.011
   *Testing on cleaning products has been limited and many common cleaning products have not been tested.
   The data should not be used as a substitute for testing specific products/chemicals.

      The Massachusetts Water Resources Authority
(MWRA) and Medical, Academic and Scientific Com-                       The Certificate of Analysis should list mercury con-
munity Organization, Inc. (MASCO), through a public-              tent in parts per billion (ppb), not as a percentage. A
private partnership called the MWRA/MASCO Mercury                 Material Safety Data Sheet is not equivalent to a Cer-
Work Group, performed laboratory analyses on some                 tificate of Analysis. (See Appendix G for a sample
of these products. (See Appendix I, Educational Re-               letter requesting a Certificate of Analysis and a sample
sources for a Mercury Pollution Prevention Program                Certificate of Analysis.)
and the MWRA/MASCO case study in Chapter 5.)
This information is provided to illustrate the widespread
presence of mercury.

                             MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                               25
Chapter 3
3.9 - Batteries                                                     3.9.2 - Alternatives to mercury-containing batteries

                                                                         The alternative to mercuric oxide batteries is zinc
3.9.1 - Mercury-containing batteries                                air batteries. However, the alternative may not be
                                                                    mercury-free. A zinc air button battery may contain
     Mercuric oxide (mercury zinc) batteries and but-               up to 25 mg of mercury. Larger zinc air batteries are
ton batteries are the only batteries made in the United             made up of stacked button batteries, each of which
States that may contain added mercury if newly pur-                 may contain up to 25 mg of mercury. It is not yet
chased (see table). Mercuric oxide batteries offer a                possible to eliminate mercury from these batteries.
reliable and constant rate of discharge and can be                  In the absence of mercury, the zinc electrode cor-
made in a wide variety of sizes intended for use in                 rodes and creates hydrogen gas. Because the bat-
medical devices.                                                    teries are tightly sealed, they can bulge when the gas
                                                                    is created and may even explode. Note that zinc air
                                                                    batteries include a tab that prevents exposure of the
                                                                    internal part of the battery to air (air serves as one of
             Table 7. Batteries (Newly Purchased) That May Contain Added Mercury and Replacement Alternatives(1998)

     Battery                 Quantity of Mercury              Use              Voltage             Available Alternatives
  Mercuric oxide           33-50% by weight                 Medical        Multiples of 1.4 v    Zinc-air (may contain up to
  (mercury zinc)                                                                                 25 mg mercury, 0.4-1.0%
                                                                                                 by weight)
  Button batteries:        No federal law, but addition     Medical        Multiples of 1.4 v    None
  Zinc air                 of mercury over 25 mg
                           prohibited by some states.
                           Manufacturers use this
                           standard for all button
  Button batteries:        Federal law allows up to         Consumer       Multiples of 1.5 v    Silver oxide (lasts longer,
  Alkaline-manganese       25 mg mercury                                                         costs more, does not come
                                                                                                 in a full range of sizes)
  Button batteries:        Contains some mercury            Consumer       Multiples of 1.5 v    None
  Silver oxide             but less than alkaline-
                           manganese button batteries

     In the 1990s, manufacturers stopped designing                  the electrodes). Once the tab on a zinc air battery is
equipment requiring mercuric oxide batteries. New                   pulled off, the internal part of the battery is exposed
models generally require zinc air batteries. However,               to air and it begins to discharge.
mercuric oxide batteries may remain in hospital stock                    For medical devices, there are Food and Drug
for many years for use in older equipment. The shelf                Administration and Underwriters Laboratory certifi-
life of mercuric oxide batteries is up to ten years.                cation concerns with replacing a battery. It is impor-
     Some of the medical devices that may still re-                 tant to contact the equipment manufacturer before
quire mercuric oxide batteries include cardiac moni-                replacing a mercuric oxide battery with a substitute
tors, pH meters, oxygen analyzers and monitors, and                 to ensure that the device has been approved for use
telemetry instruments. See Appendix A to see the                    with the alternative battery.
variety of devices in which mercury-containing bat-                      Rechargeable (nickel-cadmium) batteries cannot
teries have been used.                                              be used as an alternative to mercuric oxide batter-

Chapter 3
3.9.3 - Recycling/disposal of batteries                     3.10 - Lamps
      Provide many convenient collection
                                                                     3.10.1 - Energy efficiency of mercury-containing
points for batteries throughout the hospi-
tal, including areas where replacement bat-                          lamps
teries are obtained. There are two options
                                                                           Fluorescent lamps, high-intensity dis-
for collection:
                                                                      charge (HID) lamps and ultraviolet lamps
      1. Collect only mercury-containing bat-                         (used in biosafety cabinets) are among the
teries. This would put the responsibility for                         few mercury-containing products within hos-
knowing mercury content on the person                                 pitals for which adequate non-mercury sub-
who is discarding the battery. The hazard-                            stitutes do not exist.
ous waste management coordinator could
                                                                           Fluorescent and HID lamps are efficient
post written guidance at the collection lo-
                                                                      sources of white light, typically 3-4 times
cation. However, this option could be con-
fusing for the user.                                                  more energy-efficient than incandescent
                                                                      lamps. Since fossil fuels contain mercury,
      2. Collect all batteries. The hazard-                           power generation releases mercury and
ous waste management coordinator or re-                               other pollutants to the environment, and
cycler would take responsibility for sorting the batter-    these releases are greater when less efficient lamps
ies. The coordinator should determine which types           are used. Considering both mercury emissions from
of used batteries are hazardous waste, which types          power generation and mercury contained in the lamps
can be recycled and which types can be thrown away          themselves, incandescent lamps put more mercury
as trash. Spent mercury-containing batteries should         into the environment than do fluorescent lamps.
be recycled.
                                                                Investigate the mercury content of fluorescent and
     Some battery manufacturers offer recycling pro-        HID lamps and purchase those with a relatively low
grams for mercuric oxide batteries. Check with the          mercury content. In recent years, lamp manufactur-
hospital’ battery suppliers to learn if they have col-      ers have been reducing the amount of mercury in fluo-
lection plans and if they will coordinate packaging and     rescent lamps. Some lamps are low enough in mer-
transportation to their facilities. Check with your state   cury content to be considered nonhazardous for waste
regulatory contacts (listed in Appendix C) to                                             recycling and disposal
ensure that the specific program is legal.                                                purposes. Check verifi-
                                                                                          able product information
                                                                                          on Toxicity Characteristic
                                                                                          Leaching Procedure
                                                                                          (TCLP) testing to learn if
                                                                                          this is the case. (See
                                                                                          Section 3.10.2 for more
                                                                                          information on TCLP).

                           MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                         27
Chapter 3
3.10.2 - Recycling/disposal of mercury-containing lamps         Since fluorescent and HID lamps fail TCLP testing
                                                            for mercury a high percentage of the time, it is sug-
     There should be several convenient collection          gested that expensive TCLP testing be minimized and
points for spent lamps within the hospital. Lamps           that those disposing of these lamps assume them to
from the collection points should be taken by the haz-      be hazardous unless verifiable product information
ardous waste management coordinator to the                  states that the lamps are nonhazardous. Also, ask
hospital’ designated hazardous waste collection
           s                                                your state regulatory agency about the Universal Waste
point. The lamps can be sorted for recycling or dis-        Rule and if it applies to your state. (See Appendix C.
posal at the collection point. Do not break or crush        Also see Appendix K for a partial list of fluorescent
lamps, unless using a commercial lamp crusher that          lamp recyclers.)
captures mercury vapor. If a hospital chooses to crush
lamps on the premises, that hospital becomes liable         3.10.3 - U.S. Environmental Protection Agency (EPA) Green
to meet the requirements for RCRA Land Disposal             Lights Program
Restrictions (40 CFR 268). Because crushing lamps
may be considered to be “      treatment,”consult with                   s
                                                                The EPA’ Green Lights/Energy Star Program can
your state regulatory or regional EPA office before pur-    help the hospital save money on lighting costs and, at
chasing a lamp crusher. (See Appendix C for a na-           the same time, reduce the amount of mercury that is
tional listing of regulatory contacts.)                     emitted to the air when fossil fuels are burned at the
     If a lamp is accidentally broken in the hospital,      local power plant that supplies electricity.
store all of the debris in a sealed plastic container.          Organizations, such as hospitals, that join Energy
Request pickup by the hazardous waste management            Star sign a Memorandum of Understanding with EPA
coordinator.                                                to become a “   Partner.” Partners agree to consider
     The exact procedures for sorting, storage, pack-       available technologies and install the mix of lighting
ing, and recycling or disposal will partly depend on your   products and controls that maximize energy savings
state and local requirements. It is important to know       and maintain or improve lighting quality.
your generator status before asking questions. Some             EPA offers information, analysis, and planning and
of the questions to ask the state regulatory agency or      communications services to the Partner. For further
regional EPA office are:                                    information, contact the Energy Star Program by
   1. Which lamps can and cannot be recycled?               phone at 202-775-6650 or by fax at 202-775-6680.
   2. Which lamps must be considered as hazard-
        ous waste?
   3. How should lamps for recycling be packed for          3.11 - Electrical Equipment
        transporting? Should they be whole or
        crushed in a bulb crusher? What is the cost         3.11.1 - Alternatives for mercury-containing electrical
        of a bulb crusher?
   4. How should broken lamps be packaged?
                                                                 Mercury can be found in many types of electrical
                                                            equipment (see Table 5 on the next page) and the
                                                            equipment can have a lifetime measured in decades.
                                                            Renovation is usually the reason that the equipment
                                                            is replaced. Even if mercury use in newly manufac-
                                                            tured equipment is discontinued, the recycling or dis-
                                                            posal of used equipment will require an awareness
                                                            of the mercury content for a long time to come.

Chapter 3
    Manufacturers have not eliminated mercury in all          3.11.2 - Recycling/disposal of mercury-containing electrical
electrical equipment due to cost considerations. How-         equipment
ever, because of an awareness of mercury problems,
manufacturers are increasingly making alternatives                If the hospital is preparing used electrical equip-
available. Ask your vendor to assist the hospital in          ment for recycling or disposal and there is a question
selecting mercury-free products. (See sample ven-             about the mercury content, obtain this information from
dor product mercury-content disclosure                        the manufacturers. Remove any mercury-containing
in Appendix H.)                                               parts from the equipment. Store the parts in a tightly
                                                              covered, labeled container. Parts from switches, ther-
                                                              mostats, relays and thermostat probes (including the
                                                              thermostat probes described in the section on Ther-
                                                              mostat Probes in Gas Appliances) can be stored in the
                                                              same container. The closed, labeled container could
                                                              be located in the supply area of the hospital where
                                                              replacement parts are stored until it is full and ready
                                                              for transport to the hospital’ designated hazardous
                                                              waste storage area. Recyclers are available that ac-
                                                              cept these equipment components. (See Appendix K.)

                                                                             Table 8. Mercury-Containing Electrical Equipment

        Type of Switch                       Where Equipment is Used                           Possible Alternative
    Tilt switch               Airflow/fan limit control                                 Mechanical switch
                              Building security systems
                              Clothes iron
                              Fire alarm box
                              Fluid level, pressure or temperature control devices
                              Laptop computer screen shutoff
                              Lids of clothes washers and chest freezers
                              Silent light switch
                              Space heater
    Float switch              Bilge pumps                                               Magnetic dry reed switch
                              Septic tank                                               Optic sensor
                              Sump pump                                                 Mechanical switch
    Thermostat                Temperature control device may have a                     Electronic thermostat
                              mercury tilt switch.
    Reed relay                Low voltage, high precision analytical                    Solid state relay
                              equipment such as electron microscope                     Electro-optical relay
                                                                                        Dry reed relay
    Plunger or                High current, high voltage applications such              Mechanical switch
    displacement              as lighting, resistance heating, power
    relay                     supply switching
    Thermostat probe          Electric stoves                                           Non-mercury probe
                              Hot water heaters

                         MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                 29
Chapter 3
3.12 - Take-back Programs for Thermostats                     3.13.1 - Alternatives for mercury-containing thermostat
                                                              probes in gas appliances
     Honeywell Corporation has a free take-back pro-
gram to collect any brand of used mercury-contain-                 Non-mercury thermostat probes are also used
ing thermostats. To use the system, contact a heat-           in the appliances listed above. They are:
ing, ventilating and air-conditioning wholesaler to learn
if the wholesaler is participating in the program.
Honeywell provides a special container for thermo-
stats to each participating wholesaler. Do not re-
move the switches from your thermostats before taking
them to the wholesaler. (Call 800-345-6770 for fur-
ther information.)
     Honeywell is one example of a take-back program.
Other companies may have such programs. Contact
your supplier to learn if this option is available. Take-
back programs may be subject to Universal Waste
Rules in your state. Check with your state regulatory
contacts to ensure that the specific take-back pro-
gram is legal. (See Appendix C for waste regulation

                                                                • Sodium/potassium thermostat probes
3.13 - Thermostat Probes in Gas Appliances                      • “Dissimilar metals”thermostat probes

       Mercury-containing thermostat probes may be            3.13.2 - Recycling/disposal of mercury-containing
found in several types of gas-fired appliances that           thermostat probes in gas appliances
                                    have pilot lights, such
                                    as ranges, ovens,              Remove thermostat probes from the appliances
                                    clothes dryers, water     to be discarded and store them along with the mer-
                                    heaters, furnaces or      cury-containing electrical equipment described in the
                                    space heaters. They       section on Electrical Equipment. Place them in a cov-
                                    are usually present as    ered container that is labeled as to the type of equip-
part of the safety valve that prevents gas flow if the        ment being stored. The container could be located
pilot light is not lit. The metal probe consists of a metal   in the supply room of the hospital where the replace-
bulb and thin tube attached to a gas-control valve.           ments are stored until it is full and ready for trans-
The bulb of the probe projects into or near the pilot                                s
                                                              port to the hospital’ designated hazardous waste
light. The mercury is inside the tube and expands or          collection point.
contracts to open and shut the valve.
     A mercury thermostat probe may also be part of
the main temperature-controlling gas valve. In this
application, the probe is in the air or water that is
being heated and is not directly in contact with any
flame. These are typically found in older ovens, clothes
dryers, water heaters and space heaters.
     If there is a question about the mercury content
of a thermostat probe, obtain this information from
the manufacturer.

Chapter 3
3.14 - Industrial Thermometers

    Air and water heating and cooling systems employ thermometers to allow monitoring of the
systems’  performance. Many of these thermometers are mercury in glass.

3.14.1 - Recycling/disposal of mercury-containing industrial thermometers

    It will be necessary to properly recycle or dispose of mercury industrial thermometers if the
hospital is retrofitting with mercury-free thermometers or if it is replacing an entire heating or cool-
ing system that employed mercury thermometers. The thermometers should be packed for delivery
to the designated hazardous waste collection point in a tightly closed container and in a manner
that will prevent breakage of the thermometers. Contact the hazardous waste management coor-
dinator for detailed instructions.

                                                               Table 9. Alternatives for Mercury-Containing Industrial Thermometers

Type of Thermometer Approximate Cost                       Accuracy                                 Comments
     Digital                   $39                   Within 1% of scale range        Light-powered, no battery required;
                                                                                     interchangeable with mercury
                                                                                     thermometer as to threading and well
     Bimetal                   $45-47                Within 1% of scale range        Contains a glass “         but
                                                                                                       window” glass
                                                                                     does not contain a liquid;
                                                                                     not interchangeable with mercury
                                                                                     thermometer as to threading and well
     Alcohol-filled            $40                   Within 1% of scale range        Red-colored alcohol in glass tube;
                                                                                     interchangeable with mercury
                                                                                     thermometer as to threading and well
     Mercury                   $32                   Within 1% of scale range        Mercury in glass tube

                          MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                      31
Chapter 3
3.15 - Pressure Gauges
    Devices that measure pressure may contain mer-
cury. These include:
  • Laboratory manometers used by biomedical
      engineers to calibrate other instruments in
      the hospital
  • Barometers
  • Sphygmomanometers (see the section on
    The most common alternative to mercury-con-
taining devices that measure pressure are aneroid

                                                            Table 10. Alternatives for Mercury-Containing Laboratory Manometers

   Type of Manometer                   Cost                                           Comments
 Electronic (digital)        Several hundred dollars        An order of magnitude more accurate than sphygmomanometers.
                                                            Used in biomedical laboratory to calibrate other devices.
                                                            A traceable calibration must be performed with a mercury
                                                            manometer, onsite or offsite, on a regular schedule. The
                                                            time interval depends on the manufacturer’ recommendation.
 Aneroid (Bourdon,           Price varies widely            Manufacturers recommend calibration at least annually.
 diaphragm, piston or        depending on accuracy &        Schedule can be based on experience, with annual inspections
 capsule types)              traceability required          as a minimum.
 Liquid filled               Price varies widely            Inadvisable to move them from place to place.
                             depending on accuracy &        Manufacturers recommend calibration at least annually.
                             traceability required          Schedule can be based on experience, with annual inspections
                                                            as a minimum.
 Mercury                     $100-$150 range                One meter tall. An order of magnitude more accurate than
                                                            sphygmomanometers. Used in biomedical laboratory to
                                                            calibrate other devices. Annual calibration recommended
                                                            to ensure good performance.

3.15.1 - Recycling/disposal of mercury from mercury-
containing gauges

     Store mercury waste from servicing manometers
and other mercury-containing gauges in a covered,
airtight plastic container. The container must be clearly
labeled: CONTAINS MERCURY. Small amounts can
be stored in vials placed in a larger covered airtight
container, such as a five-gallon plastic pail. Recycle
the mercury. (See Appendix K for a list of recyclers.)

Chapter 3

                       3.16 - Plumbing                   3.17 - Spills

                            Mercury may be present in        Accidental spills of liquid mercury can increase the
                        a hospital’ sewer pipes,
                                     s                   levels of mercury in the air or wastewater of a health
                        sumps and sink traps from the    care facility. Small droplets of spilled mercury may
                        past use of mercury. The mer-    lodge in cracks,
                        cury may have entered the        mix with dust
                        pipes when items were bro-       and go down
ken, discarded or spilled in sinks. Mercury in plumb-    drains. Mercury
ing can settle at a low point such as a sump or sink     may adhere to
trap and remain in the plumbing of a hospital for many   fabrics, shoe
years. Often the slow release of the mercury accu-       soles, watches
mulation in a pipe, sump or sink trap is enough to       and jewelry on
cause violations of wastewater discharge standards       which it can be
even after best management practices for mercury         transported to other locations. A small spill of mer-
have been introduced in the hospital.                    cury in a carpeted patient room can become a major
     Whenever sewer pipes, sumps or sink traps are       cleanup challenge.
to be moved or cleaned, the plumber must be warned
about the potential of finding mercury in the sludge.    3.17.1 - Mercury spill prevention
The sludge must be handled and disposed as haz-
ardous waste unless it is demonstrated, through the          Follow proper procedures when cleaning or refill-
Toxicity Characteristic Leaching Procedure (TCLP) or     ing instruments that contain mercury:
verifiable user knowledge, that it is not hazardous.
Procedures for cleaning traps and pipes that were
                                                           • Work under a well-ventilated hood to ensure
developed by the Massachusetts Water Resources
                                                             minimal exposure to mercury vapors.
Authority/Medical, Academic and Scientific Commu-
                                                           • Clean or refill instruments over a tray to
nity Organization Mercury Work Group can be found
                                                             contain any spills. Never handle mercury over
in Appendix L.
                                                             a sink. Reserve the room for mercury use
     Hospitals have reported success in lowering their       only. Restrict traffic in the area.
wastewater levels after cleaning out their plumbing.       • Clean and calibrate all mercury-containing
After conducting such a cleaning program, a hospital         equipment according to the manufacturer’   s
should follow the recommendations in this chapter in         recommended handling procedures and the
order to avoid reintroducing mercury into the plumb-         procedures recommended by your hospital’     s
ing system.                                                  safety officer.
                                                           • Train all workers who use mercury devices
                                                             about the properties and hazards of mercury,
                                                             safe handling procedures, and specific poli-
                                                             cies related to mercury recycling and disposal.

                                                             Minimizing the impact of a spill is part of spill pre-
                                                         vention. It is preferable to use mercury devices in
                                                         rooms that do not have carpeting or other floor cov-
                                                         erings which are not smooth and easily cleaned.
                                                         Mercury devices should not be used in units which
                                                         use beds that have high structures or projections off
                                                         the beds that can smash wall-mounted sphygmoma-
                                                         nometers, or in areas where patients cannot be

                       MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                         33
3.17.2 - Sample Mercury Spill Response Plan

    Healthcare Without Harm, a non-profit environmental organization, has developed the following guidance
for dealing with mercury spills. You may wish to incorporate these suggestions into your mercury spill re-
sponse training and planning.

     1. Immediately after a spill, keep all people and pets away from the spill area. To minimize
     the amount of mercury in the air, turn off any heaters and turn up any air conditioners. This will slow the
     mercury from vaporizing. Ventilate the area by opening windows. If possible, keep the windows open for
     at least two days to allow any residual mercury to leave the building.
     2. Never use a regular vacuum cleaner to clean up mercury. The mercury will contaminate the
     entire vacuum and the heat from the vacuum will accelerate the mercury to evaporate into the air, and
     the vacuum will also blow mercury-tainted air through the room. The only type of vacuum appropriate
     for cleaning up mercury spills is a specialized mercury vacuum with an activated carbon filter to absorb
     and contain the mercury vapors. Ask your State contact for more information if you want to purchase
     one of these vacuums. Also, never use a broom to clean up mercury. It will only block the mercury up
     into smaller beads and will contaminate the broom.
     3. Assemble the necessary supplies before attempting a clenaup. These include gloves, an
     eyedropper, and two stiff pieces of paper or cardboard, two plastic bags (size depends on the size of the
     spill), a large tray or box, two labels (to put on the plastic bags), a marker or pen, duct tape or packing
     tape, a flashlight, and a wide-mouthed container with a lid. Remember that any tools used for cleanup
     should be considered contaminated and should be disposed of with the mercury.
     4. Do not touch the mercury. Remove all jewlery and watches from your hands, as mercury will
     bond with the metal. Put on gloves (preferably rubber gloves or a non-porous equivalent) to minimize
     the contact with mercury. Use the flashlight to locate all of the mercury. Mercury is a reflective element
     and the mercury beads can easily be located with a bright light.
     5. Clean up the spill with procedures appropriate to the type of surface in the spill area
     • On a hard surface or tightly woven fabric, use stiff-backed paper to push the beads of mercury
     together. If you do not have a tray or box nearby to catch any additional spills, use the eyedropper to
     suction the beads of mercury. If you are working over a tray (to catch spills), lift the beads with the
     beads of mercury with the stiff paper. Carefully place the mercury into a wide-mouthed container. Pick
     up any remaining beads of mercury with sticky tape and place the contaminated tape in a plastic bag
     along with the eye-dropper, stiff paper, and gloves. Label the plastic bag as “                     .
                                                                                      MERCURY WASTE” Place
     this bag and sealed container in the second plastic bag and also label this bag “  MERCURY WASTE” Call.
     your State agency to determine appropriate disposal regulations and locations.
     • On a carpet or rug, the mercury-contaminated section should be cut out with the scissors. The cut
      section, along with all of the cleanup items (scissors included), should be placed in a plastic bag. Label
     the bag as “   MERCURY WASTE”and call your State agency for appropriate disposal regulations and
     • In a sink of water, mercury will sink to the bottom. Remove as much water as possible without
     disturbing the mercury. Use the eyedropper to recover the mercury. Place the mercury into a wide-
     mouthed container, close the lid and seal it with tape. Label the bag as “      MERCURY WASTE”and call
     your State agency for appropriate disposal regulations and locations.
     • In a drain, mercury will settle to the bottom and get caught in the sink trap. Place a box or tray
     under the pipes to prevent any further spills. Remove the trap and pour the contents into a large-
     mouthed container. Close the container lid and seal with tape. Label the bag as “       MERCURY WASTE”
     and call your State Agency for appropriate disposal regulations and locations.

Chapter 3
3.17..3 - Mercury spill response preperation

      Mercury spills are very disruptive. A large spill will
require removing the patient from the room during
cleanup. The room would have to remain vacant un-
til it is ensured that there is no longer mercury vapor
in the air.
      Be prepared for a spill in any area of the hospital
where mercury-containing devices are used. Have a
mercury vacuum cleaner or mercury spill kit readily
available to consolidate spilled mercury and limit the
amount of mercury released into the air.
      The cleanup of mercury spills must be performed
by specially trained staff members. Carry out simu-
lated spills and cleanup as part of training.
      Create a formal mercury spill policy for the hospi-
tal. Consider the following factors when developing
the policy:
   • Round-the-clock availability of a competent
         staff person, trained for mercury spill cleanup
   • Protective equipment and clothing for cleanup
   • OSHA requirements
   • The circumstances when the patient(s),
         visitors and staff should be evacuated from
         the area before cleanup
   • How to determine when a room is “         clean
         enough”to reoccupy
   • Type of flooring (linoleum, carpet, etc.)
   • Determination of the type of equipment to be
         used for the size and type of spill
   • Manufacturer’ instructions for the equip-
         ment to be used
   • Ultimate waste disposal, which may depend
         on the cleanup method
   • Preparation of an incident report that de-
         scribes the spill, the cleanup method used,
         unusual circumstances, and follow up
   • Mercury spills during a medical procedure
   • Posting of “     Who to Call”signs in case of a
         spill in areas where mercury is used and near
         mercury recycling receptacles.

 Chapter 3
                          3.17.4 - Storage Areas
                               Mercury-containing prod-
                          ucts not in use must be
                          stored in nonbreakable con-
                          tainers with tight-fitting lids.
                          The containers must be
                          clearly labeled as to their con-
                          tents. Rooms where mercury-
                          containing items are stored
should be tested periodically using a mercury vapor
     Even after most uses of mercury have been dis-
continued in the hospital, mercury-containing prod-
ucts may still be in storage from past uses. All hospi-
tal units should check storage areas for old, dam-
aged or outdated equipment. (See Appendix A and
Appendix B for lists of possible mercury-containing
products in the hospital.) If mercury-containing prod-
ucts are found, contact the hazardous waste man-
agement coordinator. After the removal of the mer-
cury-containing products, the areas should be checked
with the mercury vapor sniffer.                              3.17.5 - Hospital Employee Health and Safety
                                                                 A major concern with the use of mercury-con-
                                                             taining products is the possible exposure of hospital
                                                             employees to mercury vapor during a maintenance
                                                             procedure, such as servicing mercury-containing
                                                             equipment. Understand the properties and hazards
                                                             of mercury. Check with your health and safety officer
                                                             prior to doing such work to ensure that you are fol-
                                                             lowing correct procedures for:
                                                               • Ventilation
                                                               • Protective clothing and equipment
                                                               • Work habits, such as smoking, eating or
                                                                    drinking in the area and wearing jewelry
                                                                    (mercury readily combines with gold)
                                                               • Handling and recycling or disposal of mercury
                                                               • Follow-up monitoring
                                                                 Conduct periodic training for all employees who
                                                             may come into contact with mercury-containing prod-
                                                             ucts. Include new and temporary employees, em-
                                                             ployees at offsite locations, and contractors.
                                                                 (See also the section on Spills.)

Chapter 4
Costs of Alternatives
                                                             The literature on this subject shows that hospi-
4.1 Introduction                                        tals will likely save money by phasing-out the use of
                                                        mercury-containing products and related mercury
                                                        handling and disposal requirements. This chapter
    As part of the effort to provide information on     discusses both the internal and societal costs asso-
the virtual elimination of mercury, the American Hos-   ciated with mercury-containing products. Internal
pital Association (AHA), the US Environmental Pro-      costs include purchase price; money and staff time
tection Agency (USEPA) and the hospitals involved in    spent on hazardous waste training, mercury spill
the H2E project recognized the need to develop rela-    clean-up, and waste storage and disposal; potential
tive cost information on mercury free products to       costs of non-compliance with environmental laws
assist facilities with the decision of reducing and     (e.g., fines, staff time and expenses for sampling and
eliminating mercury use.                                cleaning traps and drains, damages to hospital’ im-s
                                                        age); and potential health risks to staff, patients, and
                                                        visitors. Societal costs include damage to the envi-
                                                        ronmental and public health.

                                                            In terms of initial purchase price, mercury-con-
                                                        taining and mercury-free diagnostic equipment were
                                                        found to be competitive in some cases, while in other
                                                        cases the mercury-free equipment was more expen-
                                                        sive. However, when a more complete range of
                                                        costs are considered, the mercury free equipment
                                                        was found to be more cost effective and the pre-
                                                        ferred option in the long term.

                                                             Because of the specific patient care needs, hos-
                                                        pitals must consider factors other than purchase
                                                        price and other costs in their decisions. In fact, cost
                                                        is often applied secondarily, after a specific product
                                                        is identified. Some of these factors are: safety (pa-
                                                        tient & staff), ease of use, efficacy, warranty, time
    The goals of this effort were:                      savings, and preferences of medical staff, and cost.
                                                        This chapter is not meant to indicate that costs
    1. To gather specific information on the costs of
                                                        should be paramount in purchasing decisions. How-
mercury-containing products and their mercury -
                                                        ever, nearly all of the diagnostic products and the
free alternatives, and then to compare the two
                                                        majority of chemicals have a mercury-free alterna-
groups (presented in chapter 3).
                                                        tive that has been used successfully. So this chapter
    2. To provide information on often hidden or un-    was put together with the realization that cost can
accounted for costs (internal and societal) associ-     be a significant factor in choosing between products.
ated with the use of mercury containing equipment
and products in health care facilities.
    3. To provide hospitals with tools that enable a
better understanding of the relative costs associ-
ated with the use of mercury containing equipment
and products.

                        MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                      37
Chapter 4

     Prices for many mercury-containing lab and phar-             The missions of hospitals are moving toward
maceutical chemicals are not included inthis manual.          broader definitions of disease prevention, patient
However, often there is a mercury alternative that            health care and community well-being. The use of
can be substituted and the price could be more or             mercury in hospitals and the resulting emissions to
less dependent on the hospital’ contract with its             air and discharges to water contribute to environ-
supplier (Pollution Probe 1996). The case studies             mental and health problems for people and wildlife.
section contains several examples of hospitals that           Hospitals recognize this inconsistency and as com-
have faced these situations and have found mer-               munity health care leaders play an important role in
cury free alternatives. These case studies also con-          achieving the goal of mercury elimination and reduc-
tain contact information for readers who need fur-            tion.
ther assistance in finding alternatives. The most ef-
fective way to replace mercury-containing pharma-
ceuticals and lab chemicals is is to replace them over
time by adopting a mercury free purchasing policy.
This type of policy directs suppliers and vendors that
all such products should be mercury-free chemicals
whenever possible, and to alert you when new mer-
cury-free substitutes become available.

     Identifying the total cost of a product to a facility
or to the hospital can be a very effective way to iden-
tify opportunities for cost-effective toxic reduction.
Mercury thermometers are an excellent example.
The purchase cost of a mercury thermometer is very
low. However, the safest disposal for elemental mer-
cury is triple distillation recycling, which is very expen-
sive and requires that thermometers be collected,
transported, and delivered intact to a hazardous              4.2 Limitations
materials recycling facility for processing. It requires
the tracking of paperwork and other regulatory re-
quirements on an ongoing basis. This can triple the               A major limitation faced in this type of analysis is
total cost: from the point of sale to ultimate disposal.      the variability of costs between hospitals and be-
                                                              tween suppliers. Prices of goods purchased and
                                                              costs of disposal vary according to purchasing power
     There are many reasons why hospitals are re-             and waste quantities generated. Costs stated in this
ducing and eliminating mercury-containing products            report are generally quotes on a single item from one
from their facilities. These include: reducing the risk       or two suppliers and therefore do not represent av-
of accidental spills or discharges; not wanting to con-       erage prices from all suppliers nor prices for bulk pur-
tribute to environmental degradation; obtaining sav-          chases. Price and cost information obtained by indi-
ings through waste reduction; demonstrating leader-           vidual hospitals will undoubtedly vary. The tables in
ship in the community; complying with requirements            Chapter 3 are meant to illustrate purchase prices of
of present and future regulations and with interna-           comparable products as a basis for cost compari-
tional environmental agreements; responding to a              son.
perceived ethical obligation; and, of course, to work
with the American Hospital Association to virtually
eliminate mercury by 2005.

Chapter 4
    The costs of a program to an individual facility      4.3 Hospital Costs (Internal)
needs to be determined on a site specific basis by
working through purchasing and a facility’ vendors.
There are also “costs or savings”worksheets in Sec-       4.3.1 Purchase Price (Mercury Containing Products and
tion 4.5 of this chapter to assist with determining       Alternatives)
the total costs and benefits of mercury-containing
products and their alternatives.                               Relative pricing information on mercury contain-
                                                          ing products and mercury free-alternatives, is pre-
     The cost information in this report is meant to      sented in Chapter 3. In many cases., the cost of
cover the sources of mercury that are most com-           mercury spills is not tracked back to purchase of the
monly found in a hospital setting but is not meant to     mercury containing equipment. Often those types of
be inclusive of every potential mercury source. Mer-      costs are lumped into general overhead costs rather
cury is found in many different chemicals and in many     than traced back to the responsible products and
different uses. The cost information presented in         decision-makers. When accounting practices are ad-
chapter 3 and in this chapter is mainly for equipment     justed, it is possible to recognize the origins of these
and products. Other chemicals may be used, in labs,       downstream costs and make improved long term
for example, which are not included in this manual.       purchasing decisions. Because of the significant
                                                          cost that can be incurred from clean-ups, handling,
                                                          training, etc., the true total costs of mercury contain-
     For a more thorough list of chemicals, please re-
                                                          ing equipment is not only greater than the purchase
fer to the Massachusetts Water Resources Authority
                                                          price but in many cases also more costly than the
and the Massachusetts Academic and Scientific
                                                          total cost associated with the mercury-free alterna-
Community Organization (MASCO) website, which
can be found at MASCO has devel-
oped a database of 5,500 products and chemicals.
The database is currently being added to their            4.3.2 Spill Clean-Up Costs
website in an interactive format. The site also has
mercury content information and will allow vendors            Since mercury is highly toxic, spill clean-up costs
to add pricing and product information.                   can be significant for facilities that use mercury-con-
                                                          taining equipment. Most hospitals seem to have
                                                          some type of spill recovery procedure, but spills
     FOR MORE INFORMATION ON AVAILABLE                    themselves are not consistently recorded and re-
                                                          ported. It is therefore not surprising that the num-
                                                          ber of breakages and mercury spills occurring in a

                                   hospital tend to be underestimated by hospital staff
                                                          (Smith, 1996a). Better recording of spills and their
                                                          costs would likely prove helpful to those who want to
                                                          include estimates of spill costs in purchasing deci-
     Accurate estimates of the costs and risks of pol-    sion-making.
lution directly linked to mercury in the environment
and risks to human health can be difficult to quantify.
Exposure to many persistent toxic substances and
other health risks make it difficult to isolate the ef-
fects of mercury on humans and wildlife, except in
cases of gross exposure. Ironically, the more wide-
spread the toxic substance, the more difficult it is to
isolate chronic exposure because traditional meth-
ods of study depend on exposure differences.

                        MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                        39
Chapter 4
     While actual costs of cleaning up mercury spills               Several spills occurred at the hospital which
are not well documented, certain documented cases               resulted in expensive cleanup and decontamina-
show that mercury spills can be very expensive to               tion procedures. Each spill cost approximately
clean up. For example, Hartford Hospital in Hart-               $3,000 to clean up. These expensive cleanups
ford, Connecticut gathered information on mercury               were one of the reasons Butterworth Hospital has
spills from mercury sphygmomanometers and used                  made a commitment to become mercury-free.
the clean-up costs information as part of its justifica-        (See the Butterworth Hospital case study for more
tion to replace all of the mercury-containing                   details.)
sphygmomanometerss with mercury-free equiva-                        Using mercury not only involves potentially high
lents. Mercury spills at Hartford Hospital cost the             clean up costs, but also administrative costs to
hospital over $60,000 in 1998. Replacement of all               keep procedures up to date and staff trained. In
of the blood pressure equipment at the hospital in              areas where major spills occur, more stringent
1999 cost approximately $80,000.                                measures must be taken, including evacuating the
     Another example where the documentation of                 area , using respiratory gear, and posting warnings.
the costs of reported spills led to replacement of
mercury-containing products with mercury-free prod-
ucts is at Butterworth Hospital (now called Spectrum
Health) in Grand Rapids, Michigan between 1993
and 1995.

                                                                      Table 12. Mercury Cleanup Costs

P rodu c t                                            P u rchase Price              C o m m ents

                                                                                    C o n t a i n s u r face an d a i r
                                                                                    dec o n t a m i n a n t s ,
Mercon Cleanup Kits                                   $102-$288                     solidifier, iden tifier,
                                                                                    aspirator, disposal bags,
                                                                                    instructions, etc.

Mercury Recovery Vacuum (with a 6
Gallon Tan k )

Personal Protective E q u i p m e n t                 $ 2 0 0 - $ 5 0 0 /person

D isposal of M e r c u r y a n d M e r c u r y -      depen d i n g o n
contaminated objects                                  amount to be

                                                      $20-$25/ hr /
 S p i l l R e s p o n s e Team

                                                                                    D oes n o t i n c l u d e c o s t
E m ployee Train i n g                                $ 1 5 /h r/person             of m e r c u r y c l e a n u p k i t
                                                                                    and train i n g m a t e r i a l s

Chapter 4
     Clean up costs vary depending on the number of      4.3.4 Storage and Disposal
spills, amount of time that it takes to clean up the
spill, wage rate, cost of mercury spill kits, and man-        Mercury is required to be disposed of as a haz-
agement time. The average wage rate of spill team        ardous waste. Most hospitals store waste mercury
membes was estimated to be $11 - $15/hr. The             with other hazardous waste materials until the quantity
wage rate can vary widely depending on hospital          is large enough to warrant a pickup. Separating the
policy. It is estimated that a mercury spill clean up    disposal cost of mercury itself can be difficult because
can take anywhere from 15 minutes to 12 hours to         contracts with waste disposal companies generally
clean      de-                                            do not call for the isolation of specific products.
pending on
the size and
location of                                                   According to a 1996 study, the average cost to
the spill, as                                            a hospital for the proper disposal of hazardous waste
well as the                                              is $250 per pick up of a “          ,
                                                                                   Labpack” a 45 gallon drum
availability of                                          that contains a mixture of different hazardous ma-
knowledge-                                               terials (Santostefano, 1996; O’   Grady, 1996). De-
able people                                              pending on the size and the functions of each hos-
to clean up                                              pital, the number of pickups will vary. Assuming the
the       spill                                          average number of pickups to be 10 per year (based
( O ’ r a d y,
      G                                                              s
                                                         on Laidlaw’ estimate for a large hospital), the hos-
1 9 9 6 ;                                                pital would pay $850 annually for disposal. Assum-
Smith,1996a;                                             ing further that 1/4 of an average Labpack is mer-
S m i t h                                                cury and mercury contaminated waste
1996b).                                                  (Santostefano, 1996), th e cost for proper disposal
                                                         of mercury would have been $463 a year.
4.2.3 Training
                                                         4.3.5 Ensuring Compliance
    As per
OSHA regula-                                                                        s
                                                              As a result of mercury’ toxicity and well-
tions, the use of mercury and other hazardous sub-       documented adverse human health and environ-
stances requires that employees be properly trained      mental effects, Federal, State, and municipal
on how to identify, use and clean up the substances.     governments have instituted laws and agreements
Training can be expensive especially because mer-        to minimize the amount of mercury that is released
cury is used throughout the hospital. A typical spill    into the environment.
clean-up training course takes 5 hours and costs
$15/hour per employee plus the cost of materials.             The International Joint Commission identifies
                                                         mercury as one of eleven Critical Pollutants that
    There are also administrative costs associated       should be targeted for reduction. The North
with training. These costs include keeping proce-        American Free Trade Agreement includes mercury
dures updated and tracking who has been trained.         in its group of four substances to be banned or
                                                         phased out by Canada, the United States and
                                                         Mexico. The other three substances have already
                                                         been banned in Canada and the US. The Bina-
                                                         tional Toxics Strategy between Canada and the US
                                                         also designates mercury as a level one substance
                                                         with the challenge of 50% reduction of releases by

                       MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                        41
Chapter 4
    Part of the cost of using hazardous substances          In Minnesota, many hospitals have avoided
such as mercury is ensuring compliance with all         potential fines by partnering with the wastewater
current applicable regulations. Unfortunately, costs    treatment plant to develop mutually beneficial
for hospitals to comply with current regulations are    solutions. One key to this strategy has been
not well documented. For planning purposes each         eliminating all mercury disposal to drains and in
hospital needs to have staff who are familiar with      many cases creating hospital wide plans to elimi-
and regularly verify and update all applicable          nate mercury.
environmental, health and safety regulations. It            In another example in Boston, Massachusetts,
suffices to say that any costs imposed by regula-       the Deer Island Water Treatment facility was
tion will only make storing, treating, and disposing    consistently finding mercury levels higher than what
of waste more expensive. Pollution prevention is        was allowed and consequently initiated a mercury
increasingly cost-effective because it can provide      reduction project with non-compliant hospitals. For
savings, improve efficiency, and reduce the environ-    more information, contact Eugene Benton, 617-
mental liabilities of an organization.                  241-6000 at MASS Water Resources, Boston
                                                        Harbor -Deer Island.
4.3.6 - Potential Non-Compliance
                                                        4.3.7 - Human Health Risks
    On the other hand, there are also potential
costs associated with non-compliance with regula-           The risk to human health is very difficult to
tions, including the remediation and fines, and staff   quantify in terms of cost. However, the risk is very
time and expenses for sampling, monitoring and          real. OSHA standards require that maximum
cleaning of drains and traps. In Minnesota, the         exposure to mercury be no more than .1mg/m 3 on
inability to comply with water discharge regulations    a 8-hour time-weighted average. The American
for mercury has meant that hospitals have had to        Conference of Governmental Industrial Hygienists
look closely at their operations. Mercury used in       recommends mercury exposure levels below 0.025
the past often settles at low points in sumps and       mg/m3. Any mercury spill, even as little as mercury
traps. This means that discharge violations for         thermometers contain, could pose potential risk to
mercury can occur years after mercury is poured         workers and needs to be cleaned up properly.
down the drain. Hospitals in Minnesota which are        Mercury vaporizes relatively quickly, and although
not in compliance with mercury discharge to the         the mercury spill itself is unlikely to hurt anyone, the
sewer have been required to undertake regular           mercury vapor in the room where the spill occurred
sampling. The only way to avoid the sluff off of        presents a hazard to employees. A spill within a
mercury from the system is through costly cleaning      confined area could also require respiratory protec-
of drains and traps.                                    tion under the OHSA regulations, further increasing
                                                        the cost. Those most at risk from mercury expo-
                                                        sure are pregnant women, as fetuses are very
                                                        subsceptible to small amounts of mercury.

Chapter 4
4.4 Environmental and Health Costs (Societal Costs)            Concern about mercury contamination has also
                                                          led to a wide range of regulatory initiatives aimed at
                                                          reducing mercury emissions within the region.
     Identifying and quantifying the costs to society
                                                          (Northeast States and Eastern Canadian Provinces
and the economy from the use of toxic substances
                                                          Mercury Study, 1998)
is a rigorous and complex task. Yet, it is possible to
begin to consider the nature of these costs and                Mercury is a problem in the Great Lakes basin
some specific environmental consequences of               and many of the smaller lakes in which millions of
mercury releases to the environment.                      people live and enjoy recreational activities. The
                                                          environmental impacts of mercury affects both
     Specific costs related to mercury use and
                                                          commercial and sport fishing industries. Loss of
consequent environmental effects are very difficult
                                                          commercial fisheries is one of most easily identifi-
to quantify. For instance, in terms of human health
                                                          able losses of economic value. Cleaner waters
and the environment, how much is it worth to
                                                          would likely increase both the commercial and
decrease the amount of mercury in air, water, or
soil from human activities by 1 ppm? Alternatively,
how much is it worth to recreation and fishing
enthusiasts to know that they can eat all the fish
                                                          and create
they can catch without fear of harming their
     While these costs are difficult to estimate, it is   for other
important to recognize that mercury has these             sectors
detrimental effects and the overall detrimental           such as
effect should be a consideration in the decision-         tourism
making process. The next three sections address           and
more specific environmental and societal effects          related activities.
that need to be considered in a facility’ decision to
                                                               Mercury is so toxic, persistent and
adopt the goal of virtual elimination of mercury.
                                                          bioaccumulative that it is the most frequent basis
                                                          for fish advisories. Mercury is the significant pollut-
4.4.1 Cost of Polluted Lakes                              ant in 60 percent of all water bodies with adviso-
                                                          ries. Forty-one states have advisories for mercury
     Beneficial use impairments (e.g., reductions in      in one or more water bodies, and eleven states
availability of edible fish or drinkable water) result-   have issued statewide mercury advisories.
ing from mercury can be found in lakes in most                 If sport fishing were to increase by 10% in the
every state in the country. The pollution is of           Great Lakes due to decreased pollution and
particular concern in the Great Lakes ecosystem.          decreased fish advisories, estimates of the eco-
These impairments include: restrictions on fish           nomic impact show an increase of revenues of
consumption by humans, restrictions on dredging           approximately $300 million each year. If the fishery
activities, and impairment of water and sediment          is managed in a sustainable manner, this economic
quality. Mercury concentrations in shoreline              impact can be replicated each year for an indefinite
samples of water, sediment, sport fish and biota of       period of time (National Wildlife Federation, 1993).
the Great Lakes often exceed the Great Lakes                   Dangerously high levels of mercury in fish also
Water Quality Agreement. Similarly, forty one             threaten subsistence fishers and wildlife. For
States and three eastern Canadian provinces have          example, several species of wildlife have shown
issued fish consumption advisories recommending           reproductive problems attributable to chemical
limits on the consumption of potentially contami-         pollutants in the Great Lakes. These fish catching
nated fish.                                               species include eight birds, one reptile, and two
                                                          mammals. (Environment Canada, 1991).

                          MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                     43
Chapter 4
4.4.2 Health Effects
                                                               Pollution prevention is generally a much more
    Heavy metals such as mercury can impair                cost effective way of reducing environmental
human health and have medical costs. The most              impacts than using pollution controls. For example
important benefit to society of reducing pollution is      in Minnesota, it is estimated that it costs approxi-
the decreased risk of illness and premature death.         mately $2,500 to $3,500 to remove one pound
These risks occur because a large number of                (.4538Kg) of mercury from a municipal waste
substances are emitted to the natural environment                      s
                                                           incinerator’ air emissions (Michigan Mercury
which cause negative health effects upon exposure          Pollution Prevention Task Force, 1996). It is easier
to humans. For instance, low concentrations of             and cheaper to prevent pollution than to try to
substances such as mercury, PCB, and dioxin in             control the release after it has already occurred.
drinking water supplies can be associated with
increased incidence of serious chronic illnesses
including certain forms of cancer and adverse
effects on neurological, immunological, and repro-
ductive systems (Flint and Vena 1991).

      Benefits of reducing pollution can be difficult to
evaluate in economic terms for a number of epide-
miological reasons including: uncertainty surround-
ing the dose-response relationship for many toxic
substances; the latency periods associated with
some diseases; extent to which responses can be
reduced by “                      ,
               defensive actions” and the com-
pounding effects of exposure to multiple sub-
stances. It is also difficult to estimate and assign
dollar values to avoided cancer, asthma, eye
irritation, and the pain and suffering that accom-
pany these illnesses.

    However, it is important to recognize that there
are serious health effects associated both with
consumption of fish contaminated from mercury
and with direct exposure to high concentrations of
mercury. See Chapter 3 for more information on
health effects.

4.4.3 Societal Costs and Pollution Prevention

    Costs to the environment and society are not
generally included in the purchase price of products
or equipment containing persistent toxics such as
mercury. Environmental liabilities of current and
past practices are usually ignored and not ac-
counted for on financial statements.

Chapter 4
4.5 Mercury Cost Savings Worksheets
    The following worksheets were put together to assist hospitals in determining the costs or
savings of eliminating mercury in their facilities. For the first worksheet, a sample is provided for
reference, followed by a blank worksheet for your personal use.

    The sample worksheet compares the costs of a mercury and a non-mercury mobile sphygmo-
manometer. The analysis shows that, although the initial purchase price of the mercury sphygmo-
manometer might be the same or slightly higher, when clean-up estimates and low disposal cost
estimates are included, the non-mercury sphygmomanometer becomes the more cost effective

    Caluclations on the Sample Worksheet use the following methodology:

    Handling of mercury sphygs = 10 hr * $15/hr = $150

    Spill Clean-up includes the cost of the clean-up kit plus the time required to train staff.
    If an external contractor is required to clean up a spill, costs increase by 4 or 5 times. the cost
    of using internal staff.

    1 spill per year:

    Spill cleanup Kit = $5 - $300

    Staff time for cleanup = $10-$15/hr

    Contractor = $20-$25/hr * 1-5 hours = $10 - $125

    Personal Protective Equipment for Staff = $200-$500 * 2-5 Employees = $400 - $2500

    Initial Training for spill cleanup = $20/hr-$25/hr for trainer * 3 hours = $60-$75
                                    $10-15/hr for employees * 2-5 employees * 3 hours= $60-$225

    Hazardous waste disposal of PPE and cleanup materials = $100 - $500 per spill

    Total Net Operating Cost or Savings : $ 795 - $3875 per spill

    Total Capital Costs for Aneroid Sphygs = $7350 - $9840

    Payback Period (in years) = ($7350-$9840) divided by ($795 - $3875) =.02 to 12.3 years

                        MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                      45
Chapter 4


  Proposed product      Aneroid Mobile Sphygmomanometers __________________________
  Current product     Mercury Mobile Sphygmomanometers ___________________________
  Hospital          Sample Hospital _______________________________________________
  Prepared by ____________________________________________________________________
  Date __________________________            Number of Replacements ________________

  Capital costs of proposed product*

                                              Description                         $ Cost
   Product              30 sphygmomanometerss ($255 to $242/each)            6750 - 7260 ___
   Materials                      _____________________________               ______________
   Installation                   _____________________________               ______________
   Utility connections            _____________________________               ______________
   Engineering                    _____________________________               ______________
   Start-up and training process  _____________________________               _____________
   Other capital costs            Disposal of old sphygmomanometers           1980 _________
                                                 Total capital costs          $6570-9240 _

  Annual Operating Costs                                   $ Current            $ Proposed
                                                         Product Costs         Product Costs
   Disposal                                              _____________        ______________
   Recycling                                             _____________        ______________
   Handling                                              150* ________       150 __________
   Spill clean-up (at 1 spill/year)                      400 _________       0 _____________
   Training                                              90** ________       90 ____________
   Calibration                                           _____________        ______________
   Other                                                 _____________        ______________

   Annual net operating cost or savings                 $640 annual savings w/ mecury-free
                                                         sphygs _________________________

  Payback period (in years) =       Total capital costs                  = -4 to -.02 years
                            Annual net operating cost or savings
  *Depreciation should be considered. Consult with your accounting department about this factor.

Chapter 4

Chapter 4

Chapter 4

Chapter 4
4.6 Summary of Results
                                                              Costs for lab chemicals and pharmaceuticals
                                                          are difficult to compare directly since these chemi-
    Mercury free alternatives exist for most
                                                          cals are not used in isolation but as part of a
mercury-bearing products. Truly effective purchas-
                                                          protocol or procedure. Several hospitals that have
ing decisions need to be based on more than the
                                                          replaced their lab chemicals found that costs for
purchase price. When total costs of mercury
                                                          using mercury free alternatives were approximately
products are considered, cost does not appear to
                                                          the same. (Pollution Probe 1996). For lab and
be a significant barrier to the replacement of
                                                          pharmaceutical chemicals, purchase price is not
mercury products with mercury free alternatives.
                                                          considered to be the most significant issue when
                                                          exploring alternatives, but rather assuring that the
    On the basis of purchase price alone, the cost        mercury-free alternative is right for the application
of mercury free equipment is in some cases com-           and educating hospital staff on its use.
petitive and in some cases more expensive than
mercury-based products. However, there are
                                                              It is important to note that product cost is not
several additional internal and societal costs that
                                                          the most important factor when patient care
need to be considered with mercury products.
                                                          decisions are being made. Hospitals’     primary
                                                          considerations in their purchasing specifications
      Hospitals’internal costs include:                   include: safety, ease of use, efficacy, warranty, time
      •Purchase price                                     savings, and preferences of medical staff. How-
      •Money and staff time spent on hazardous            ever, as noted above, in most cases mercury free
       waste training                                     products have been developed that meet hospitals’
      •Mercury spill clean-up, waste storage and          specifications. These products are being used
       disposal                                           successfully by hospitals around the country.
                                                          Purchasing decisions benefit from the evaluation of
      •Potential costs of non-compliance with
                                                          true costs and the consideration of the environ-
       environmental laws (e.g., fines, staff time        mental benefits of being mercury-free.
       and expenses for sampling and cleaning
       traps and drains, damages to
       hospital’ image).
      •Potential health risks to staff, patients,
       and visitors.

     Societal costs include damage to the environ-
mental and public health for which the hospital is
not held responsible.
     Even when only the internal costs were consid-
ered, it was shown that the use of mercury-free
equipment can save facilities money.
     The key is in identifying all of the costs associ-
ated with the usage of mercury equipment and
attributing those costs to the equipment itself
rather than letting those costs get lost in overhead

Chapter 5
Mercury Reduction Case Studies
5.1 - Strong Memorial Hospital, Rochester, New
                                                              1. Mercury thermometers were being used
                                                         in cases of isolation patients and in-patient care
                                                         units where electronic thermometers were
     When the Monroe County Department of                deemed inappropriate. These units included
Health decided to form a Mercury Pollution Preven-       Newborn and the Neonatal Care Units. Six units
tion Task Force it contacted and received coopera-       were identified as using over half the mercury
tion from a faculty member of the University of          thermometers at SMH. The rest of the Hospital
Rochester Medical Center’ Environmental Health           used non-mercury devices. The Director of
Science Department. A student in the Master’       s     Medical Engineering stated that over 1.14
program for Environmental Studies performed              million non-mercury temperatures were taken at
initial fact finding as part of a project for a Master   SMH during 1996 and that the phase-out would
of Science degree.                                       continue as more equipment was purchased.

     No University or Strong Memorial Hospital               2. Mercury-filled sphygmomanometers were
administrator was contacted formally by the County       being phased out as the equipment needed
                  kick-off”meeting. Informal commu-
until the initial “                                      replacement. All new construction and renova-
nication between a faculty member and the                tions included aneroid blood pressure reading
University’ Director of Environmental Health and         devices.
Safety prior to the kick-off meeting was not ad-
equate to outline the project intent or scope. The
net result was that it took over a year to work out          3. Gastrointestinal devices that contained
a Memorandum of Understanding (MOU) that was             mercury were generally being replaced with
acceptable to all parties involved. Once top admin-      tungsten-filled equipment unless there was a
istrative staff were on board the rate of progress       medical reason for not doing so.
and access to the facility improved dramatically.
                                                              4. Laboratory reagents, such as histology
    This experience yielded Lesson 1: Identify and       fixatives and stains, that contained mercury had
involve all appropriate facility management in the       not been used since 1992. Only those reagents
process before predetermining a program’ scope
                                           s             or procedures in which mercury could not be
and desired outcome.                                     substituted or were not known to contain
                                                         mercury were still being used in the Clinical
    The intern wrote a comprehensive report which
detailed the status quo of mercury usage and
management at the University of Rochester Strong             5. Noncontact dental amalgam was
Memorial Hospital (SMH). In addition, other              being collected for proper disposal.
undergraduate interns, along with members of
University/SMH staff, investigated mercury usage             6. Energy efficient lighting was installed
and gathered existing policies/protocols (official       as a part of the USEPA Green Lights Pro-
and unofficial). The findings were as follows:           gram. High mercury T-12 lamps were re-
                                                         placed by lower mercury T-8 lamps.

                                                              7. Fluorescent lamps that failed Tox-
                                                         icity Characteristic Leaching Procedure
                                                         (TCLP) testing were being collected and
                                                         disposed of as hazardous waste.

                        MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                      51
Chapter 5
         8. Mercury spill protocols were long                     10. Battery collection sites were already
     established (at least since 1983). These                 established throughout the Medical Center to
     were current and the staff trained periodically.         prevent batteries from being incinerated. In
     A log book of spills was being maintained. In            addition, a letter was on file stating that the
     fact, SMH owned a special mercury vacuum                 alkaline batteries purchased under the
     cleaner with activated carbon filters for vapor          University contract contained no added
     control. An industrial hygienist used a mer-             mercury.
     cury vapor “  sniffer”to determine if spill
     cleanup efforts were successful. The earliest                11. Monthly monitoring for mercury
     record of a mercury “   sniffer”being used at            vapors was being performed by an industrial
     the facility was in the early 1980s. There was           hygienist in areas where mercury equipment
     also a pre-existing mercury disposal/spill               was being repaired or stored.
     protocol for Nursing Units in existence since
     1983 that has been updated periodically.

       9. Hazardous waste, including mercury,
     was being collected via a formal program and
     shipped to off-site facilities for disposal.

  Areas of concern included:

  • Initial testing of the wastewater effluent showed mercury levels of 0.8 ppb. This would be required to
    be reduced once the Great Lakes Water Quality Initiative standards were adopted.
  • Existing policy was sometimes decentralized. Gathering information was sometimes difficult and the
    results from questionnaires or other queries could be conflicting. There was no mercury
    thermometer take-home policy.
  • Substitutes for mercury are still to be identified for thermometers in some applications at SMH.
  • Mercury as a contaminant needs to be addressed for various lab reagents and cleaning compounds.
  • Mercury pollution prevention training needs to be incorporated into as many pre-existing training
    programs as feasible.
  • Contact amalgam (amalgam that has been in the patient’ mouth) was being considered regulated
    medical waste.
  • Mercury thermometers from isolation patient care rooms were being considered regulated medical
  • Nursing staff surveys indicated that not all staff understood fully what to do with used mercury
    thermometers or with mercury in the event of a spill, in spite of existing policy and training. Similar
    knowledge gaps were also discovered in other areas of the institution.

     This information led to Lesson 2: In spite of policy or training, there are always items that can fall
 through the cracks. It pays to compare practice with policy in order to identify and solve a problem.

Chapter 5

    A Mercury Work Group was established at SMH. It included representatives of:
       Administration                         Housekeeping
       Clinical Laboratories                  Medical Engineering Laboratory
       County Health Department               Nursing Practice
       Dentistry                              Procurement
       Education                              Quality Assurance
       Environmental Health and Safety        Stores

    The Hospital’ mercury pollution prevention program accelerated after the formation of the Work
    Group in the following areas:

    Elimination of mercury
    • Non-mercury thermometers were identified and tested in some of the areas where no substi-
       tute was previously identified.
    • Some nursing units no longer give out take-home thermometers.
    • Laboratories were surveyed to verify that mercury was still no longer being used. If discov-
       ered, the use and disposal route were determined.
    • Mercury sphygmomanometer replacement was tracked more closely and the rate of replace-
       ment increased.

    • Mercury-specific training was included in the annual required training video. A specific test
       question about mercury disposal was included. Also a new segment about mercury was added
       to the Facilities Operations and Maintenance training presentation.
    • Educational packets were created for nursing managers and the housekeeping supervisor.
    • A mercury survey for nursing personnel was developed that was intended to be used both
       before and after training. (See survey at the end of this case study.)
    • Articles were written and published in SMH/University newspapers that pointed out some of
       the issues and concerns with mercury.
    • Designated containers for mercury thermometer disposal were placed in the “      soiled utility
       rooms.” The containers are marked with a specially designed sticker (see end of this case
    • Specially designed stickers (see end of this case study) were placed on or near red bag con-
       tainers to discourage the placement of a mercury thermometer there.
    • An overview of the mercury pollution prevention program was given to department heads at a
       meeting. The overview included the reasons for the program and successes that have been
       achieved so far.
    • A pamphlet on “    Mercury Management for Nursing Units”was distributed to the nursing per-
       sonnel (see end of this case study).
    • A plan was developed to display educational materials about mercury for the general public in
       the corridor to the Hospital cafeteria.

                   MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                         53
Chapter 5

      • Nursing Policy was updated to cover mercury thermometers from isolation units (disinfection
         prior to collection).
      • Policies about mercury have been collected from various departments and are being consoli-

      Best management practices
      • A disposal container for mercury-containing electrical parts, such as switches, was placed at
         the location where the replacement equipment is distributed.
      • A protocol for the care, use and recycling of dental materials was implemented in the Depart-
         ment of Dentistry and Eastman Dental Center.
      • The Hospital entered into an agreement with the Monroe County Department of Environmen-
         tal Services that establishes best management practices to reduce mercury loading from the
         Hospital to the County’ wastewater treatment system.

         For further information, contact Hazardous Waste Manager, Environmental Health and Safety,
         University of Rochester, 716-275-2056.

Chapter 5
                              Mercury Survey for Nursing Personnel

     This survey is part of an upcoming hospital-wide effort to educate personnel about the proper
     handling and disposal of mercury-containing items.

     A.   Which of the following items may contain mercury?
     1.   Gastrointestinal tubes
     2.   Sphygmomanometers
     3.   Thermometers
     4.   Batteries

     B. What is the proper disposal method for mercury thermometers in patient care
        units? Choose one.
     1. Place in normal trash.
     2. Place in red bag.
     3. Send home with patient.
     4. Label and place in hazardous waste collection area.
     5. Place in sharps shelter.
     6. Do not know.

     C. Do you know why mercury thermometers should be discarded in this manner (see
        question above)? Choose all that apply.
     1. It prevents mercury from getting into the air during incineration.
     2. It prevents mercury from causing an explosion.
     3. It prevents mercury from reacting with other hospital chemicals.
     4. It ensures proper disposal of mercury.
     5. It prevents the spread of disease.
     6. All of the above.

     D. What is the proper disposal method for a mercury thermometer that has been
        used in an isolation unit? Choose one.
     1. Disinfect before removing from the isolation unit and place in normal trash.
     2. Place in red bag.
     3. Send home with patient.
     4. Disinfect before removing from the isolation unit, label,
        and place in hazardous waste collection area.
     5. Place in sharps shelter.
     6. Do not know.

                    MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                     55
Chapter 5
      E. What is the problem with sending mercury thermometers home with new moth-
         ers? Choose all that apply.
      1. The thermometer can cause a health problem in the baby during normal use.
      2. The thermometers are very expensive.
      3. The family may be exposed to mercury if the thermometer breaks.
      4. The thermometer may not be properly discarded.
      5. Do not know.

      F. What is the protocol for disposal of gastrointestinal tubes containing mercury?
         Choose one.
      1. Place in a sealed labeled container and place in thehazardous waste collection area for pickup
         by Materials Management personnel.
      2. Place in a sealed labeled container and then in the normal trash.
      3. Place in a sealed labeled container and call the Hazardous Waste Management Unit for pickup.
      4. Do not know.

      G . Which of the following health effects is associated with chronic exposure to
          mercury vapor? Choose one.
      1. Cardiac arrest
      2. Lung cancer
      3. Damage to the nervous system
      4. Allergies
      5. Do not know

      H. Why is it important to keep mercury out of the air and water? Choose all that
      1. It causes human health problems.
      2. It bonds easily with other metals.
      3. It can damage fish and wildlife.
      4. It can be explosive when exposed to sunlight.
      5. Its discharge is illegal.
      6. Do not know.

      I. Who can you always call in the event of an emergency?

      What is the telephone number?_________________________________________________

Chapter 5
                    Answers to Mercury Survey for Nursing Personnel

   This survey is part of an upcoming hospital-wide effort to educate personnel about the proper
handling and disposal of mercury-containing items. (Correct answers are in italics.)

   A. Which of the following items may contain mercury?
   1. Gastrointestinal tubes                  3. Thermometers
   2. Sphygmomanometers                       4. Batteries

   B. What is the proper disposal method for mercury thermometers in
   patient care units? Choose one.
   1. Place in normal trash
   2. Place in red bag
   3. Send home with patient
   4. Label and place in hazardous waste collection area
   5. Place in sharps shelter
   6. Do not know

   C. Do you know why mercury thermometers should be discarded in this manner
   (see question above)? Choose all that apply.
   1. It prevents mercury from getting into the air during incineration.
   2. It prevents mercury from causing an explosion.
   3. It prevents mercury from reacting with other hospital chemicals.
   4. It ensures proper disposal of mercury.
   5. It prevents the spread of disease.
   6. All of the above.

   D. What is the proper disposal method for a mercury thermometer that has been
   used in an isolation unit? Choose one.
   1. Disinfect before removing from the isolation unit and place in normal trash
   2. Place in red bag
   3. Send home with patient
   4. Disinfect before removing from the isolation unit, label, and place in
   hazardous waste collection area
   5. Place in sharps shelter
   6. Do not know

   E. What is the problem with sending mercury thermometers home with new
   mothers? Choose all that apply.
   1. The thermometer can cause a health problem in the baby during normal use.
   2. The thermometers are very expensive.
   3. The family may be exposed to mercury if the thermometer breaks.
   4. The thermometer may not be properly discarded.

                      MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                 57
Chapter 5
  5. Do not know.

  F. What is the protocol for disposal of gastrointestinal tubes containing mercury? Choose one.
  1. Place in a sealed labeled container and place in thehazardous waste collection area for pickup by Materials
  Management personnel.
  2. Place in a sealed labeled container and then in the normal trash.
  3. Place in a sealed labeled container and call the Hazardous Waste Management Unit for pickup.
  4. Do not know.

  G. Which of the following health effects is associated with chronic exposure to mercury vapor? Choose one.
  1. Cardiac arrest
  2. Lung cancer
  3. Damage to the nervous system
  4. Allergies
  5. Do not know

  H. Why is it important to keep mercury out of the air and water? Choose all that apply.
  1. It causes human health problems.
  2. It bonds easily with other metals.
  3. It can damage fish and wildlife.
  4. It can be explosive when exposed to sunlight.
  5. Its discharge is illegal.
  6. Do not know.

  I. Who can you always call in the event of an emergency?

  What is the telephone number?_____X-13________________________________________

Chapter 5
 Mercury Stickers

Chapter 5

Chapter 5

Chapter 5
  5.2 - F.F. Thompson Hospital, Canandaigua, New York

     F.F. Thompson Hospital has not had a formal              There are some factors that eased Thompson’        s
mercury pollution prevention policy, has not had a        transition to mercury-free. Thompson Hospital em-
formal educational program, and has not had a mer-        powers its associates to make decisions, thus has-
cury pollution prevention “            ,
                            champion” and yet Th-         tening the time to move a project from the idea
ompson has elim inated almost all uses of mercury         phase to the implementation phase. Thompson
from the facility. Thompson began its informal mer-       Hospital is a relatively new facility. Therefore, it has
cury pollution prevention program in 1990 because         been easy to ensure that electrical equipment, such
of the recognition that mercury products can be           as switches and thermostats, are mercury-free.
hazardous to employees and patients, especially                       s
                                                          Thompson’ small to medium size may be an advan-
where there is a high potential for breakage. Other       tage over a larger hospital. It is easier to make
incentives were the reduction of mercury disposal         changes in a smaller hospital because it has a
costs, the avoidance of mercury spill cleanups, and       smaller inventory. Also, a smaller hospital may use a
the difficulty of complying with OSHA requirements        smaller variety of materials.
for the use of mercury.
                                                             For further information, contact Mike Zanghi,
    The pollution prevention program began with the       Safety Officer, F.F. Thompson Hospital, 716-396-
phase-out of sphygmomanometers, which was com-            6770.
pleted in 1993.

The Hospital has also:

• Discontinued the use of mercury thermometers,
except in isolation units, because the electronic ther-
mometers were considered to be a better technol-
ogy overall.
• Discontinued the use of mercury stains in order
to eliminate discharge of the stains to wastewater.
• Replaced or are replacing mercury gastrointesti-
nal tubes with tungsten tubes.
• Eliminated the use of mercury batteries because
newer equipment came with mercury-free batter-

Chapter 5
5.3 - Case Studies of Mercury Pollution Prevention Measures in Michigan Health Care Institutions

    The following information is adapted from: Michigan Mercury Pollution Prevention Task Force (1996),
Mercury Pollution Prevention in Michigan: Summary of Current Efforts and Recommendations for Future

    As part of the compilation of the Mercury Pollution Prevention in Michigan report, a health care group was
formed to identify the uses of mercury in hospitals and alternatives for those uses. Several hospitals were
contacted regarding the topic of mercury pollution prevention measures currently underway in their institu-
tions. While there are measures that must be adhered to under federal and state laws, for example training
on spill prevention and management, many of these health care institutions go beyond mere compliance with
existing law by educating a broad spectrum of employees in the proper procedures in handling mercury spills
and minimization of mercury use. The following are examples of some of the ongoing activities.

5.3.1 - Detroit Water and Sewerage Department
(DWSD)                                                                  During the past several years, DWSD has also
                                                                    conducted sampling at two major Detroit hospitals
    The following information is taken from a                       that have instituted pollution prevention plans.
National Wildlife Federation information bulletin
         Mercury Pollution Prevention in Healthcare
entitled “                                                               Sampling began in January 1993 for the first
- A Prescription for Success”.                                      hospital (sites #1 and #2) and continued through
                                                                    October 1995. Before the mercury pollution
     As part of the DWSD National Pollution Dis-                    prevention program, which began in April 1994,
charge Elimination System (NPDES) permit applica-                   measures at these sites were on the average of
tion, a new mercury minimization plan has been                      0.28 parts per billion (ppb) and 0.96 ppb, respec-
instituted. One major part of the plan requires                     tively. After the program was instituted, these
DWSD to work with local hospitals to identify                       figures dropped to 0.15 ppb and 0.13 ppb, respec-
sources of mercury and institute in-house plans to                  tively. At the second hospital (sites #3 And #4 ) the
eliminate mercury use. Some of the hospitals that                   sampling that took place between May 1991 and
have participated in these efforts include Henry                    November 1995 showed similarly encouraging
Ford Hospital, Holy Cross Hospital, St. Joseph’ s                   results. Pre-pollution prevention figures averaged
Hospital and St. Mary’ Hospital.                                    0.34 ppb and 0.74 ppb, respectively, while samples
                                                                    taken after the program was instituted averaged
     These hospitals approached the problem of                      0.09 ppb and 0.11 ppb, respectively.
mercury use within their facilities by following some
basic steps, including: conducting inventories to                       The mercury pollution prevention plans insti-
identify sources of mercury within their facilities;                tuted at these two hospitals, which include the
making recommendations to existing hazardous                        purchasing of alternative products and ongoing
waste and safety committees and the administra-                     phaseout of mercury-containing items, have
tion for reducing or eliminating these sources;                     resulted in substantial decreases in the amounts of
instituting immediate steps for mercury reduction;                  mercury being discharged to DWSD.
and, devising long-term goals for the virtual elimina-
tion of mercury from their facilities.                                  For further information contact Steve Kuplicki,
                                                                    Industrial Waste Control Division, DWSD, at 313-

                          MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                             63
Chapter 5

5.3.2 - Butterworth Hospital (now Spectrum Health),      5.3.3 - Corning Clinical Laboratory (now Quest
Grand Rapids, Michigan                                   Diagnostics), Wyoming, Michigan

       Butterworth Hospital made a commitment                   Corning Clinical Laboratory instituted mer-
   to reach mercury-free status. They have insti-           cury pollution prevention measures to meet the
   tuted a purchasing department policy stating                  s
                                                            City’ strict water guidelines of 0.5 ppb. Corning
   that, unless there is no suitable mercury-free           isolated manufacturer contributions of mercury
   alternative, no mercury-containing devices are           within its wastewater system by testing its list of
   to be purchased. Administrative approval was             reagents for mercury content. Manufacturers
   given to replace all sphygmomanometers                   might not list mercury on their Material Safety
   currently in use with aneroid devices. The               Data Sheets if the amount is less than one
   obstertrics department stopped sending mer-              percent. Therefore Corning did not know the
   cury thermometers home with new mothers.                 sources of mercury until test results were
                                                            finalized. Once the sources were determined, a
                                                            formal mercury reduction policy was instituted.
        Butterworth Hospital hired a local environ-
                                                            Corning located vendors that could provide
   mental consultant to devise a mercury spill
                                                            mercury-free reagents or, where possible,
   response and disposal plan that is safe and
                                                            changed methodologies to processes that do
   economical for the entire hospital. The consult-
                                                            not involve mercury.
   ant also offered training on spill response,
   prevention and management. Educational
   materials about mercury, including the Terrene                The following is a list of the top nine
   brochure (see Appendix I), were distributed to           mercury-containing reagents discovered at
   all hospital departments, administrative person-         Corning Clinical Laboratory. It should be noted
   nel and regional facilities.                             that the survey of these reagents occurred over
                                                            time and the manufacturers may have reduced
                                                            their mercury content since the original testing:
         Spectrum Health is currently introducing
                                                            Prostatic specific antigen (Hybertech); Crypto-
   mercury pollution prevention in all entities in the
                                                            coccus antigen wash (Meridian); Clostridium
   Spectrum Health system, such as free-standing
                                                            difficile wash (Meridian); Cesium diluent for
   medical centers, clinics, nursing homes and
                                                            lithiums (CMS); Wash solution for Hitachi
   affiliated rural hospitals.
                                                            analyzers (BMC); FTA antibody test kit (Zeus);
                                                            Lyme antibody test kit (Mardx); EBV antibody
       For further information, contact Dan Stick-          test kit (Organon); Herpes antibody test kit
   les, Environmental Safety Manager, at 616-               (Biowhittak)

Chapter 5
5.3.4 - Riverside Osteopathic Hospital, Trenton, Michigan       Laboratories within the University Hospitals are
                                                            investigating whether or not laboratory procedures
    Riverside Osteopathic Hospital’ Mercury
                                    s                       that contain mercury can be substituted by those
Minimization Plan includes identifying sources of           that are mercury-free. However, laboratories are
mercury, developing a spill management procedure,           hesitant to switch procedures where the same
providing educational material to staff, and devel-         effectiveness is not guaranteed. The pharmacy has
oping an action plan that sets up a timetable for           successfully discontinued using mercury in any
implementing mercury pollution prevention mea-              items dispensed. The UM Health System has also
sures.                                                      implemented a fluorescent tube recycling project.

    Riverside Hospital identified some mercury                   The Terrene brochure (see Appendix I) was
sources and found mercury-free alternatives.                distributed to individuals within the UM Health
Riverside informally instituted a policy allowing only      System who are responsible for distribution and
mercury-free devices to be used in the Hospital,            disposal of mercury-containing items. UM Hospitals
including thermometers, thermostats and sphygmo-            utilize a mercury vacuum as appropriate during spill
manometers. The Hospital discontinued using                 response activities.
mercury-containing batteries, and has substituted
water-containing esophageal dilator tubes for the
mercury-containing tubes. Riverside is investing in         5.3.6 - Genesys Health System, Grand Blanc Michigan
T-8 lamps with electronic ballasts that contain less
mercury than the lamps previously used. The
Hospital has also eliminated caustic drain cleaners             A formal policy that replaces mercury-containing
and switched to the alternative organic oils and            thermometers and sphygmomanometers with
compounds that are not as harmful to the environ-           electrical devices where medically acceptable and
ment. A spill prevention kit was purchased for              feasible has been instituted by Genesys Health
mercury cleanup.                                            System, as well as a purchasing policy that allows
                                                            only mercury-free items to be purchased. Also in
                                                            effect is a goal to eliminate clinical lab procedures
                                                            that contain mercury.
 5.3.5 - University of Michigan (UM) Health System, Ann
Arbor, Michigan                                                 Genesys has partnered with the National
                                                            Wildlife Federation in support of their “
    An informal policy exists in the institution            Free Medicine”initiative. Mercury containing
allowing only mercury-free items to be purchased.           sphygmomanometers have already been replaced
This includes sphygmomanometers, thermometers               with non-mercury units at the East Flint Campus
and batteries. Sphygmomanometers containing                 Family Practice Center and the Dort Medical
mercury have been replaced with aneroid devices,            Building. In addition, fluorescent lamps are now
including those in newly acquired physicians’               recycled.
practices and offsite clinics. The same holds true
for mercury thermometers, which are being re-
placed by their digital counterparts in all areas.

                           MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                           65
Chapter 5
    Genesys Health System has also devised                     Thermometers and esophageal dilators con-
programs to train its employees on spill response          taining mercury have been or are being replaced
and spill prevention and management that properly          with mercury-free alternatives. Blood pressure
clean up mercury spills in accordance with appli-          cuffs that contain mercury are in the process of
cable regulations, as well as to evaluate fluores-         being replaced with aneroid devices. While there
cent tubing. An Environmental Control Advisory             are still devices that contain mercury located and
Committee within Genesys has formed an Environ-            used at the hospital, the safe storage of these
mental Control Policy stressing reduction of waste         devices is an important consideration for Henry
into the environment. The committee has also               Ford.
provided education materials concerning mercury
pollution prevention to staff people.                                      s
                                                                Henry Ford’ laboratory does not release any
                                                           chemicals down its drains, thereby minimizing
   For further information contact Scott Cruzen at         chemical wastes in its effluent. The laboratory also
Genesys Occupational Health Network at 810-742-            does not keep excess chemicals on their laboratory
7700.                                                      sites, buying only the necessary amount of chemi-
                                                           cals needed for their procedures. Henry Ford has
                                                           removed their old drains and catch points and
                                                           replaced them with up-to-date systems. The
5.3.7 - Henry Ford Hospital, Detroit, Michigan
                                                           sediment within the pipes are cleaned systemati-
                                                           cally, and the sludge is treated as hazardous waste.
     Perhaps one of the most important aspects
Henry Ford stresses in environmental matters,
including mercury pollution prevention, is educa-              For further information contact Mark Dittman,
tion. Education at the clinical, administrative, and       Environmental Safety Officer at 313-916-4259.
emergency planning levels focus on being environ-
mentally responsible while at the same time
meeting the community health needs. The alterna-
tives to mercury-containing items must be clinically
viable in order to be used, and a product that is not
environmentally sound will not be purchased.
First-response teams are able to minimize patient
discomfort and maximize their care, tuning into the
emotional element of pollution prevention.

For more information about mercury pollution prevention in Michigan hospitals, contact Steve Kratzer,
Michigan Department of Environmental Quality, 517-373-0939.

Chapter 5
5.4 - Massachusetts Water Resources Authority
(MWRA)/Medical, Academic and Scientific Community           •Facilities Loadings Subgroup Report
Organization (MASCO) Mercury Work Group
                                                            -estimated sewer discharge loadings of mercury
     The Massachusetts Water Resources Authority        from five types of facilities discharging to the
(MWRA) is a public agency charged with supplying        MWRA sewerage system.
water and sewerage services to municipalities in
the Boston metropolitan area. The MWRA/MASCO                •Pretreatment Guidance Manual
Mercury Work Group, a public-private partnership
of the MWRA and sewer dischargers (including
hospitals, universities, and other industries), was         -recommended steps for implementing coordi-
established in 1994 to study and implement ways         nated source reduction, source segregation, and
to reduce mercury discharges to the MWRA sewer-         pretreatment including mercury pretreatment.
age system. One institution, the Medical Academic
and Scientific Community Organization, Inc.                 •Technology Identification Subgroup Report
(MASCO) that represents many local Boston hospi-
tals, has worked from the beginning of this effort to       -background and results of a bench-scale
help identify the sources and methods of removing       feasibility testing project involving six different
mercury from hospital waste streams. Phase II of        mercury pretreatment technologies
the Work Group was initiated in 1996 to further
examine mercury management techniques and
                                                            •Mercury Management Guidebook
promising mercury pretreatment technologies.

                                                            -recommended steps for overall management
    During Phase I, the Work Group addressed
                                                        of mercury to reduce and control the mercury
sources of mercury, developed a Mercury Products
Database, considered mercury pretreatment               concentration of sewer discharges.
systems, and developed guidelines for source
reduction and removal of residual mercury from              For further information, contact
hospital wastewater piping systems. As a result of          Karen Rondeau, Massachusetts Water
this effort, 28 participating hospitals reduced the         Resources Authority, 617-241-2347
annual mercury concentration of their wastewater
from an overall average of approximately 23 µg/l            or visit MASCO online at:
(ppb) to as low as 6 µg/l (ppb).                  

     The Phase II effort has updated the work of
Phase I and has resulted in the development of an
enhanced Mercury Products Database built on a
Microsoft AccessTM platform. The Database lists
approximately 8,000 chemicals used by hospitals
and institutions. For about 800 listed products,
the Database includes the results of analytical
testing for mercury content. The Phase II effort
also resulted in the publication of four reports as

                       MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                           67
Chapter 5
5.5 - Newton-Wellesley Hospital, Newton Massachusetts


    This case study will emphasize reduction of mercury in a Clinical Laboratory setting, but could be imple-
mented for any toxic material. To reduce use of any toxic material you first have to recognize that you have it.
Once you identify the material or materials that you need to reduce or eliminate from your facility, you are really
faced with three questions:

   1) Where do I begin?
   2) How do I interpret and utilize results of the investigative process?
   3) How do I reduce or eliminate the material?

   Newton-Wellesley Hospital began to look at sources of mercury in the laboratory in order to comply with its
water discharge permit to the local Water Treatment Plant (Massachusetts Water Resource Authority). This
paper will outline the process followed and present the results of chemical testing (performed by Matrix
Analytical, Inc., Hopkinton, MA) and subsequent mercury reduction activities.

   Activities Performed at Newton-Wellesley Hospital to Identify Sources of the Mercury Contamination

    1. We identified all reagents used in the department. A database was established using MSDS information
and the quantity discharged by the lab. The chemicals were then screened for mercury containing substances.
The testing results are provided on the following pages.
    2. We segregated waste by department and screened the waste for mercury. First we placed large drums
for collection of all waste in all departments. The drums were used to eliminate the possibility of the pipeline
as a source of mercury. Aliquots from the drums were tested for mercury. In retrospect the ideal situation
would have been a laboratory that is plumbed to segregation of waste streams once plumbing is determined
to have below quantitative levels of detectable mercury.
    3. All laboratory waste streams which tested positive for mercury were then segregated by bench. Collec-
tion stations were placed on every bench and aliquots of those wastes were submitted for analysis. The bench
areas from which the mercury-containing waste came were identified. The MSDS for reagents used on these
benches were scrutinized, and the manufacturer was contacted for additional information. Suspect reagents
were tested for mercury content.

Chapter 5
Laboratory Mercury Contamination: Results of Initial Testing

Laboratory             Bench                         Analytical Reports mg/L (Cert. Lab testing)
                                                     (SEE NEXT PAGE FOR EXPLANATION OF BQL)

Chemistry              TDX benches                                BQL limit=0.005
Chemistry              IMX benches                                BQL limit=0.001
Chemistry              Array                                      BQL limit=0.002
Chemistry              Flex benches                               BQL limit=0.005
Chemistry              E4A                                        BQL limit=0.002
Chemistry              Specials bench (Electrophoresis)           8.8
Chemistry              Plating soln. (leads)                      0.6
Cytology               EOSIN stain                                BQL limit=0.002
Cytology               OG-6 stain                                 BQL limit=0.005
Bacti                  Cspor                                      10
Bacti                  Hepatitis (Abbot)                          0.15
Bacti                  Probes                                     0.002
Bacti                  Methylene Blue                             0.002
Bacti                  Basic fuchsin                              0.002
Bacti                  Iodine                                     BQL
Bacti                  Crystal violet                             BQL
Bacti                  Auramine-Rhodamine                         BQL
Bacti                  Parasitology (known to contain Hg)         25
Hematology             Coagulation (MLA + Dade Reagents)          BQL
Hematology             IRIS                                       BQL
Hematology             Technicon H1                               BQL
Hematology             Hematoxylin                                BQL
Hematology             Coulter T890                               BQL
Hematology             Semen analysis (Hematoxylin)               0.04
Hematology             Naphthol and NAP AS-D                      BQL
Hematology             LAP                                        BQL
Hematology             Acid Hemat. Soln (Sigma)                   0.01
                       (Peroxidase Satin)
Hematology                 s
                       Gill’ Hemat.#3 (LAP Counterstain)          BQL
Histology              H&E . stainer                              BQL
Histology              Floatation water baths
                       (Microtome Stations)                       Ranged from 0.008 to 1.18
Histology              VIP fixative                               116
Histology              Composite sample                           0.001
Histology              Tote waste                                 0.004
Histology              Water from VIP filter *                    0.04
Histology              Processor 1*                               8.0
Histology              Stainer rinse 2 *                          0.016

                          MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                             69
Chapter 5
Interpretation of Testing Results

    Mercury is one of four substances strictly              BQL could be written by some laboratories as
prohibited from sewer discharge. The accepted          <2.00 ppm with the detection limit stated to be
detection limit based on methods currently accept-     2.0 ppm, thus stating that the laboratory analysis
able to the EPA is at 0.0002 mg/L or 0.2 ppb. The      as run could not detect levels of mercury below 2.0
threshold for enforcement in Massachusetts             ppm. When the term BQL is used the laboratory
(MWRA District) is 0.001 mg/L or can also be           has to state the detection limit.
expressed in parts as 1 ppb (part per billion).

    MSDS reportable limits: Since heavy metals are
considered to be carcinogens or potential carcino-
gens, the concentration limit set by OSHA for
manufacturers to disclose their presence is set at
0.1%. This is equivalent to O.l g/100ml or O.Ol gm/
L or 10 mg/L. Most manufacturers outside of
Massachusetts therefore feel that they have
exceeded their responsibility by reporting the
presence of mercury when it exceeds the EPA limit
of 1 ppm or 1 mg/L, as they legally only have to
include it on the MSDS when it exceeds 10 mg/L.
This is important to recognize when dealing with

     In evaluating a product, we must establish if
the product is certified mercury free or if the
manufacturer has attempted to test only to the
limit set nationally. A company may insist that the
product does not contain mercury because the
company did not detect its presence at a level of
10 ppm or 1 ppm or higher. It is therefore very
critical to ensure that a product to be used in this
hospital has been tested to detect mercury at
levels at or below 1 ppb , not 1 ppm.

Below quantitative limits (BQL):

     This means that the results of the testing
demonstrated that there was no mercury detected
at the lowest concentration that the laboratory’s
method for testing for the concentration of mercury
in that particular specimen could detect. When BQL
is written you need to know what the limits of
detection are for the analysis that you performed.

Chapter 5
Reagents Testing Below Quantitative Levels of Measurement for Mercury

    Non-specific and Specific esterase Kits
    LAP stain
    Technicon Hi reagents - measured as a mixture
    Coulter T890 reagents - measured as a mixture
    IRIS reagents - measured as a mixture
    Dade coagulation reagents - used with MLA

    EA-50 mod
    EASO stain

    Blood Bank:
    Gamma N-Hance (LISS)
    Baxter Certified Blood Bank Saline

    Mixture of reagents and a waste sample collected from each of the following instruments and tested:
    CPK Iso

                          MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                    71
Chapter 5
Continued Testing and Discussion

    Embedded tissue that had been fixed in VIP or other known mercury containing compounds continued to
leach mercury and contaminate other areas of the histology laboratory. Water baths at microtome stations are
the first solutions into which fixed tissues were placed for processing and staining. We should find alternatives
for mercury containing stains.

    Parasitology stains and preservative contain mercury; alternatives need to be found. Stains need to be
tested and replacements for mercury-based reagents, PVA transport system and preservative need to be

    Few problems with mercury, stains and reagents not a problem.

    Testing results from the follow-up of the 8.8 mg/l found in the electrophoresis waste:

    Electrophoresis Reagents:
    HGBA1C buffer                                      0.028 mg/L
    IFE buffer                                         0.2 mg/L
    Elec. Stain                                        1.8 mg/land IFE BQL

    These results could not account for the 8.8 mg/L detected.
    Further evaluation led us to the blood bank saline and blood bank.

    Blood Bank Reagents:
    Grand mix blood bank reagents                      14.3 mg/L
    Blood bank waste (plumbing sample)                 5.8 mg/L
    0.9% sterile saline bags                           BQL
    Dade certified blood bank saline                   0.029 mg/L
    Dade immusal (saline)                              44.2 mg/L
    Immu add (LISS)                                    0.206 mg/L

    Alternative reagents tested:
    Ortho antibody enhancement                         0.07 mg/L
    Gamma N-Hance                                      BQL limit (0.0005 mg/L)
    BCA EM-X                                           0.138 mg.L
    Grand mix (all reagents + H20)                     BQL limit (0.0005 mg/L)

Chapter 5

Toxic Waste Management Program

    The analysis and testing done as a result of the mercury problem led to the establishment of a Hospital
Mercury Reduction Policy (listed below), a method for tracking and following progress of Mercury containing
reagents, and establishment in the laboratory of a Waste Reduction Program.

Mercury Reduction Policy
    Purpose: To enable the Hospital to meet mercury level standards established by the federal and state
environmental protection agencies and the Massachusetts Water Resources Authority (“                   )
                                                                                              MWRA” and require-
ments of the Hospital’ Sewer Use Discharge Permit.
    Background: Mercury is a hazardous substance under state and federal environmental laws. The Hospital’         s
Permit and MWRA regulations prohibit the discharge of mercury into the sanitary sewer system. Pursuant to its
permit, the Hospital must monitor its discharges into the sewer system of several elements, including mercury.
Among other enforcement actions, the MWRA may assess monetary penalties for discharges which exceed the
standard. Neither government nor private agencies have been able to identify a process by which mercury can
be successfully removed from a water stream. The hospital therefore, must attempt to prevent mercury from
entering its waste water stream in order to protect public health and to avoid penalties.
    *It is important to note that since the time this policy was drafted the hospital has identified and is testing
a technology that is producing preliminary results which look excellent for removing the trace mercury from the
    Policy Statement: (Note: This policy was developed for the specific use of Newton Wellesley Hospital; no
representation is made that it is applicable to any other institution). Mercury containing products and pro-
cesses shall not be used in any manner on the Hospital campus, including within the Hospital buildings and
medical office buildings, unless no reasonable alternatives, as determined by Hospital Administration, are
available. When use of a mercury containing product is permitted, measures shall be taken to avoid introduc-
tion of mercury into the sanitary sewer system.
    Applicability: Compliance with this policy and its procedures is a condition of employment and a condition of
the exercise of clinical privileges or the use of any property located on the Hospital campus. The Hospital
reserves its right to take any and all actions, including to seek injunctive relief, to prevent violation of this
policy by any party.

                       MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                           73
Chapter 5

     I. The Hospital’ Departments of Engineering, Environmental Services, Purchasing, Pathology, Radiology,
and Safety shall work together to identify product(s) or process(es) containing mercury currently in use on the
Hospital campus and to identify acceptable alternatives. A list of such products/processes and their alterna-
tives shall be presented to the Safety Committee which shall arrange for its distribution throughout the Hospi-
tal community.
     II. When mercury containing products or processes are identified, the manager(s) for the department(s)
using such products/processes shall develop a plan to include a.) procedures for the prevention of disposal of
any mercury into the sanitary sewer system, b.) a timeframe for the elimination of the use of these products/
processes or, in the alternative, the rationale (including information required below at IV) for continued use of
such products/processes. The manager(s) shall present the plan to the Safety Committee for review and
     III. The Safety Committee shall review all mercury use plans and may approve the plans as submitted or
with modification.
     IV. Managers of departments using mercury products/processes shall maintain a readily retrievable log of
the mercury-containing products/processes, the approved use(s), the alternatives considered, the reasons
such alternatives were deemed unacceptable, and a time frame for reconsideration of available alternatives.
     V. In the event of a mercury spill, employees and physicians shall follow the procedures of Safety Policy
#28-8, Handling of Mercury Spills. Managers shall report such spills to the Safety Committee for review.
     VI. All employees and physicians shall prevent the disposal of mercury into the sanitary sewer system and
shall refrain from using mercury-containing products/processes on the Hospital campus unless such use has
been approved in accordance with this policy.
     VII. All employees and physicians are encouraged to present suggestions for eliminating mercury containing
products or processes from the Hospital campus to the Hospital Safety Committee.




MERCURY CONC.:_______________________________________________________________________

VOL. USED/WEEK:_______________________________________________________________________

DISPOSAL PROCEDURE:___________________________________________________________________


IF CANNOT ELIMINATE, RATIONALE FOR CONTINUING USE:_______________________________________

                    MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                       75
Chapter 5
Hazardous Waste Management Report, Pathology Department, January 1998

    We continue our effort to comply with federal, state, and local hazardous waste requirements
and to provide strong pro-active leadership in hazardous waste reduction. A major focus of the
Pathology Department in 1997 was on the elimination of mercury and a reduction of toxic chemi-
cals at the point of production. Our goal was to improve the workplace, help the environment and
at the same time effectively cut chemical purchase and disposal costs.

Toxic use reduction was accomplished by:
1.    Reduction in Chemical purchases and better inventory control, using the Meditech Chemical
2.    Purchase of equipment that utilized small reagent volumes and generated minimum
      hazardous waste.
3.    Elimination of Hg PVA in Microbiology, replacing with a low Zn PVA system.
4.    Replacement of manual staining procedures in Histology with kits continues with elimination
      of dry chemicals and toxic concentrated stains.
5.    Increased employee training in hazardous materials management and mercury source

    In January of 1997, training in hazardous waste management emphasized looking at chemical
purchases with emphasis on actual need not restocking, cost of discarding expired reagents, and
hazards of having a large inventory of chemicals. Chemical inventories were included as part of the
monthly safety audit of each area and employee knowledge of chemical hazards were assessed
during the routine safety inspections. As of January of this year the amount of hazardous chemi-
cals we were expiring had decreased by half and safety inspection reports showed an increase in
chemical safety knowledge.

     Employee training in hazardous materials management and implementation of several chemi-
cal disaster drills in the department have heightened employee awareness of their role in handling
spills and in controlling chemical waste. The disaster drill reports showed a marked improvement
since 1996.

    New instruments and procedures are now evaluated for the type and volume of chemicals
used and for the impact they will have on our hazardous waste reduction policy. We have seen a
reduction in flow volume of nonhazardous waste in the laboratory of 4500 gallons per month
average in 1998 to 4000 gallons per month in 1999. During the same time frame, the laboratory
has seen an increase in workload volume of as high as 21%.

    The total volume of hazardous waste drums generated per week showed no change from
1997, however, the workload volume in Histology alone showed a 23% increase. The fact that we
were able to keep our hazardous waste volume at the same level even with an increase in testing
volume was due mostly to the reduction in volume of reagents used, and a concerted effort by the
employees in Histology to conserve and reduce toxic waste generated.

Chapter 5

    To comply with the Mercury Reduction Policy, all waste streams in Pathology continue to be tested for
mercury; sources of mercury identified, and alternative-products continue to be actively sought. As an
active participant in the MASCO (Massachusetts Academic and Scientific Community Organization) Mercury
Workgroup, we have taken a leadership role in developing protocols for toxic waste management, identify-
ing effective pretreatment technologies, and ultimately reducing wastewater volumes. The Pathology
department is continuing to evaluate formaldehyde and xylene recycling systems. This would significantly
reduce the hazardous waste volume sent out each week. We have looked at several excellent, small, safe,
and cost effective systems in use in area hospitals. Space and personnel requirements are presently being
evaluated by the department.

    We continue to seek methods which will offer quality results with minimal chemical exposure and waste
production. The ultimate goal is to utilize technology that eliminates employee exposures and toxic waste

Addendum July 1998

    Mercury testing in Microbiology revealed a mercury contamination of the sink and staining racks. The
sink is on order and staining racks have arrived.

Measurement Units

    Milligrams per kilogram or mg/kg equals mg/1000 g of the mixture. This is similar to mg/L as a measure-
ment of a substance’ concentration; however, mg/kg is not volume based but rather based on the specific
gravity of the waste mixture. Expressing concentrations in these terms would eliminate the existing situation
where concentration of mercury detected is dependent on the amount of diluent present. In other words,
hospital A and hospital B may have the same amount of mercury discharge, but if hospital A has a much
higher water usage and discharge than hospital B. hospital A’ waste may be in compliance and hospital
B’ might not.

    For further information on this case study, please contact William Sullivan at Newton-Wellesley Hospital
at 617-243-6562.

                       MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                        77
Chapter 5
5.6 - Dartmouth Hitchcock Medical Center Replaces
Mercury Filled Miller Abbott Tubes

    Background of hospital/medical facility                The cost of mercury disposal and the tracking
                                                       procedure was substantial. In 1995, after deter-
     Dartmouth Hitchcock Medical Center (DHMC)         mining that the challenges of managing this unique
located in Lebanon, New Hampshire is a 427 bed                                      s
                                                       waste stream outweighed it’ usefulness, DHMC
facility and has approximately 6,000 employees         determined that replacing the mercury with water
and volunteers.                                        and contrast media was a reasonable alternative.
                                                       DHMC did not evaluate any other alternatives. The
                                                       risks associated with the use of mercury filled MATs
    Summary of project
                                                       was outlined to the physicians and they embraced
                                                       the new policy.
    Miller Abbott Tubes (MAT) posed a particular
challenge in the effort to eliminate mercury. The
                                                           The Pharmacy no longer had to purchase the
potential for spills and improper disposal is high,
                                                       one pound bottles of elemental mercury. When
despite best efforts to minimize these risks. In
                                                       requests for MATs were placed, a small bottle of
1995, DHMC eliminated the use of mercury in
                                                       contrast media was included (contrast media was
Miller Abbott Tubes by replacing the mercury with
                                                       already in stock in Radiology).
water and a contrast media (indicator to pick up
tube on xray). No other changes in practice of the
use of MATs were necessary.                               Cost to implement/Savings realized

    Process to accomplish goal                             DHMC realized a cost saving from switching to
                                                       water and the contrast media. Savings were
                                                       realized from decreased hazardous waste disposal
     In 1990 due to its incinerator permit, DHMC
                                                       costs and decreased training needed to implement
developed a mercury management program. The
                                                       the tracking system for the Miller Abbott tubes. In
primary objective was to ensure no mercury
                                                       addition, the cost of the contrast media compared
sources were disposed of in red bags and therefore
                                                       to mercury was negligible.
incinerated. Other objectives of the program
included the elimination of “  non-essential”uses of
mercury, manage and track all sources, and treat
all mercury waste as hazardous waste. Miller
Abbott Tubes are used for intestinal blockages, the
mercury is used to weight the device. Initially
doctors did not want to replace the mercury filled
Miller Abbott tubes so DHMC developed a proce-
dure to help ensure that the mercury filled Miller
Abbott tubes were not discarded into the waste
stream. When a MAT was requested, a call was
made to the “   Safety and Environmental Programs”
office to start the tracking process. Handling and
disposal instructions, labels and ziploc bags were
issued with every MAT.

Chapter 5
    Reasons hospital implemented program                    Experience with alternative

     The DHMC Environmental Resource Committee                Since water is not as heavy as mercury, it may
(ERC) and the Safety Committee unanimously               not work as quickly as its mercury counterpart.
passed “ Resolution in Support of a Mercury Free         However, the Safety and Environmental Programs
Initiative for DHMC” DHMC is aware that elemen-          office has not received complaints from clinicians
tal mercury and mercury compounds are known to           about the replacement. The nursing and house-
be hazardous to human health and the environ-            keeping staff have been pleased because they
ment and a potential source of exposure to pa-           werethe parties ultimately responsible for mercury
tients, visitors and staff. DHMC is committed to the     spills.
immediate reduction and eventual elimination of
mercury.                                                     In general, the staff is happy about the switch
                                                         since it eliminated the chance of mercury spills and
    Miller Abbott tubes had to be filled with mercury    exposures, the concern for improper disposal, and
using a syringe which posed health and safety            intensive oversite.
issues with employees and patients. Because this
procedure was not a closed loop system, there was           For more information on this case study,
the potential for mercury spills and exposure to         contact Dartmouth Hitchcock Medical Center
mercury.                                                 Lebanon, New Hampshire.

    With mercury filled Miller Abbott tubes there is
also a potential concern that the sac with mercury
can be disconnected when being removed from the
patient. This poses both medical and liability issues.

    The cost of the tracking system could be
eliminated in addition to hazardous waste costs for
disposing of the mercury from Miller Abbott tubes.

    Overall environmental impact

    DHMC purchased approximately 24 a year. For
each Miller Abbott tube issued, a one pound bottle
of mercury would be issued with the tube. The tube
was filled with as much mercury as needed for the
procedure and the remaining mercury needed to be
tracked to ensure it did not end up in the waste
stream. Typically about a half a pound of mercury
was used per procedure. A rough estimate of the
amount of mercury no longer needed due to the
replacement would be 12 pounds of mercury a

                       MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                     79
Chapter 5
5.7 - Mercury Reduction at Minnesota Hospitals
Mercury Management at Mayo Clinic, Rochester          St. Cloud Hospital, St. Cloud

    Mayo’ management of mercury in the medical            Nurses and physicians at St. Cloud Hospital, a
environment has evolved over time. Mercury            489-bed facility in central Minnesota, have re-
batteries were first collected for referral to a      placed mercury thermometers with digital units that
California-based reprocessing center in 1978. A       pose no threat of mercury contamination to staff or
strong emphasis has existed since the mid-1970s       infants. Rather than risking exposure to mercury in
on collecting and commercially disposing of           the event of a broken thermometer, staff and
mercury-containing laboratory wastes through          patients at St. Cloud Hospital are assured that
Mayo’ hazardous waste program. Specialized            their nursery environment is mercury-free.
mercury vacuum cleaners were first purchased in
the 1970s to ensure that mercury spills were              In keeping with state regulations prohibiting
effectively and safely managed.                       hospitals from routinely sending mercury thermom-
                                                      eters home with new mothers, St. Cloud Hospital
    In more recent years, institutional interest in   provides small, user-friendly, mercury-free ther-
mercury management has led to even more ag-           mometers.
gressive actions. Mercury thermometers have been
removed from Mayo’ 1,500 outpatient examina-              For further information please contact Kris
tion rooms and replaced with electronic devices.      Peterson, Director of Support Services, at
Mercury-containing sphygmomanometers were             320-251-2700, extension 4607.
replaced with mercury-free devices in all hospital
areas. Laboratory test procedures have been
re-evaluated for mercury use with an emphasis on      Hennepin County Medical Center
substitution, whenever possible, and strict atten-
tion to disposal management when not possible.            Staff at Hennepin County Medical Center, a
Used mercury-containing fluorescent light bulbs are   435-bed facility in Minneapolis, Minnesota, used to
collected and disposed of through a commercial        purchase ten to fifteen thousand mercury ther-
vendor who recovers and recycles mercury.             mometers a year. After making efforts to replace
                                                      those thermometers with mercury-free ones, fewer
                                                      that one thousand mercury thermometers are now
    Efforts continue to further investigate and
                                                      needed and the facility is working toward eliminat-
reduce the presence of mercury in the Mayo
environment. Examples of such efforts include the     ing the use of mercury thermometers altogether.
incorporation of heavy metal analysis in certain
product purchases and similar evaluations in             For further information contact Lee Volbert at
certain large components of Mayo’ incinerated
                                     s                612-347-2971.
waste stream. Additionally, there are continuing
educational efforts to sensitize staff on avoidance
of the use of mercury or mercury-containing materi-
als, whenever possible, and especially when alter-
native choices are available.

   For further information, contact David Senjem,
Mayo Clinic, 507-284-7459.

Chapter 5
St. Joseph’Medical Center, Brainerd
          s                                                Representatives from maintenance and pur-
                                                       chasing departments were particularly important to
    St. Joseph’ Medical Center, a 162-bed facility
               s                                       the team. The maintenance staff is familiar with the
in Brainerd, Minnesota, is essentially mercury-free.   inner workings of the Hospital, which is helpful
Aneroid blood pressure cuffs and ear or digital        when conducting monitoring. Purchasing depart-
thermometers are used throughout the facility.         ment involvement is necessary because toxics
Mercury-containing esophagael dilators have also       reduction projects often involve changes in the
been replaced with non-mercury alternatives. The       types of products purchased and used.
only mercury present in the medical center is in the
chemicals used in histology laboratories, and staff        As a first step, the mercury reduction team
are also working toward replacing those chemicals.     completed a survey on mercury use provided by
                                                       WLSSD (see survey at the end of this case study).
Mercy Hospital, Moose Lake                                                                  s
                                                       The survey disclosed that St. Mary’ had already
                                                       replaced some mercury-containing items, such as
                                                       thermometers and blood pressure cuffs, with
    Mercy Hospital in Moose Lake, Minnesota, is a
                                                       alternative electronic devices. In addition, mercuric
rural healthcare provider with 31 beds, an attached
                                                       chloride, a common reagent used in the pathology
94-bed healthcare center, and 11 apartment
                                                       lab, was being captured and handled as hazardous
elderly housing service. The hospital is working
                                                       waste instead of being flushed to the wastewater
towards the elimination of mercury throughout the
                                                       treatment plant.
healthcare campus. The hospital spearheads this
effort with the replacement of mercury thermom-
eters, blood pressure cuffs, and laboratory equip-         A wastewater monitoring plan was then devel-
ment, replacing them with digital thermometers,        oped to try to pinpoint mercury sources within the
aneroid blood pressure cuffs, and thermal-gauge        Hospital. Older buildings, such as hospitals, often
laboratory equipment.                                  have several discharge points to the sanitary sewer
                                                       system. Meeting with maintenance staff to review
                                                       old blueprints was found to be essential before
    For further information please contact Keith
                                                       beginning the monitoring program. The use of dye
Carlson at 218-485-5520.
                                                       tablets may be needed to verify sewer flow and
                                                       route connection information, especially in facilities
St. Mary’ Medical Center, Duluth                       that have undergone expansion. Monitoring results
                                                       found mercury concentrations varying from 0.3 ppb
    The following information is from: Western Lake    to 1.2 ppb. The monitoring also identified days on
Superior Sanitary District (March 1997), Blueprint     which mercury concentrations were high, and
for Mercury Elimination: Mercury Reduction Project     where it came from in the Hospital. In this case,
Guidancefor Wastewater Treatment Plants, page          the information was valuable in educating the
18.                                                    reduction team. The team felt they had already
                                                       solved their mercury problem and didn’ anticipate
    St. Mary’ Medical Center is a 326-bed hospital
             s                                         additional discharges. Once they saw the numbers,
located in Duluth, Minnesota. Western Lake                          can
                                                       however, a “ do”attitude quickly developed.
Superior Sanitary District (WLSSD) staff began the
mercury reduction project by meeting with Hospital
management to ensure their interest and commit-
ment. Once support was assured, an existing team
of Hospital employees worked with WLSSD staff on
the project.

                         MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                   81
Chapter 5
    In 1997, the remaining mercury in the waste-
water appeared to be coming from the Hospital
laboratories and laundry services. Reagents and
bleach are the suspected sources. These products
are being investigated and, where possible, alterna-
tives will be substituted.

    Historic sources are also under investigation.
Mercury from items such as broken thermometers
may have been disposed of down the drain in older
buildings. The mercury accumulates in waste traps
and discharges in small amounts each time water
is used. Traps in nursing stations and in the labs
are being cleaned and inventoried as part of the
reduction effort.

    WLSSD continues to work with St. Mary’ on s
mercury reduction and has initiated similar projects
with the other hospitals in Duluth. These following
actions are essential first steps for any hospital
beginning a mercury reduction project:
    1. Discontinue the purchase of
mercury-containing equipment such as thermom-
eters, sphygmomanometers and gastrointestinal
equipment, and substitute mercury-free alterna-
tives for existing equipment.
    2. Discontinue the policy of sending mercury
thermometers home with new parents (this prac-
tice is illegal in Minnesota).
    3. Institute recycling programs for
mercury-containing lamps and batteries.
    4. Implement a mercury-free purchasing policy
and request all vendors to disclose mercury con-
centration on a Certificate of Analysis. Products
with no mercury or low mercury can then be se-
lected for purchase.

    For further information, contact Jamie Harvie
(formerly of WLSSD), Mercury Specialist, Institute
for a Sustainable Future, at 218-525-7806.

Chapter 5

                             MEDICAL FACILITY MERCURY SURVEY

    This checklist is provided as a sample. A checklist can be a useful tool to help medical facility staff
    identify sources of mercury in their workplace.
    Type of Facility (hospital, clinic) __________________________________________________
    Size of Facility (number of beds, number of patient visits) ____________________________
    Contact Name ________________________________________________________________
    Title _______________________________________________ Phone__________________
    Please indicate the following mercury sources located or used in your facility.
    ___   Fever thermometers (including home-care visits and those sent home with newborns)
    ___   Sphygmomanometers
    ___   Commercial manometer
    ___   Gastrointestinal diagnostic equipment
    ___   Feeding tubes

    ___ Zenker’ solution         ___ Histological fixatives

    Staining solution and preservatives
    ___ Mercury chloride       ___ Mercury (II) oxide ___ Mercury (II) chloride
    ___ Mercury (II) sulfate   ___ Mercury nitrate    ___ Mercury iodide ___ Other

    ___ Fluorescent              ___ Metal halid          ___ High pressure sodium       ___ Ultraviolet

    ___ Mercuric oxide           ___ Button batteries

    ___ Thermostats

    ___ Barometers

    ___ Switches (relay, tilt, silent)

    ___ Other possible mercury sources -- please list here any other materials that
         should be a concern for mercury pollution.
    Have you considered mercury-free alternatives for any of the products listed above?___ Yes ___ No

                      MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                         83
Chapter 5

   Complete the following section on facility practices. Additional pages may be attached if needed.

   Safety Practices
   Is staff training provided on the health and environmental concerns of mercury? ___ Yes ___ No

   Is staff training provided on mercury spill prevention or management?       ___ Yes ___ No
   If yes, indicate the departments that have this training and the frequency.

   Is there a mercury spill clean-up kit on site?                                      ___ Yes ___ No

   Have there been any mercury spills within the last ten years?              ___ Yes ___ No
   If yes, indicate the source of the spill(s) and the clean-up method.

   Purchasing Practices
   Does your facility have a policy on purchasing mercury-containing products?         ___ Yes ___ No
   If yes, please attach policy.

   Does your purchasing department currently require a disclosure by your vendors of mercury
   concentrations in chemicals/reagents?                                          ___ Yes ___ No

   Disposal Practices
   What is the current procedure for disposal of medical waste?
     ___ autoclave ___ incineration ___ other

   Have your sewer drain traps or catch basins been cleaned to remove mercury? ___ Yes ___ No
   If yes, list the area of the facility and dates.

   Was mercury discovered?                                                            ___ Yes ___ No

   Are any mercury products in your facility currently recycled?                      ___ Yes ___ No

   Are there other facility practices that you think should be a concern for mercury pollution? List here:

Chapter 5
5.8 - Children’Hospital of Wisconsin

     The Children’ Hospital of Wisconsin is a 222          The parameters of the program once estab-
certified bed healthcare, education and research       lished were nonnegotiable; required everyone’ s
institution founded in 1894. The Hospital moved its    participation and cooperation; and required ongo-
facility in 1988 to the campus of the Milwaukee                                                s
                                                       ing support and reinforcement. Children’ Hospital
Regional Medical Center in Milwaukee, Wisconsin,       made “  reuses, reduces and recycles”an organiza-
with approximately 2600 employees in its system.       tional responsibility.

    In 1994, Children’ Hospital embarked upon an       2. Acquire the tools and knowledge of the experts:
ambitious program to reduce wastes, increase the
reclamation of “  marketable”recyclable materials      - The laws, rules, regulations and standards for
and identify opportunities to reuse materials where    proper waste management and materials recovery,
appropriate. A philosophy, as such, had been           as well as vendors were researched to determine
shared throughout the organization for a number of     the “best practice”for compliance;
years. However, the Department of Natural Re-
                                                       - Publications and trade magazine articles were
sources’  new waste rules adopted by the state in
1994 provided the necessary synergy for the
Hospital to enhance its program. The Director of                       s
                                                       - The Children’ Hospital utilized experts from the
the Environmental Services Department, respon-         engineering consulting services, hazardous waste
sible for chairing the hospital’ Hazardous Materials
                               s                       management services and the Solid and Hazardous
and Waste Management Subcommittee, an arm of           Waste Education Center of the University of
the Safety Committee, was given the charge. The        Wisconsin-Extension (SHWEC), who assisted in
steps taken to achieve its success are as follows:     performing extensive audits to identify hazardous
                                                       materials and waste located on site and offered
                                                       resource information and guides to assist in reduc-
1. Create an organizational structure with clear       tions and substitutions as the Hospital deemed
responsibilities:                                      appropriate.

    Administrative support and Program Leadership      3. Establish the vision for the program:
(Director of Environmental Services); Task Force:
12-15 members of hospital leadership from various
disciplines (Environmental Services, Laboratory,       - Waste streams were defined and audited
Clinical Engineering, Sterile Processing, Security,    benchmarking current practices;
Material Services, Facilities Operations, Infection    - Evaluation of disposal/recovery processes was
Control, Risk Management, Food Services, etc.)         completed;
dedicated to overseeing “   regions”of the hospital    - Aggressive, yet attainable, goals which would be
dedicated to attending biweekly meetings for one       publicly celebrated were established.
year; Area Coordinators (50 staff level personnel
who volunteer or are appointed by department
heads): assigned and reporting biweekly to Task
Force members, to daily inspect areas, monitor
compliance and offer assistance to areas needing
special attention; Environmental Services staff: who
withhold waste and materials removal services from
non-compliant areas or individuals.

                         MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                               85
Chapter 5
4. Set up and implementation of action plan:              Some of its most significant achievements are:

    - A program for orientation of new employees,            Mercury:
department specific orientation and a process for
continuing education and competency was estab-                 Using substitute “ non-mercury”devices had not
lished (mandatory annual safety fair with hands on        been well received in the hospital setting by physi-
exhibits and exercise for all employees) clearly          cians, nurses and clinical professionals. With proper
identifying individual’ responsibilities for proper       communication, education, employee participation
handling, use and disposals of all materials;             and administrative support, mercury containing
    - Committees (products review, clinical prac-         devices, such as esophageal dilators, blood pres-
tice, etc.) and other departments set up processes        sure manometers and thermometers were tar-
to monitor, limit, restrict and control the acquisition   geted for removal and substitution. Having the “  buy
of non recyclable and hazardous substances/               in”of the key decision makers of clinical practice
materials as well as researching safer alternatives;      was essential. Mercury containing devices such as
    - Mass media kick off and ongoing communica-          esophageal dilators were replaced by tungsten gel
tion of program achievements (hospital newsletter,        filled dilators; blood pressure manometers were
local news media, contracted vendor media com-            replaced with aneroid and electronic devices;
munications);                                             thermometers were replaced with an electronic
    - Source separation processes were defined            digital type. Most mercury replacements were
and containers/storage rooms identified and               implemented by 12/15/96 at a cost of $6,750.00.
appropriately labeled;                                    The annualized cost of thermometers will be less
                                                          than $2,000.00. These product substitutions
                                                          significantly reduced the risk of environmental and
    A process for ongoing monitoring and periodic
                                                          waste water contamination.
reporting, through proper hospital channels, was
                                                             Medical waste:
   Children’ Hospital has enjoyed many suc-
             s                                               Medical waste represented 6.7% of the total
cesses in reducing waste, hazardous materials, and        waste volume in 1998; 128, 980 pounds (2.17
materials recovery reflecting a commitment to             pounds per patient-day) were generated.
ongoing ‘improvements in its processes and pro-
grams.                                                        Solid waste:
                                                              Solid waste represented 58.5 % of the total
                                                          waste volume in 1998, down from 70% in 1994;
                                                          compactor hauling frequencies have been cut in

                                                              Recycling materials:
                                                              Currently 34.8% of the total waste volume
                                                          (paper, cardboard and beverage containers) is
                                                          reclaimed; increasing from 388,107 Ibs. in 1994 to
                                                          673,580 Ibs. in 1998.

Chapter 5

     Children’ Hospital of Wisconsin continues to
pursue hazardous materials and waste reduction
initiatives and pollution prevention strategies. Its
ideas and successes are networked through
member hospital associations on the local and
national level, and through the University of
Wisconsin-Extension, Solid and Hazardous Waste
Education Center.

    In conclusion, fundamental to the success of
these and all waste reduction programs are: top
administration support, employee participation,
education and training, good housekeeping and
materials management, auditing/measuring/
monitoring the program, then reporting achieve-
ments and successes to all those engaged in this
partnership. Also essential to hazardous materials
and waste reduction are, assuring proper handling
and disposal, selecting safer alternatives and
incorporating any changes into the overall hazard-
ous materials and waste management program.

    For further information please contact Chris
Stoll at Children‘ Hospital of Wisconsin. Phone:
(414) 266-2152.

Chapter 5
5.9 - Kaiser Permanente, California

                                                    Healthy Hospitals:
                                           Environmental Improvements
                                      Through Environmental Accounting


                                                               Submitted to:
                                           US Environmental Protection Agency
                                               Office of Prevention, Pesticides
                                                        and Toxic Substances

                                                                August 2000

Chapter 5
Kaiser Permanente -- Mercury Minimization

Organizational Profile

    Kaiser Permanente, the country’ largest not-for-profit Health Maintenance Organization, serves 8 million
members in 11 states and Washington, D.C.; 5.8 million members are located in California. With more than
90,000 employees and 10,000 group practice physicians, Kaiser Permanente’ integrated health delivery
system owns and operates 30 hospitals and 360 clinics.

    Kaiser Permanente purchases about $5 billion of commodities and services annually. According to its
calculations, Kaiser Permanente generates 70 million pounds of waste (solid and infectious) each year.

    Kaiser Permanente’ Resource Conservation Management (RCM) program is a two-year-old initiative at
the national level to integrate issues surrounding supply chain management, environmental health and safety
(EH&S), and facilities management. The goals of the initiative are to minimize waste, prevent pollution, con-
serve natural resources, reduce costs, and develop model environmental protection practices within the
health care industry.

    For additional detail on Kaiser Permanente’ procurement practices, see profile, Appendix A.

Issue and actions to date: Mercury minimization

   Since October 1998, Kaiser has had a mercury minimization policy for national contracting and procure-
ment. RFPs and terms and conditions state:
    Kaiser Permanente is committed to minimizing the amount of mercury utilized in its operations, and
    desires to avoid the acquisition of products that contain mercury whenever feasible alternatives exist that
    do not compromise patient care.
    Potential vendors or suppliers submitting contract bids must identify any mercury contained in the product
they are offering and indicate if a “feasible”mercury-free alternative is available. This policy predates the
mercury reduction commitment of the EPA/AHA voluntary partnership.

   Under this policy, Kaiser Permanente has pursued mercury reduction principally through three procure-
ment items:

·   Thermometers — Switch to digital thermometers. Kaiser Permanente has implemented a national
    standard specifying that only mercury-free thermometers shall be procured; mercury-free
    thermometers have almost entirely replaced the previous stock of mercury thermometers. (One
                                                                                 cold kits”given to
    exception is that mercury thermometers are included in the existing stock of “
    patients for home care. When the 1998– stock of cold kits is depleted, mercury-free kits will be
·   Sphygmomanometers (blood pressure measurement devices) — Mercury-containing devices are no
    longer being procured; aneroid alternative devices are being procured instead. While some facilities
    have completely replaced their mercury sphygmomanometers, most are doing so gradually. When
    facilities are remodeled or renovated, any existing mercury sphygmomanometers are replaced.

                       MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                         89
Chapter 5
·   Fluorescent lamps — Kaiser Permanente has signed a national contract with a fluorescent
    lamp recycler. Large-scale lamp disposal associated with facility lighting efficiency retrofits fall
    under this contract; Kaiser is attempting to divert lights replaced in the course of normal
    maintenance to its recycler as well.
    (See discussion of mercury as a component of the hospital waste stream in Section 3.3)


    Senior management in Kaiser Permanente’ National Purchasing Organization considered the
mercury reduction decision a clear one — mercury was an obvious bad environmental actor, clear
product or practice alternatives existed for the largest mercury sources in the waste stream, and a
national procurement policy would formalize policy which was in many cases being pursued in a de
facto manner by individuals responsible for different procurement areas, both nationally and at
specific facilities.

    Product procurement areas targeted so far are straightforward — mercury-free substitutes were
previously demonstrated and posed no patient care issues. Further mercury reduction is likely to be
more difficult, and involve far more debate and conscious weighing of tradeoffs. The mercury free
alternatives available for product classes such as fixatives, reagents, vaccines, and dental amal-
gams are less proven, do pose efficacy issues, and for these reasons are controversial in many

Role of EA — contributions, considerations

   Underlying management’ willingness to make the mercury reduction commitment was an aware-
ness that the mercury-free alternatives and practices (which would address 95% of Kaiser Permanente’
mercury waste stream) would not result in insupportable costs.

    Kaiser Permanente’ Resource Conservation Manager did employ EA principles in preparing a
supportive analysis of the mercury reduction decision. This analysis and Kaiser Permanente’ expe-
rience with changes in procurement cost structures arising from mercury-reducing product and practice
changes are presented below. They are of interest for two reasons:

·   They provide an example of the application of EA principles, and
·   They clearly illustrate that the hard cost consequences of these waste reduction decisions
    cannot be captured simply by assessing differences in unit purchase costs.
    In addition, they point to the type of analysis which may be necessary for situations in which
tradeoffs between alternative products and practices must be more seriously assessed.

Chapter 5
Avoided costs for mercury-containing devices (thermometers and sphygmomanometers)

    Eliminating procurement of mercury thermometers and sphygmomanometers is expected to result in a
set of cost reductions associated with reduced incidence of spills, exposure incidents and liability, and staff
toxics training. The savings detailed in the table below were calculated across Kaiser Permanente’ system.

 Avoided cost category          Amount     Source of cost avoidance estimate

                                          The cost of a mercury spill kit is known, as is the cost of a spill
                                          response by Kaiser Permanente's contractor. These costs, combinedd
 Spill preparartion/response    $20K/yr
                                          with the average historical number of spill incidents from broken
                                          devices in a year, permit an avoided cost estimate to be made.

                                          Use of mercury-containing devices necessitates staff spill/exposure
                                          training, an estimable cost.

                                          Further, even given staff training, careful use and appropriate spill
Compliance/liability            $15K/yr   procedures, the presence of mercury-containing devices gives rise to
                                          the possibility of fines from facility inspections or spill incidents. The
                                          probabilistic costs of mercury-related penaties were estimated using
                                          representative statutory and regulatory penalties multiplied by the
                                          probability of a fine being assessed for any particular voilation.

                                          A probabilistic cost. Even assuming very high standards of appropriat
                                          eand careful use, some small number of mercury exposures from
                                          broken devices are likely when mercury-containing devices are
 Treatment of exposure          $20K/yr   employed throughout the Kaiser system. Cost is determined from the
                                          expected yearly cost of long-term treatment of a single pediatric
                                          exposure case ($100,000-plus), and the probability of an exposure
                                          incident within a given year.

Additional soft savings (not              "Soft cost" savings were not estimated, but could, for example, include:
quantified, but considered by   ____      Environmental contamination from mercury release and subsequent
environmental staff)                      health impacts, negative media attention.

                         MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                  91
Chapter 5
Changes in per-unit purchase costs (thermometers and sphygmomanometers)

    The avoided costs detailed on the previous page are essentially changes in lifecycle costs asso-
ciated with the products not reflected in their purchase prices. Movement to mercury-free alterna-
tives also changed unit purchase costs and cost structures:

     Thermometers. Mercury thermometers are purchased, used for some expected number of
cycles, and subsequently disposed of, usually when broken. Yearly acquisition costs are thus essen-
tially determined by:

   unit price * (number of units required to replace breakage) + (number of units required to meet
expansion needs, if any)

    An important point, however, is that the purchase of a mercury thermometer almost necessarily
incurs the cost of a spill kit/spill response incident at some future point. At the least, it incurs the
incremental cost associated with disposal of the thermometer as hazardous waste.

    Digital thermometers themselves, on the other hand, are provided at no initial cost by the manu-
facturer. Each use of the thermometer, however, requires a sterile, disposable cover. These covers
are purchased on a per-unit basis.

    The cost structure of the two thermometer alternatives is thus quite different. Digital thermom-
                                         pay             ).
eters incur a clear cost with each use (“ as you go” When treated as a current expenditures
                                                     free”after the billing period in which they were
item, the use of mercury thermometers is effectively “
bought, until they are broken or disposed of, at which point another set of costs is incurred.) 1

    Sphygmomanometers. The traditional blood pressure device measurement device registers
pressure via a mercury column; at $230/unit, the aneroid alternative is significantly more expensive
to purchase on a unit basis. When associated lifecycle costs are included (including the avoided cost
categories detailed in the table above), total costs per unit drop to about 1/3 the total costs of the
mercury unit.

Cost considerations: lighting

    Kaiser Permanente has a facility lighting upgrade program targeted at achieving energy effi-
ciency gains, with resulting cost savings and environmental benefits. Generally, the program focuses
on upgrading existing fluorescent systems with more efficient bulbs and ballasts. The upgrade pro-
gram follows EPA Green Lights program protocols2. Rather than focus on procurement of “      environ-
mentally preferable”lamps — a problematic determination (e.g., what is the tradeoff between (be-
cause fluorescent systems are more energy efficient, but contain mercury) — Kaiser Permanente
has focused on proper end-of-life treatment of lamps.

Chapter 5
    A national contract for lamp recovery and recycling has been tied to the upgrade program; lamps removed
during the course of upgrades are packed and shipped to or picked up by the recycler. Under RCRA, many
fluorescent and other lamps must be handled as hazardous waste, either being recycled or disposed of in a
hazardous waste landfill. The relative costs of recycling versus hazardous waste landfill disposal vary signifi-
cantly by location, and type of lamp (e.g., fluorescent tubes vs. high intensity discharge lamps). In both cases,
end-of-life treatment is a small fraction of total lifecycle costs, which are dominated (90% on average) by
energy use.

    Detailed economic studies have been performed by other parties on lighting upgrade projects in general,
notably by EPA’ Green Lights program; Green Lights provides lighting project assessment tools to evaluate
upgrade costs and expected return. EPA figures indicate that incremental costs incurred by lamp recycling
programs make relatively little difference in the lifetime savings realized from reduced energy use in upgrade
projects. (That is, the additional cost of recycling is small compared to avoided costs of energy resulting from
installation of higher-efficiency lighting.) This reasoning does not apply, of course, to ongoing maintenance,
which involves piecemeal replacement of burned-out lamps with identical new ones. Kaiser Permanente’           s
efforts to integrate ongoing maintenance replacements into its lamp recycling program does add a small incre-
ment to total lifecycle costs.

                                                                                                  Fluorescent Lamps

   End-of-life option              Cost

   Municipal landfill              Average $0.05/lb (>$0.10 per 4-foot tube)

   Recycling                       Average $0.10/foot ($0.40 per 4-foot tube) *

   Hazardous waste landfill        $0.25 - $0.50 per 4-foot tube *


   Expected lifetime energy        $64 ($0.07 kwh, 20000-hour bulb life)
   operating cost for
   one 4-foot lamp

     * plus packaging and shipping costs
                                                                Source: Lighting Waste Disposal

                         MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                           93
Chapter 5
   The following table gives average EPA cost data for fluorescent lighting end-of-life options:


   Gerwig, Kathy (Resource Conservation Manager, Kaiser Permanente). Personal Communication. 23 Sep-
tember 1999.

    Kaiser Permanente. “ National Purchasing Organization Policies and Procedures — Resource Conserva-
tion”(Internal document). September 1998.

                                                          Saving the Earth from Mercury”in Kaiser
   Lawrence, David (Chairman and CEO, Kaiser Permanente). “
Permanente/Stat (newsletter). August, 1999.

   US EPA, Office of Air and Radiation. Lighting Waste Disposal (EPA-430-B-95-004). September, 1998.

       1       It is possible to view both digital and mercury thermometers as having an incremental cost of use — for digital
              thermometers, this is the cost of the sterile, disposable cover. For mercury thermometers, this incremental cost is:
               (unit purchase cost + unit disposal cost)/ (expected number of uses).. This omits discounting and spill, compliance, and
               treatment costs.
       2                                                                                                               s
               Green Lights is a US EPA voluntary program. Its goal is to improve the energy efficiency of the nation’ commercial and
               institutional lighting, thereby reducing greenhouse gas emissions and providing savings to participants. Participants
               commit to completing a lighting survey and upgrading 90% of eligible space, where profitable, within five years.
               Deployed originally as a stand-alone program, it now constitutes the first stage of EPA’ Energy Star Buildings program,
               which targets building energy efficiency more generally.


                                                Appendix A
                    Instruments and Products, Used in Hospitals, That May Contain Mercury

      (This list should not be assumed to be complete.)

          Body temperature thermometers
          Clerget sugar test thermometers
          Heating and cooling system thermometers
          Incubator/water bath thermometers
          Minimum/maximum thermometers
          National Institute of Standards and Technology calibration thermometers
          Tapered bulb (armored) thermometers
      Gastrointestinal tubes
          Cantor tubes
          Esophageal dilators (bougie tubes)
          Feeding tubes
          Miller Abbott tubes
      Dental amalgam
      Pharmaceutical supplies
          Contact lens solutions and other ophthalmic products containing thimerosal,
          phenylmercuric acetate or phenylmercuric nitrate
          Diuretics with mersalyl and mercury salts
          Early pregnancy test kits with mercury-containing preservative
          Merbromin/water solution
          Nasal spray with thimerosal, phenylmercuric acetate or phenylmercuric nitrate
          Vaccines with thimerosal (primarily in hemophilus, hepatitis, rabies, tetanus, influenza,
          diphtheria and pertussis vaccines)
      Cleaners and degreasers with mercury-contaminated caustic soda or chlorine
      Batteries (medical uses)
          Blood analyzers
          Hearing aids
          Telemetry transmitters

     Batteries (non-medical uses)
         High-intensity discharge (high pressure sodium, mercury vapor, metal halide)
     Electrical equipment
         Tilt switches
              Air flow/fan limit control
              Building security systems
              Chest freezer lids
              Fire alarm box switches
              Lap-top computer screen shut-off
              Pressure control (mounted on bourdon tube or diaphragm)
              Silent light switches (single-pole and three-way)
              Temperature control (mounted on bimetal coil or attached to bulb device)
              Washing machine (power shut off)
         Float control
              Septic tanks
              Sump pumps
         Thermostats (non-digital)
         Thermostat probes in electrical equipment
         Reed relays (low voltage, high precision analytical equipment)
         Plunger or displacement relays (high current/high voltage applications)
     Thermostat probes in gas appliances (flame sensors, gas safety valves)
     Pressure gauges
         Vacuum gauges
         Devices, such as personal computers, that utilize a printed wire board
         Blood gas analyzer reference electrode (Radiometer brand)
         Cathode-ray oscilloscope
         DC watt hour meters (Duncan)
         Electron microscope (mercury may be used as a damper)
         Flow meters
         Lead analyzer electrode (ESA model 3010B)
         Vibration meters

                     MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                        A-2

                                            Appendix B
                           Laboratory Chemicals That May Contain Mercury
                                         (Compiled in 1997)

  This list is intended to demonstrate the wide variety of laboratory chemicals that may contain mercury. It
  was derived from examining the Massachusetts Water Resources Authority Mercury Source Identifica-
  tion Program Database (See Chapter 5, Mercury Reduction Case Studies, and Appendix I, Educational
  Resources for a Mercury Pollution Prevention Program).

  Some of the chemicals may contain added mercury, and others may contain mercury as a contaminant in
  a feedstock. If the mercury is a contaminant, its presence or absence may vary from lot to lot. In the
  case of kits, it is necessary to consider separately each of the reagents that make up the kit.

  This list should not be assumed to be complete. Request that vendors disclose mercury concentration on
  a Certificate of Analysis for all chemicals ordered. See Appendix G for a sample letter requesting mercury
  information and sample Certificate of Analysis.

  Acetic acid                                                      Potassium hydroxide
  Ammonium reagent/Stone analysis kit                              Pregnancy test kits
  Antibody test kits                                               Rabbit serum
  Antigens                                                         Shigella bacteria
  Antiserums                                                       Sodium hypochlorite
  Buffers                                                          Stains
  Calibration kits                                                 Standards
  Calibrators                                                      Substance abuse test kits
  Chloride                                                         Sulfuric acid
  Conjugate kits                                                   Thimerosal
  Diluents                                                         Tracer kits
  Enzyme immunoassay test kits                                     Urine analysis reagents
  Enzyme tracers                                                   Wash solutions
  Extraction enzymes
  Hematology reagents
  Immunoelectrophoresis reagents
  Immunofixationphoresis reagents
  Liquid substrate concentrates and diluents
  Negative control kits
  Phenobarbital reagent
  Phenytoin reagent
  Positive control kits


                                                  Appendix C
                 National Listing of State Hospital Waste Reduction / Pollution Prevention Contacts
                                            (Compiled in September 2000)


   Alabama Department of Environmental Management
   Pollution Prevention Unit
   PO Box 301463
   Montgomery, AL 36130

   Mr. Gary Ellis
   Telephone: (334) 213-4303
   General Number: (334) 271-7700
   Fax: 3342717950


   Alaska Department of Environmental Conservation
   Environmental Health Coordinator
   554 Cordova Street
   Anchorage, AZ 99500

   Ms. Kristin Ryan
   Telephone: 9072697630
   General Number: 9072697630
   Fax: (907) 269-7678

   Alaska Department of Environmental Conservation
   Pollution Prevention
   555 Cordova Street
   Anchorage, AZ 99501

   Ms. Tee Little
   Telephone: 9072697586
   General Number: 9074655350
   Fax: (907) 269-7678

                     MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                     C-1


Arizona Department of Environmental Quality
Pollution Prevention
3033 N. Central Avenue
Phoenix, AZ 85012

Ms. Sandra Eberhardt
Telephone: (602) 207-4210
General Number: (800)234-5677 ext. 4333.
Fax: 6022074538

ARIZONA, Nationwide Links

Earth’ 911
Reduce, Reuse and Recycle Sites
5110 N. 44th Street, Suite L120
Phoenix, AZ

Ms. Anne Reichman
Telephone: 6022245444
General Number: (602) 224-5444
Fax: 6025538782


Arkansas Department of Pollution Control and Ecology
Customer Service Division/Pollution Prevention
P.O. Box 8913
Little Rock, AR 72219-8913

Mr. James Gilson
Telephone: (501) 682-0821
General Number: (501) 682-0744
Fax: (501) 682-0798
Website: Prevention



   California Environmental Protection Agency/Department of Toxic Substances Control
   Office of Pollution Prevention and Technology Development
   P.O. Box 806
   Sacramento, CA 95812-0806

   Ms. Mary Pride
   Telephone: (916)324-1088
   General Number: (916)322-3670
   Fax: 9163274494


   Colorado Health and Hospital Association
   Pollution Prevention
   7335 East Orchard Rd., Suite 100
   Englewood, CO 80111

   Ms. Particia McClearn
   Telephone: (720) 489-1630
   General Number: (720) 489-1630
   Fax: (720) 489-9400


   Conneticut Department of Environmental Pollution/Bureau of Waste Management
   Department of Pollution Prevention
   79 Elm Street
   Hartford, CT 06106-5127

   Ms. Kim Trella
   Telephone: (860) 424-3234
   General Number: (860) 424-3297
   Fax: 8604244081

                      MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                     C-3


Delaware Department of Natural Resources and Environmental Control
Pollution Prevention Program
89 Kings Highway
Dover, DE 19901

Ms. Andrea Kreiner
Telephone: (302)739-3822
General Number: (302) 739-4403
Fax: (302)739-6242


Florida Department of Environmental Protection
Pollution Prevention
2600 Blair Stone Rd., MS 4750
Tallahassee, FL 32399-2400

Ms. Laurie Tenace
Telephone: (850) 488-1865
General Number: (850) 488-1865
Fax: (850) 921-8061

Florida Pollution Prevention Roundtable


Georgia Department of Natural Resources
Pollution Prevention Assistance Division
7 Martin Luther King, Jr. Drive, Suite 450
Atlanta, GA 30334-9004

Ms. Stephanie Busch
Telephone: (404) 651-5120
General Number: (800) 685-2443
Fax: (404) 651-5130


   Department of Health/Environmental Health
   Hazardous Waste Branch/Waste Minimization
   919 Ala Moana Boulevard #212
   Honolulu, HI 96814

   Ms. Marlin
   Telephone: 8085864226
   General Number: 8085864226
   Fax: 8085867509


   Division of Environmental Quality
   Air Toxics Regulatory Analyst
   1410 North Hilton
   Boise, ID 83706

   Mr. Tim Teater
   Telephone: (208)373-0457
   General Number: (208)373-0502
   Fax: (208)373-0417


   Illinois Environmental Protection Agency/Pollution Prevention Office
   Mercury Reduction Project for Hospitals
   1021 North Grand Avenue East
   Springfield, IL 62794-9276

   Mr. Kevin Greene
   Telephone: (217) 785-0833
   General Number: (217) 782-8700
   Fax: (217) 557-2125

                      MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN               C-5

 Indiana Department of Environmental Management
 Voluntary Compliance
 105 West Market Street, Suite 703
 Indianapolis, IN 46204

 Mr. Dave Wintz
 Telephone: (317)233-1194
 General Number: (800)988-7901
 Fax: (317)233-5627


 Iowa Department of Natural Resources
 Pollution Prevention and Business Assistance
 502 E. 9th Street, Wallace State Office Building
 Des Moines, IA 50319-0034

 Mr. Brian Tormey
 Telephone: (515) 281-8927
 General Number: (515) 281-4367
 Fax: Fax: (515) 281-8895


 Department of Health and Environment/Division of Environment
 Pollution Prevention
 Forbes Field, Bldg. 283
 Topeka, Kansas 66612

 Ms. Janet Neff
 Telephone: 7852960669
 General Number: (800) 357-6087
 Fax: (785) 291-3266



   Kentucky Pollution Prevention Center
   P2 For Healthcare Organizations
   420 Lutz Hall
   Louisville, Kentucky 40292

   Ms. Penny Williams
   Telephone: (502) 852-0965
   General Number: (502) 852-0965
   Fax: (502) 852-0964


   Kentucky Department of Environmental Protection
   Resource Conservation and Local Assistance
   14 Reilly Road
   Frankfort, KY 40601

   Ms. Melinda Meredith
   Telephone: (502) 564-6716
   General Number: (502) 564-6716


   Louisiana Department of Environmental Quality
   Small Business/Pollution Prevention
   P.O. Box 82135
   Baton Rouge, La. 70884-2135

   Mr. Patrick Devillier
   Telephone: 2257650912
   General Number: (225) 765-0219
   Fax: (225)765-0222

                      MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN              C-7


Maine Department of Environmental Protection/Bureau of Management Services
Pollution Prevention
Augusta, ME 04333
State House Station 17

Ms. Chris Rushton
Telephone: 2072877100
General Number: 2072877100
Fax: 2072872814


Maryland Department of the Environment
Waste Management Administration
2500 Broening Highway
Baltimore, MD 21224

Mr. Nick Kauffman
Telephone: (410) 631-4119
General Number: (800) 633-6101 x4119


Massachusetts Office of Technical Assistance
Pollution Prevention
100 Cambridge St. Rm 2109
Boston, MA 02202

Mr. Scott Fortier
Telephone: 6177273260
General Number: (617) 723-4920
Fax: 6176261095



   Massachusetts Executive Office of Environmental Protection
   Bureau of Waste Prevention
   One Winter Street, 7th Floor
   Boston, MA 02108

   Ms. Judy Shope
   Telephone: 6172925597
   General Number: 6172925849
   Fax: 6172925778


   Michigan Department of Environmental Quality
   Environmental Assistance Division
   PO Box 30473
   Lansing, MI 48909

   Ms. Marcia Horan
   Telephone: 5173739122
   General Number: 5173739122
   Fax: 5173354729


   Minnesota Pollution Control Agency
   Pollution Prevention
   520 Lafayette Rd.
   St. Paul, MN 55155-2100

   Mr. Ed Swain
   Telephone: (651) 296-7800
   General Number: (651) 296-7800



Minnesota Office of Environmental Assistance
Pollution Prevention
520 Lafayette Rd.
St. Paul, MN 55155-2100

Mr. John Gilkeson
Telephone: (651) 215-0199
General Number: (651) 215-0199


Mississippi Department of Environmental Quality
Waste Reduction/Waste Minimization Program
101 W. Capitol Street
Jackson, MS 39201

Mr. David Peacok
Telephone: 6019615220
General Number: 6019615171
Fax: 6019615742


Missouri Department of Natural Resources
Technical Assistance Program
P. O. Box 176
Jefferson City, MO 65102

Mr. David Goggins
Telephone: 5735266627
General Number: 8003614827
Fax: 5735265808


   Montana Department of Environmental Quality
   Pollution Prevention Bureau
   P.O. Box 200901
   Helena, MT 59620-0901


   New Hampshire Department of Environmental Services
   Pollution Prevention Coordinator
   6 Hazen Drive
   Concord, NH 03301-6509

   Ms. Sara Johnson
   Telephone: 6032716460
   General Number: (603)271-2900
   Fax: 6032712456


   New Jersey Technical Assistance Program for Industrial Pollution Prevention
   Office of Director
   138 Warren St.
   Newark, NJ 07102

   Mr. Mike Wallace
   Telephone: (973) 596-5844
   General Number: 9735965864
   Fax: (973) 596-6367


   City of Albuquerque Pollution Prevention
   Pollution Prevention Program
   4210 2nd Street SW
   Albuquerque, NM 87185

   Mr. Robert Hogrefe
   Telephone: 5058737030
   General Number: 5058737030
   Fax: 5058737087

                      MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN               C-11


New Mexico Environmental Department
Environmental Protection Division
P.O. Box 26110
Sante Fe, NM 87502

Ms. Patricia Gallagher
Telephone: 5058270677
General Number: 5058270677
Fax: 5058272836


New York State Department of Environmental Conservation
270 Michigan Avenue
Buffalo, NY 14203-2999

Mr. Thomas Corbett
Telephone: (518) 457-1859
General Number: 5184572553
Fax: 5184572570


New York State Department of Environmental Conservation
Pollution Prevention Unit
50 Wolf Rd.
Albany, NY 12233

Ms. Mary Werner
Telephone: (518) 457-7267
General Number: 5184572553
Fax: 5184572570


    Northern Carolina Department of Environmental Health & Natural Resources
    Division of Pollution Prevention and Environmental Assistance
    P.O. Box 29569
    Raleigh, NC 27626

    Mr. Gary Hunt
    Telephone: 9197156508
    General Number: 9197156500
    Fax: 9197156794


    North Dakota Department of Health/Division of Waste Management
    Pollution Prevention Coordinator
    P.O. Box 5520
    Bismarck, ND 58506-5520

    Mr. Robert J. Tubbs
    Telephone: (701)328-5166
    General Number: (701)328-5166
    Fax: (701)328-5200


    Ohio Environmental Protection Agency
    Pollution Prevention
    P.O. Box 1049
    Columbus, OH 43216-1049

    Ms. Ellen Miller
    Telephone: (614)644-2817
    General Number: (614)644-3469
    Fax: 6146442807

                      MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN             C-13


Oklahoma Department of Environmental Quality
Pollution Prevention Program
P.O. Box 1677
Oklahoma City, OK 73101-1677

Ms. Dianne Wilkins
Telephone: 4057029128
General Number: 4057021000
Fax: 4057029101


Oregon Department of Environmental Quality
Pollution Prevention Program
811 S.W. Sixth Avenue
Portland, Oregon, 97204

Ms. Maryann Fitzgerald
Telephone: 5032295946
General Number: 5032295263
Fax: 503


Department of Environmental Protection
Pollution Prevention Program
P.O. Box 2063
Harrisburg, PA 17105

Mr. Patrick McDonnell
Telephone: 7177830540
General Number: 7177830540
Fax: 7177878926


   Rhode Island Department Environmental Management
   Office of Technical and Customer Assistance
   235 Promenade Street
   Providence, RI 02908

   Mr. Richard Enander
   Telephone: 4012226822
   General Number: 4012226822
   Fax: 4012223810


   South Carolina Department of Health and Environmental Control
   2600 Bull St.
   Columbia, SC 29208

   Mr. Bob Burgess
   Telephone: (803) 898-3971
   General Number: (803) 898-3971


   South Dakota Department of Environment and Natural Resources
   Pollution Prevention
   Joe Foss Bldg., 523 East Capitol
   Pierre, SD 57501-3181

   Ms. Carrie Jacobson
   Telephone: 6057735623
   General Number: 6057734254
   Fax: 6057734068



 Tennessee Department of Environment/Division of Community Assistance
 Pollution Prevention
 401 Church Street, 21st Floor, L&C Tower
 Nashville, TN 37243

 Ms. Karen Grubbs
 Telephone: (615) 532-0463
 General Number: 8888918332


 Texas Natural Resources Conservation Commission
 Small Business Environmental Assistance/Pollution Prevention
 P.O. Box 13087, M/C 112
 Austin, TX 78711-3087

 Mr. Thomas Vinson
 Telephone: 5122393182
 General Number: 5122393182
 Fax: 5122393165


 Utah Department of Environmental Quality Solid and Hazardous Waste
 Pollution Prevention
 P.O. Box 144810
 Salt Lake City, Utah 84114-4810

 Ms. Sonja Wallace
 Telephone: 8015364400
 General Number: 8004580145
 Fax: 8015364401



   State of Vermont Agency of Natural Resources
   103 South Main St
   Waterbury, VT 05671

   Ms. Karen Busshart
   Telephone: 8022413455
   General Number: 8022413455
   Fax: 8022413273


   Virginia Department of Environmental Quality
   Office of Pollution Prevention
   PO Box 10009
   Richmond, VA 23240

   Ms. Sharon K. Baxter
   Telephone: 8046984344
   General Number: 8046984344
   Fax: 8046984277


   Washington Department of Ecology
   PO Box 47600
   Olympia, WA 98504

   Ms. Lynn Helbrecht
   Telephone: 3604076760
   General Number: 3604076760
   Fax: 3604076715



West Virginia Department of Environmental Protection
Office of Waste Reduction
HC 61 Box 384
Danese, WV 25831

Mr. Leroy Gilbert
Telephone: (304) 484-6269
General Number: (304) 484-6269
Fax: (304) 558-2780


Wisconsin Department of Natural Resources
Pollution Prevention
101 S. Webster St., PO Box 7921
Madison, WI 53707

Ms. Kim McCutcheon
Telephone: (608) 267-0876
General Number: (608) 267-0876
Fax: (608) 267-0496


Wyoming Department of Environmental Quality
Office of Outreach and Environmental Assistance/P2
Hersler Building, 4th Floor 122 West 25th Street
Cheyenne, WY 82002

Mr. Steve Roseberry
Telephone: (307)777-6105
General Number: (307)777-6106
Fax: (307)777-3610


                                              Appendix D
              Benefits of a Mercury Pollution Prevention Program in Your Hospital (Handouts)

     Addresses Human Health Concerns About Mercury in the Environment
     • Hospital medical equipment contains a much larger amount of mercury than home medical
        equipment, and thus presents a larger potential hazard. For example, while a home fever
        thermometer contains about 1.59 grams of mercury, a desk-mounted sphygmomanometer
        contains about 83.7 grams of mercury.
     • There are human health impacts due to eating mercury-contaminated fish and fish
        consumption advisories due to mercury
     • Worker and patient exposure to mercury from broken thermometers and other mercury-containing
        devices could be avoided by using mercury-free equipment
     • Health professionals practice preventive medicine for public health.

     Reduces Discharge of Mercury into the Environment
     • Discharge to the air from incineration, and deposition of the airborne mercury back to the ground or
     • Discharge of mercury in wastewater to sewage treatment plants, and from there to:
        • A waterway, or
        • The air if sludge is incinerated, or
        • The soil if sludge is land spread.

     Helps to Avoid the Need for Future Environmental Regulations
     • As a result of the Federal Great Lakes Water Quality Guidance (also referred to as the Great
        Lakes Initiative), several states have adopted stricter water quality standards for mercury .
     • The hospital may not be able to meet stricter state standards for discharge to the sewage
        treatment plant without action.
     • Implementing best management practices now can help to avoid the need for increased
        regulations in the future.

     Produces Hospital Operations Efficiencies
     • Mercury Pollution Prevention avoids:
        • Disruption of services due to spills
        • High disposal costs of mercury
        • Need to train staff for handling mercury
        • Costs of end-of-pipe treatment that may be needed to meet upcoming regulations
     • Mercury alternatives are becoming more readily available and in many cases are cheaper.

     Demonstrates Leadership
     • Your hospital is a leader in the local medical community.

     Examples of What Some Hospitals Are Doing
     • See tables

                     MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                       D-1
                                                                                       Mercury Pollution Prevention in Select Michigan Hospitals
                                                                                   (Table Compiled by the National Wildlife Federation, August 1995)

                                               Pollution Prevention Actions          Bronson, Butterworth, Henry Ford, Genesys,           Riverside, U. Michigan Corning Labs,
                                                                                    Kalamazoo Grand Rapids  Detroit      Flint             Trenton    Ann Arbor Grand Rapids

                                               Administrative directives -
                                               (Formal vs.Informal)                       F             F              F            F          I          I           F

                                               Clean drain traps/catch basins

                                               Educate staff

                                               Install energy efficient lighting

                                               Inventory mercury uses

                                               Mercury-free batteries

                                               Purchase new mercury-free
                                               sphygmomanometers                                                                                                    N/A

                                               Replace broken
                                               sphygmomanometers with                                                                                               N/A
                                               mercury-free units

                                               Replace mercury thermometers

                                               Separate wastes

                                               Substitute pathology lab


                                               Training on spill prevention
                                               and management
         Mercury Pollution Prevention Activities In Select North American Health Care Facilities
         (Table Compiled by Margy Peet, Monroe County Department of Health, Rochester, NY)

   Pollution Prevention Actions     Princeton       Facilities       Hospital for            s
                                                                                     St. Mary’      13
                                    Hospitals,   participating in   Sick Children,   Hospital,   Wisconsin
                                    Princeton          the             Toronto        Duluth     Hospitals
                                        NJ       MWRA/MASCO          Hospital &      Minnesota
                                                 Mercury Work         Centenary
                                                      Group         Health Centre

   Clean drain traps

   Waste piping power washing

   MOU with POTW (MWRA)
   to suspend sewer discharge
   compliance enforcement

   Inventory mercury uses/
   waste reduction assessment

   Prepared Facilities Loadings
   Report, Pretreatment Guidance
   Manual, Technology
   Identification Report and
   Mercury Management

   Database of mercury content
   of 8,000 products

   MOU with Government,
   adopt plans and timetables
   to reduce or eliminate mercury

   Alternatives Project

   Replaced mercury
   thermometers &

   Education materials
   for employees

   Work Group for support
   & problem solving

                          MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                D-3
                                                     Appendix E
                     Annual Assessment of the Hospital’ Mercury Pollution Prevention Program

 Use this form for your hospital’ baseline mercury assessment before you begin your mercury pollution prevention
 program. Space is provided to assess progress during four successive years.

                                                     Baseline     Year 1    Year 2       Year 3       Year 4
                                     Year assessed

 1. Are mercury thermometers still in use?
 In which departments?

 2. Number of mercury thermometers purchased

 3. Number of mercury thermometers sent
 home with patients

 4. Are mercury sphygmomanometers
 still in use? In which departments?

 5. Number of mercury sphygmomanometers

 6. Are mercury gastrointestinal tubes
 still in use?

 7. Number of mercury gastrointestinal tubes

 8. Is phase-out of mercury laboratory
 chemicals underway or completed?

 9. Is phase-out of mercury pharmaceutical
 products underway or completed?

 10. Is phase-out of mercury
 batteries underway or completed?

 11. Number of mercury batteries purchased

 12. Is phase-out of mercury in electrical
 equipment underway or completed?

 13. Quantity of mercury waste disposed
 as hazardous waste

 E-1            MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                              E-1

                                                      Baseline   Year 1   Year 2   Year 3   Year 4
                                      Year assessed

 14. Quantity of mercury waste recycled

 15. Costs for the recycling and/or
 disposal of mercury waste

 16. Number of mercury spills

 17. Estimated total quantity of
 mercury involved for all mercury spills

 18. Is documentation kept to track that all
 pertinent staff are educated about mercury
 spill prevention and management?

 19. Percentage of pertinent staff trained about
 mercury spill prevention and management

 20. Do all pertinent staff know where the
 mercury vacuum cleaners and/or
 mercury spill kits are located?

 21. Percentage of pertinent staff that know
 whom to call for clean-up of a mercury spill

 22. Percentage of maintenance staff that
 know the proper procedure for trap cleaning
 in areas where mercury is used

 23. Is training documentation kept for all staff
 educated about the health and environmental
 concerns of mercury?

 24. Percentage of staff that has been educated
  about the health and environmental
 concerns of mercury

 25. Is there a disclosure about mercury
 content for each of the products or chemicals
 used by the hospital?

 26. Percentage of disclosures that are on file
 (see above)

                           MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                        E-2

                                               Appendix F
                                     Wastewater Sampling and Analysis

Measurement of success is vital to determining the effectiveness of a pollution prevention program. In order to
measure success a point of reference needs to be established. This is called a baseline (or starting) point. One
of the ways a baseline can be measured is through wastewater monitoring. Be sure to consider all the wastewa-
ter lines leaving hospital property.

Both analytical concentration of mercury and the volumes of flow need to be measured. This data should be
combined to result in a mass loading of mercury to the sewage treatment facility or receiving stream. All sewage
treatment facilities measure discharges the same way. By measuring with the same units as these facilities,
apples-to-apples can be compared. Sewage treatment plants in the Great Lakes basin measure mercury in the
parts-per-trillion (ppt) range. But upstream, at the source of the mercury, parts-per-billion (ppb) testing may be
sensitive enough. See below for examples of calculations based on these two concentration ranges.

Mass loading calculation:

 Mercury in ppb x Flow in mgd* x 8.34** = Mass mercury loading in lbs/day

 Mercury in ppt x Flow in mgd* x 8.34** = Mass mercury loading in lbs/day

This mass loading calculation should be used to calculate your baseline point, to monitor progress, and to help
measure program success. This calculation should be done over a period of time. By repeating the flow and
analyses, a more accurate status can be determined. Contact a local wastewater testing laboratory to identify
options for sample collection and analysis. Clean sampling techniques, as defined by the U.S. Environmental
Protection Agency, may be required for very low detection limits. You can monitor your progress by collecting and
analyzing samples one to four times per year.

* mgd: million gallons per day
** 8.34 is a set of conversion factors consolidated to one number so that units will work out.
ppb is equivalent to micrograms per liter (µg/L).
ppt is equivalent to nanograms per liter (ng/L).

F-1            MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                   F-1

                                                     Appendix G
                                     Sample Letter Requesting Certificate of Analysis
                                           and Sample Certificate of Analysis
                     (Adapted from sample prepared by Western Lake Superior Sanitary District)

                                            University Memorial Medical Center

  January 2, 1997

  Mary Smith
  Director of Sales
  Mercury Laboratory Products
  40 Third Street
  Duluth, MN 55805

  Subject: Certificate of Analysis

  Dear Ms. Smith:

  As you are aware, mercury is ever increasingly becoming a concern as an environmental pollutant. Mercury released
  from air and water sources is transformed into methylmercury in lakes or rivers. The methylmercury bioaccumulates
  in the aquatic food chain making consumption of fish hazardous to those organisms high on the food chain. As a
  result, regulations on the discharge of mercury to the solid and wastewater stream are becoming increasingly strin-

  Because of this knowledge, and our concern for the environment, our institution has instituted a mercury reduction
  policy. This policy requires the elimination or minimization of mercury in all our purchases. Low level concentrations
  of mercury in products (less than 10,000 ppm or one percent) are not required to be listed on Material Safety Data
  Sheets. The contribution from the sum of these low concentration sources accounts for a large fraction of the mercury
  in the wastewater stream. In order for our purchasing department to be able to make an informed choice on mercury
  concentration within the products that it buys, we are requesting that all vendors supply us with a certificate of analysis
  and/or a notarized affidavit which describes product mercury concentration and the detection method used in the
  analysis. This information will be used along with other criteria in the selection process of our vendors.

  Please submit the aforementioned information on all products that you intend to supply our institution. Thank you for
  your understanding and assistance in this matter.


  Jane Doe

                         MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                 G-1

                                          Sample Certificate of Analysis
                    (Adapted from sample prepared by Western Lake Superior Sanitary District)

  Anderson’ Acids
  98 Molarity Drive
  Marathon, Ontario
  Customer : Acme Manufacturing, Inc.
  Attn: John Jefferson
  Fax : 1-800-555-5555

  Product Grade :      SULFURIC ACID 93%               Shipment Date : 09/03/96

  B/L Number : 00008650                                        Quantity (as is):       100.400

  Customer P/O No.: C125062


  Tank Car/Tank Truck No. :

  The analysis below is representative of the quality of product loaded into the above shipment.
  Parameter                                    Analysis                  Specification
  Strength (% H2S04)                           93.67                       93.19 Min
  Color (HU)                                     11                         40 MAX
  Iron (ppm Fe)                                   9                         50 MAX
  Sulfur Dioxide (ppm S02)                       10                         50 MAX
  Appearance (%T)                                100
  Oxides of Nitrogen (ppm NO3)                    1                         10 MAX
  POM (ml 0.02N KMnO4)                          1.00                       5.00 MAX
  Mercury (ppb)                                  60

  Detection method for mercury analysis _________________________________________________



                                              Appendix H
                                 Vendor Product Mercury-Content Disclosure

   Hospital name _______________________________________________________________________
   Name of Hospital Purchasing Agent ______________________________________________________
   Address ____________________________________________________________________________
   Telephone _______________________________________Fax _________________________________

   The above-named Hospital has the policy of minimizing the use of mercury in products
   purchased for the Hospital. Such products may include:

        Barometers                                     Lamps
        Batteries                                      Pharmaceutical products
        Cleansers and soaps                            Sphygmomanometers
        Electrical relays                              Switches
        Gastrointestinal tubes                         Thermometers
        Laboratory chemicals                           Thermostat probes
        Laboratory manometers                          Thermostats

   Vendor name ________________________________________________________________________
   Name of vendor’ agent _______________________________________________________________
   Address ____________________________________________________________________________
   Telephone _______________________________________Fax _________________________________

   The above-named vendor agrees to:

   • Assist _____________________________________ Hospital in obtaining manufacturers’disclosures
     about the mercury content of their products.

   • Assist _____________________________________ Hospital in selecting products that are virtually
     free of mercury content.

    _______________________________________________           _______________________________
               Signature of vendor’ agent                                   Date

                      MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                    H-1
Appendices                                           H-1

                                                 Appendix I
                     Educational Resources for a Mercury Pollution Prevention Program

  MWRA/MASCO Mercury Work Group                       Mercury Products Database, computerized listing
  Karen Rondeau                                       of 8,000 chemicals in Microsoft Access™ (free)
  617-241-2347                                        Facilities Loadings Subgroup Report (39 pages plus
                                                      appendices, free)
                                                      Mercury Management Guidebook (30 pages plus
                                                      appendices, free)
                                                      Pretreatment Guidance Manual (47 pages plus
                                                      appendices, free)
                                                      Technology Identification Subgroup Report (30
                                                      pages plus appendices, free)
                                                      (See also listing for the MASCO Internet site)

  Minnesota Office of Environmental Assistance        Video (inquire about availability)
  Emily Moore
  520 Lafayette Rd. N., 2nd Floor
  St. Paul, MN 55155-4100
  FAX 612-215-0246

  National Wildlife Federation                        Mercury Pollution Prevention in Healthcare: A
  Great Lakes Natural Resource Center                 Prescription for Success (42 pages, $6.00)
  506 E. Liberty, 2nd Floor
  Ann Arbor, MI 48104-2210

  Terrene Institute                                   The Case Against Mercury: Rx for Pollution
  4 Herbert Street                                    Prevention (one of two sources for ten-page
  Alexandria, VA 22305                                booklet and poster, free)
  FAX: 703-548-6299

I-1          MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                             J-1
  U.S. Environmental Protection Agency                The Case Against Mercury: Rx for Pollution
  Region V                                            Prevention (one of two sources for ten-page
  Michael Bland                                       booklet and poster, free)
  Attn: P-19J                                         General outreach materials (free)
  77 West Jackson Blvd.                               Video (inquire about availability)
  Chicago, IL 60604

  Western Lake Superior Sanitary District             MercAlert (pamphlet for consumers, free)
  Mercury Specialist                                  Blueprint for Mercury Elimination: Mercury
  2626 Courtland St.                                  Reduction Project Guidance for Wastewater
  Duluth, MN 55806-1894                               Treatment Plants (38-page book of interest
  218-722-3336, ext. 307                              beyond wastewater treatment plants, free)

  Internet Sites:

  (Massachusetts) Medical, Academic and Scientific Community Organization (MASCO)

  Massachusetts Water Resources Authority

  Michigan Department of Environmental Quality

  National Wildlife Federation

  U.S. Environmental Protection Agency

  Sustainable Hospitals Project

  For additional resources, see Chapter 5, Mercury Reduction Case Studies, Appendix C, National Listing of
  State Contacts and Appendix R, Bibliography.

                      MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                      I-2

                                 Appendix J

                                 Use Best Management
                                 Practices for Amalgam
                                 Handling and Recycling


                        John D. Doyle
                       County Executive

              Prepared by the Monroe County Department of Health, in cooperation with
         the University of Rochester’ Department of Dentistry and Eastman Dental Center and
                      the Monroe County Department of Environmental Services,
               with funding by a grant from the U.S. Environmental Protection Agency

                   MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                               J-2

                                                         This booklet has been developed to enlist your
                                                         help in a region-wide effort to manage amalgam
                                                         waste so as to protect the environment from
                                                         mercury. The amalgam management practices
                                                         described in this booklet were developed during
                                                         the past few years by dentists at the University
                                                         of Rochester’ Department of Dentistry and
                                                         Eastman Dental Center in Rochester, New York,
                                                         and by dentists in Minnesota, in cooperation
                                                         with the Western Lake Superior Sanitary District.
                                                         The methods have been shown to be effective in
                                                         keeping mercury from amalgam out of the
        Share this booklet with your staff. When new employees join your staff, make sure that they read
           this booklet also. You and your staff together can evaluate your current practices and, where
           appropriate, adopt new practices to protect the environment from the discharge of mercury
           from dental amalgam.

        There are many ways that mercury from dental amalgam can get into the environment:
        • Amalgam particles that are rinsed down drains or that escape poorly maintained chair-side
           traps and vacuum pump filters travel through the sewer system to the wastewater treatment
           plant. From there mercury from the amalgam may enter the environment in one of three
           ways: (1) It may be released directly to a waterway; (2) It may be released to the air if the
           treatment plant sludge is incinerated and then re-deposited to the ground or a waterway; (3) It
           may be released to soil if treatment plant sludge is land spread.
        • If a dental practice is connected to a septic system, amalgam particles become part of the
           sludge in the septic tank, which is eventually pumped out and transported to a wastewater
           treatment plant or land spread. Any mercury from the amalgam that becomes soluble will
           end up in groundwater.
        • Placing an item that contains amalgam particles in a red bag allows mercury from the amal-
           gam to be released into the air if the medical waste is incinerated. The volatilized mercury is
           then re-deposited to the ground or a waterway.
        • If items that contain amalgam particles are discarded with the ordinary trash, there is the
           potential for mercury from the amalgam to leach into groundwater when the trash is placed in
           a landfill not designed to handle hazardous waste.
        • In an older dental clinic, pure bulk mercury from past practices may have settled in sink traps.
           The mercury is gradually released into wastewater for many years after the use of bulk mer-
           cury has been discontinued.



     New federal regulations greatly reduce the amount of mercury that is allowed to be discharged
        from a municipal wastewater system or an incinerator. By implementing the best management
        practices described in this booklet, you can reduce the level of mercury in the environment and
        avoid the need for increased regulations in the years to come.

     Stock your amalgam materials in a good choice of capsule sizes, in order to better select the right
        amount of material for a particular restoration. This will minimize waste.

     Dental scrap amalgam should be collected and stored in two designated, tightly closed, widemouth
        plastic containers. One container should be labeled CONTACT AMALGAM (amalgam that has
        been in the patient’ mouth). The other should be labeled NONCONTACT AMALGAM. Neither
        the New York State Department of Health nor the Occupational Safety and Health Administra-
        tion (OSHA) requires that contact amalgam be discarded in a medical waste red bag.

     Most recyclers prefer that contact amalgam be transported for recycling in a disinfectant. The
        liquid is visual evidence that the contact amalgam has been disinfected. Noncontact amalgam
        in a tightly sealed container can be stored and transported dry.

     Collect and store the entire contents of broken or unusable capsules with your noncontact scrap
         amalgam. If empty dental amalgam capsules contain no visible amalgam materials, they may
         be placed in the trash.

     If there is a spill of mercury from a capsule, contain it and clean it up immediately. Keep mercury
          clean-up materials on hand, and train a staff member in proper spill clean-up. Inexpensive
          mercury clean-up materials are available from science and safety equipment suppliers. (Some
          suppliers are listed on page 8.)

     When the fine particles of amalgam come in contact with cleaning agents and chemicals in the
        suction system and sewers, the mercury may be released. Large particles of amalgam can be
        prevented from entering the sewer system by the use of chair-side traps and vacuum pump
        filters. Material captured in the traps and filters can be sent to a recycler. Calculations based
        on data in scientific literature indicate that, when used properly, chair-side traps and vacuum
        pump filters can capture about 70% of the amalgam that enters the vacuum system.


                      MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                          J-4

         Never rinse scrap amalgam down the drain.
         Never place scrap amalgam in the medical waste red bag.
         Never place scrap amalgam in the trash.

       Recommended techniques for collecting amalgam from the chair-side traps are as follows:

       1. Change or clean chair-side amalgam traps often. The frequency may vary from daily to weekly
          depending on how often the chair is used for amalgam placement or removal and the effective-
          ness of the suction.

       2. Flush the vacuum system with disinfecting line solution before changing the
          chair-side trap. The best method is to flush the line at the end of the day,
          and then change the trap the first thing the next morning.

       3. Use universal precautions (gloves, glasses and mask) when handling the
          chair-side trap. Choose utility gloves intended for cleaning and handling
          wastes for this procedure.

       4. Do not place gloves, plastic bags or paper towels into the recycling con-
          tainer. These add to the volume of the waste created and cause problems
          in the recycling equipment.

       5. Remove all visible amalgam by tapping the contents into the container labeled CONTACT
          AMALGAM. Close the cover tightly. If the trap is visually clean, it can be put in the trash. These
          visually clean traps have been determined to be nonhazardous.* (A heavily contaminated trap
          should always be recycled. It should be placed in the contact amalgam container.)

       Vacuum pump filters are usually located upstream of the central vacuum pump. Recommended
          techniques for recycling the vacuum pump filters are as follows:

       1. Replace or dispose of these filters regularly as recommended by the
          equipment manufacturer.

       2. Use universal precautions.

       3. Remove the filter and decant, over a tray, as much liquid as possible
          without losing visible amalgam.

       4. Put the lid on the filter and place the filter in the box in which it was
          originally shipped. When the box is full, the filters should be recycled.

       *Shown by the Toxicity Characteristic Leaching Procedure (TCLP) to be acceptable for landfilling.



    After your office adopts its new amalgam management practices, it may be a good time to replace
        sink traps. Mercury from past practices often settles at low points such as sink traps and
        sumps. The slow dissolution of the mercury in a sink trap or sump can release mercury into the
        wastewater for years after past disposal practices have been corrected. Whenever plumbing
        parts are moved or cleaned, caution should be taken to avoid spilling the contents in case
        amalgam or mercury are present. Pour and brush out the sludge and handle it as you would
        handle contact amalgam. The plumbing parts can be put back in place or discarded in the

    If you have an older dental office, alert renovators to the possibility of mercury contamination in
         carpets, in floor cracks, behind moldings and other areas where bulk mercury may have been
         used, or where amalgam capsules may have been spilled. Call your county health department,
         district office of the New York State Department of Health, or regional office of the New York
         State Department of Environmental Conservation if you have questions about disposal of
         renovation debris. (See page 7 for telephone numbers.)

    Systems are available to treat wastewater contaminated with amalgam particles that are too fine to
        be caught in traps or filters. Most systems employ centrifugation or enhance sedimentation of
        particles. Some can also capture mercury that is in solution. Some of the new equipment can
        remove more than 99% of the mercury in the wastewater. It is used in some European coun-
        tries, where removal rates of at least 95% are required. The systems are being evaluated in
        dental offices in the U.S. Equipment can be purchased or leased. These systems are expensive
        now, but may become cheaper in the future. Contact 716-292-3935 for further information.

    In 1994 the American Dental Association recommended that dentists eliminate the use of bulk
        dental mercury by switching to precapsulated amalgam alloy in their practices. Measurement of
        the ratio of liquid mercury to amalgam powder is much more exact with the precapsulated
        technique. There is also less possibility of leakage during trituration. The use of precapsulated
        amalgam alloy eliminates mercury dispensers and containers as sources of mercury vapor, and
        eliminates the possibility of spilling a large quantity of mercury.
    Recycle bulk mercury. If there is a spill of a large amount of bulk mercury before it is eliminated
        from your office, call your county health department or district office of the New York State
        Department of Health for instructions about cleaning it up. (See page 7 for telephone numbers.)


                      MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                          J-6

       There are four options for recycling the amalgam from your dental office.

       1. Amalgam containers only: Mail via U.S. Mail to the Monroe County Household Hazardous Waste
          Facility in Rochester. It has authorization to collect noncontact amalgam and contact amalgam
          by mail from other counties, as well as from Monroe County. Make arrangements with the
          Monroe County Household Hazardous Waste Facility at 716-760-7600 to receive detailed
          instructions for amalgam recycling. Packaging materials will be provided for your office as long
          as supplies last.

       2. Amalgam containers, vacuum pump filters and bulk mercury: Deliver directly to the Monroe
          County Household Hazardous Waste Facility in Rochester. Materials can be dropped off
          without an appointment in the Industrial Waste Office foyer of Building 15 at 444 East
          Henrietta Road, in Rochester. The foyer is open between 7:00 a.m. and 4:30 p.m. Monday
          through Friday. The Facility has authorization to accept deliveries of these materials from other
          counties, as well as from Monroe County. Call 716-760-7600 for directions to the Facility and
          other information.

       3. Amalgam containers and vacuum pump filters: Ask your infectious or hazardous waste hauler if
          delivery of amalgam containers and vacuum pump filters to a mercury recycler or the Monroe
          County Household Hazardous Waste Facility can be arranged.

       4. Amalgam containers, vacuum pump filters and bulk mercury: Work directly with an amalgam
          recycling company. There are many questions you will need to ask when choosing a recycler:
          • What can I recycle?
               • Contact amalgam
               • Noncontact amalgam
               • Chair-side traps
               • Vacuum pump filters
               • Bulk mercury
          • What are the costs or profits
              for recycling each of the
          • What are the instructions for
              disinfection of contact
          • What are the packaging
              requirements for contact
              amalgam, noncontact amal-
              gam chair-side traps, vacuum
              pump filters and bulk mercury?                   (See page 6 for a partial list of recyclers.)



     Advanced Environmental Recycling Co.     Global Recycling Technologies, Inc.
     2591 Mitchell Ave.                       218 Canton St.
     Allentown, PA 18103                      Stoughton, MA 02072
     800-554-AERC                             781-341-6080

     Amalgaway Mail Disposal Service          Maquire & Strickland Refining Co.
     1002 West Troy Ave.                      1290 81st Ave. NE
     Indianapolis, IN 46225                   Minneapolis, MN 55432
     800-267-1467                             612-786-2858

     Bethlehem Resource Recovery Division     Mercury Refining Company, Inc.
     890 Front St.                            1218 Central Ave.
     P Box Y                                  Albany, NY 12205
     Hellertown, PA 18055                     800-833-3505
                                              Mercury Waste Solutions, Inc.
     Dental Recycling North America, Inc.     21211 Durand Ave.
     P Box 1069                               Union Grove, WI 53182
     Hackensack, NJ 07601                     414-878-2599
                                              RECYCLIGHTS, Inc.
     DFG Mercury Corp.                        401 West 86th St.
     909 Pitner Ave.                          Minneapolis, MN 55420
     Evanston, IL 60202                       800-831-2852
                                              Safety Kleen
     Dorell Refinery                           .O.
                                              P Box 97
     533 Atlantic Ave.                        Avon, NY 14414
     Freeport, NY 11520                       716-226-2411

     Everlights                             Note: The above list does not imply an endorse-
     8500 West 191st Street, Suite 1           ment of any company. Each user is respon-
     Mokena, IL 60448                          sible for verifying vendor information. The
     815-469-0631                              list is not intended to be all-inclusive, but is
                                               provided for informational purposes only.
     Garfield Refining
     810 East Cayuga
     Philadelphia, PA 19124-3892
     800-523-0968 ext. 300


                     MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                 J-8

        Bel-Art Products                                     Thomas Scientific
        Pequannock, NJ 07440-1992                            99 High Hill Road @ I-295
        201-694-0500                                          .O.
                                                             P Box 99
                                                             Swedesboro, NJ 08085
        Fisher Scientific                                    800-345-2100
        52 Fadem Road
        Springfield, NJ 07081                                VWR Scientific Products
        800-766-7000                                         5 Marway Circle
                                                             Rochester, NY 14624
        Lab Safety Supply, Inc.                              716-247-0613
        P Box 1368
         .O.                                                 800-932-5000
        Janesville, WI 53547-1368

      Note: The provision of these names does not imply an endorsement, nor is it intended to be all-
         inclusive. Each user is responsible for verifying vendor information. The list is provided for
         informational purposes only.

        See Appendix C






Advanced Environmental Recycling Corp.                                215-797-7608
Allentown, PA

Dental Recycling North America, Inc.                                     800-525-37

D. F. Goldsmith Chemical and Metal Corp.                             847-869-7800
Evanston, IL
DorellRefinery                                                       800-645-2794
Freeport, NY

Envirochem                                                            612-428-4002
Rogers, MN
Everlights                                                         815-469-0631
M      ,
 okena IL
Garfield Refining                                            800-523-0968 ext. 300
Philadelphia, PA
Light Cycle                                                        651-641-1309
St. Paul, MN

M ercury Refining Co.                                              800-833-3505
Albany, NY
Superior Lamp Recycling                                            800-556-5267
Port Washington, WI
US Technologies (Mercury Waste Solutions)                           414-878-2599
Union Grove, WI


                                            Appendix K
                                       Mercury Waste Recyclers
    The U.S. mercury waste recyclers listed below are full service recyclers. In general, they will
    accept the full range of mercury waste from a hospital: thermometers, gastrointestinal tubes,
    laboratory chemicals, batteries, lamps, relays, switches, thermostats, manometers, metallic
    mercury, and mercury-contaminated material. They also accept dental amalgam from hospitals
    that have a dental clinic. See the following pages for a list of fluorescent lamp recyclers.

    Specific services vary from company to company. Each user is responsible for verifying vendor
    information. The list below does not imply an endorsement of any company, and it is not
    intended to be all-inclusive, but is provided for informational purposes only. In addition to
    contacting the companies listed, you can ask your current hazardous waste hauler to put you in
    contact with a mercury recycler.

    The following lists of recylers have been verified as of July 1999. These lists will be
    updated periodically.

                       MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                   K-1

                   (FREE FLOWING) MERCURY:
      COMPANY NAME               PROCESS USED                       SPECIAL CONDITIONS
 Gary Pyburn, Owner         Retort and Distillation             Hg must be clean, free flowing.
 Mercury Distributors                                           This company does not recover Hg
 Houston, TX                                                    from soil or debris. This company
 713/433-2418                                                   does not pay for Mercury.
                                                                NOTE: MAKE
                                                                ARRANGEMENTS BY PHONE
                                                                BEFORE SENDING ANY
 Bob Ames, Customer Serv.   Retort                              Charge customer $50 for Hg kit to
 Mercury Refining Co.       Distillation                        package & ship up to 150 pounds.
 Albany, NY                 Filtering                           Over 150 pounds, company will
 800-833-3505                                                   pay $.15/lb, but customer must pay
 518-459-0820                                                   freight. NOTE: MAKE
                                                                ARRANGEMENTS BY PHONE
                                                                BEFORE SENDING ANY
 Bruce Lawrence, Owner      Retort & Distillation               Charge customer $76 for Hg flask
 Bethlehem Apparatus                                            and shipping kit that holds 76
 Hellertown, PA             NOTE: In 1994 US                    pounds. UPS will ship liquid Hg
 610-838-7043               Government stopped selling Hg
                            into market. Mr. Lawrence sees
                                                                as co-product. Contaminated Hg
                            the price going him for   is considered Haz Waste. Over
                            current status.                     200 pounds, company will pay
                                                                $.50/lb, but customer must pay
                                                                NOTE: MAKE
                                                                ARRANGEMENTS BY PHONE
                                                                BEFORE SENDING ANY
 Mr. Goldsmith, Owner       Distillation & Retort               Accepts no less than 25 pounds.
 Mr. Jim Moran, V.P.                                            UPS shipping kit costs $65.00,
 D.F. Goldsmith Chemical                                        customer must pay freight. More
 & Metal Corporation                                            than 100 pounds (7-8 gallons),
 Evanston, IL (Chicago)                                         Goldsmith will pay $.50/lb, but
 847-869-7800                                                   customer must pay freight &
                                                                packaging. NOTE: MAKE
                                                                ARRANGEMENTS BY PHONE
                                                                BEFORE SENDING ANY


                  (FREE FLOWING) MERCURY:
Jim Cornwell,               2 Machines - 1) Retort     Flow meters, thermometers all
Sales Manager               (stationary 25 bbls/ day   types of mercury debris. Must
US Technologies             for D009 Waste codes)      have waste profile, analytical
(Mercury Waste Solutions)   and 2) 30 drum/day         information, shipping documents.
Union Grove, Wisconsin      Continuous Flow system     Use independent hazardous waste
414-878-2599                (designed for soils and    transporters. Will charge $.50/lb
                            solids)                    to take elemental mercury.
Sandra Smith/Jane Buzzard   Retort followed by         Charge $5-$10 per pound to accept
Advanced Environmental      Triple Distillation        elemental Hg. Do not pay for
Recycling Corporation                                  product. Company requires
Allentown, PA                                          shipment on hazardous waste
215-797-7608                                           manifest with hazardous waste
                                                       transporter. Will make
                                                       arrangements to ship for large
                                                       NOTE: MAKE
                                                       ARRANGEMENTS BY PHONE
                                                       BEFORE SENDING ANY

                  MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                    K-3

       COMPANY NAME                      PR O CESS USED                       S P EC IAL
                                                                           COND ITIO N S
Mike Chintis 602-495-1833      Com p any has one Mercury                   Call for details.
Drew Hunter 801-322-7022       Reco very unit to process soil and          Recovery pro c ess
Hunter Refining Company        reco ver elemental H g.                     fo r la rge c leanups.
Salt Lake City, UT

Mr. MikeRockandel              Deve loped treatm e n t technolo g y to This com pany does
Unive r sal Dynamics           rem o ve m e rcury from c o ntam ina te d not treat waste. Mr.
Vancou ver, Canada 4V3
                   V6J 4V3     was te (5%-10% Mercury).                  Rockandelis a
(604 )-736-3381 - Canada                                                 consultan t th a t
                                                                         developed Hg
                                                                         waste tre a tm e nt
                                                                         te chnolo g y being
                                                                         used on two
                                                                         superfund sites in
                                                                         th e U S in 1994.
Mr. R ic h ard Harrison        Acid Leaching w / Precip itation            Call for details on
CyanoKem                       Trea t Me rcury Sa lts and Solids via       trea tment
Detroit, M I                   o xid a tion, stabiliza tio n and           te chnolo g y.
313-933-1850                   landfilling .

Thom a s W a yland, Ph.D .     A m o bile re torting facility using a 2    Call for details.
Mercury Re c o very Services   S tage batch p rocess. Capacity             P ro c ess was bein g
AKA /Pittsburgh M ineral &     1000 lbs/hour (2 4 hr operation).           used to recover Hg
Env ironmenta l Technology     Second s tage takes process to              a t con tam ina ted
New B r ighton, PA             1000-1200F.                                 fa cility w hen inquire
412-843-5000                                                               was m a de.

Mr. Brian Horne                The rm a l Dis tilla tion - Heat solid &    Large remedia l
Seaview Thermal System s       liquid wa s te in c re m entally to 2000F   pro je c ts on site
Blue b e ll, PA                in N atm osphere . Coo l to re c o ver      only. No fixe d
(215 ) 654-9800                con tam inant.                              reco very facility to
                                                                           process waste .
                                                                           Call for more
Bill Frista d Proje c t Mgr.   TerraMet Technology - Soil                  Mobil technolo g y.
CognisIncorporated             W a s hing /Leaching technology for         Large remedia l
Santa R o sa, California       reco very of heavy metals from soil.        pro je c ts on ly. No t
(707 ) 576-6200                                                            appropriate for a 2
                                                                           ya rd job.
                                                                           Mobiliza tion cost of
                                                                           $100,000 (est.).
Mr. B o bG a llegher           S tationary retort (H eating) facility Call to inquire.
NSSI                           that processes Hg waste on-site in a
Hous ton, Texas                va c uum c ham b er condensing out
(713 )641-0391                 the Hg. Air strea m goes to carbon
                               filtra tion syste m .


Mercury Waste Solutions                   Hg recovery for: Fluorescent, HID lamps, metal
Indianapolis, IN      888-988-4050        switches, mercury batteries, thermostats,
Roseville, MN         612-628-9370        thermometers, mercury relays, etc.
Union Grove, W I      800-741-3343
Keith Thorndyke           800-831-2852    F luorescent and HID recycling, P C B, D E H P &
Recyclights                               non PCB/DEHS ballast recycling , battery
M inneapolis, MN, Lakeland, FL            recycling, electronic recyc ling
Tallahassee, F lor ida, Columbus, OH
web site : http://www.recyc
M e rcury Technologies/Advanced
Environme ntal Recycling
Hayword, CA            800-628-3675
Alle ntown, PA,        800-628-3675
W. Melbourne, FL         800-808-4684

                    MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                        K-5

L A M P S /B A L L A S T S :
E n v ir o n m e n t a l L a m p e c yc l e rs
                               R                                                                 t
                                                                   C r u s h f l u o r e s c e n l a m p s, r e c o v e r
F t . W o r th , T e x a s            817-924-9300                 r e c y c la b l e s , s e n d p h o s p h o r a n d
                                                                   M e r c u r y P o w d e r to r e t o r t f a c i li t y .
                                                                   A l s o r e c y c le n o n - P C B b a l la s t s
                                                                   a n d c o l le c t a n d s h i p P C B b a l la s t s
                                                                   a n d b a t t e ri e s o ff- s i t e .
G re e n li g h t s L a m p R e c y c le r s    5 17 -67 6-00 44   F l u o r e s c e n t B u l bre c y c l e r s, H I D ,
M a s o n , M ichiga n                                             m e t a l h a li d e , m e rc u r y v a p o r ,
e - m a i l : g r i -m @ ti r . c o m                              r e c l a i m a l l p a r t s o f la m p .
B o b G a l le g h e r                     71 3-64 1-0 39 1        T a k e s l a m p s, e l e m e n t a l m e r c u r y
NSSI                                                               a n d b a ll a s t s f o r r e c y c l in g .
H o u s ton, T e xa s
B e th le h e m A p p a ra t u s C o ., 6 1 0 - 8 3 8 7 0 3 4      T a ke s l a m p s , e l e c tro n i c d e vic e s ,
H e l l e r to w n P A                                             b a tte r ie s , a m a lg a m s f o r r e c y c li n g

M e rc u r y W a s t e S o l u tio n s , I n c .                                                  r
                                                                   L a m p a n d b a l la s t e c y c le r. T u b e s :
80 0 - 6 9 9 2 8 9 5                                               p re f e r o r i g i n a l c o n ta i n e r s , c a n
M a ri e tta , G A                                                 p ro v i d e p a c k a g i n g . A l s o a c c e p t
( h a s o th e r l o c a tio n in In d i a n a p o l is , I N )    c r u s h e d la m p s. B a l l a s t s : D O T
                                                                   a p p ro v e d c o n t a i n e rs . A l s o
                                                                   a c c e p ts m e r c u r y c o n t a i n i n g
                                                                   d e v ic e s s u c h a s t h e r m o s ta ts ,
                                                                   t h e r m o m e t e r s , m e r c u r y r e la y
                                                                   s w i t c h e s , d e n t a l a m a lg a m ,
                                                                   b a tte r ie s , C R T s c r e e n s , e tc . .

C a r o li n a E n v i ro n m e n t a l A s s o c .                                             r
                                                                   L a m p a n d b a l la s t e c y c le r.
800-848 2324                                                       A c c e p ts in ta c t a n d c r u s h e d b u l b s .
B u r li n g to n , N C                                            F u ll s e r v i c e i s a v a i l a b le . N o
                                                                   m in im u m q u a n ti t y .

E a s t e r n E n v ir o n m e n t a l                                                           r
                                                                   L a m p a n d b a l la s t e c y c le r.
 8 0 0 - 8 0 8 -7 2 2 7                                            A c c e p ts in ta c t a n d b r o k e n t u b e s .
P o rt C h e s te r , N Y                                          F u ll s e r v i c e ; m i n im u m q u a n t i t y :
                                                                   b a l la s ts = 1 d ru m , n o n e f o r t u b e s .
                                                                   A l s o a c c e p t s b a tte r i e s ,
                                                                   t r a n s fo rm e rs , th e r m o m e t e r s , a n d
                                                                   s w itc h e s .

E c o fl o I n c .  8 0 0 -9 9 9 6 5 1 0                                                        r
                                                                   L a m p a n d b a l la s t e c y c le r. T u b e s :
G re e n s b o ro , N C                                            i n ta c t o n l y in o r i g i n a l p a c k a g i n g o r
                                                                   b o x p r o v i d e d o n r e q u e s t; b a ll a s ts
                                                                   in d rum s .

E n v i r o c y c le             8 0 0 -3 3 7 2 4 2 0                                            r
                                                                   L a m p a n d b a l la s t e c y c le r. T a k e s
H i g h P o i n t, N C                                             i n ta c t a n d c r u s h e d tu b e s i n
                                                                   o ri g in a l c o n t a i n e r s . W i l l p r o v i d e
                                                                   fib e r d r u m for u s e o r p u r c h a s e .

A d va n c e d E n v i r o n m e n tal         80 0-84 3 36 04                              r
                                                                   L a m p a n d b a l la s t e c y c le r.
T e c h n ic a l S e r v i c e s
M e n o m o n i e F a l ls , W I


  LAM P S/ B A L L A S T S :
  F u l C i r cle Ba llas t R e c yc lers                                   T a ke s b a llas ts to be rec y c l e d .
  800-775-1516                                                              P re-drum m e d in 1 7 H o r 1 7 C
  C a m b ri d g e , M A                                                    d ru m s . M inim u m c h a r g e = 1 d r u m .
  (has oth e r l o c a tio n s i n A tl a n ta , B o s to n , Ch ic a g o ,
  D e troit, H ous to n , Ne w Y o r k , P hilad e l p h ia , a n d
  S a n F ra n c i s c o , H on olulu)

  A m e ri- w a s te E n vironm e nta l                                  B rok e r a g e f o r r e m ed ia tion . L a m p
  800-343 2179                                                                         .
                                                                         rec y c le rs Drum s o r pa lle ts up to
  Technology Services                                                    3 ft. H igh (in o r i g i n a l
                                                                         p a c k a g in g);c r u s h ed or in tac t
                                                                         b ulbs .

  S . D. M e ye rs               800-44 4 9580                                                 .
                                                                         B allas t r e c ycler Ta k e s d ru m s if
  T a l lm idg e OH                                                      lea k in g o r c o r r u g a te d bo xes if no t
                                                                         lea k in g.

  S a le s c o S ys tem s             800-368 8 878                                                  t
                                                                         L a m p a n d b a l la s r e c y c le r  .
  Bra in tree M A                                                        B allas ts 5 5 g a l d ru m s , bu lb s in
  (oth er loc a tio n s P h oe nix, A Z 8 0 0-36 8 - 9 0 4 5             o ri g in a l b o x e s o r p r o v i d e d
  S a n D ie g o , C A 619 -22 2-58 08                                   c o n ta in e r s .
  C h i c a g o , IL 7 0 8 - 2 5 9 - 8 3 1 1

  Allie d T e c h n o l o g y G r o u p     510-490 8686                                    .
                                                                         L a m p r e c yc ler Als o r e c y c l e s P C B
  F r e m on t, C A                                                      & N o n-P C B b alla s ts .

  Aptus E n viron m en tal S e r v i c e s                                                                 r        .
                                                                         L a m p , b a l l a s t a n d b ulbe c ycler
   61 2-4 6 9 3 4 7 5                                                                            D
                                                                         N o t e : T h is is a R O P - O F F
  Lakeville, MN                                                          c e n t e r w h ic h is o n ly o p e n at
                                                                         C E R T A IN T IM E S . P l e a s e c a l l
                                                                         fir s t .

  A-T E C R e c y c ling , In c . 8 0 0 - 5 5 1 4 9 1 2                  R e c y c l e slam p s, ba l lasts a n d
  D e s M o n ie s , IA                                                  fluo res c e n t b u l b s .

  E c o ligh ts N o rthw e s t        20 6-34 3 1 2 4 7                  R e c y c l e slam p s, fluo res c en t b ulbs
  Seattle, W A                                                           a n d b a llas ts .

  G le n n H u n te r                                                    L a m p r e c yc ler
  C h i c a g o E d is o n C orp .
  1 1 7 1 C o m e t Dr.
  A u r o r a , IL 6 0 5 0 5

  A m e ri c a n R e c yclin g C o L T D
  P .O. Box #27486                                                       F lou res c e n tlam ps a n d b a l la s ts
  C l e velan d , O H 4 4 1 2 7 - 0 4 8 6
  P h o n e : ( 2 1 6 ) 34 1-4 1 4 1
  F a x: ( 2 1 6 ) 3 4 1 -45 51

                           MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                K-7

 FulCircle B a l las t R e c yclers                                             T a ke s b a llas ts to b e r e c y c l e d .
 800-775-1516                                                                   P re-drum m e d in 1 7 H o r 1 7 C
 Cam b ri d g e , M A                                                           d ru m s . M i nim u m c h a r g e = 1 d r u m .
 (has oth e r l o c a t io n s i n A t l a n t a , B o s t o n , C h ic a g o ,
 D e troit, H ous to n , Ne w Y o r k , Philad e l p h ia , a n d
 S a n F ra n c i s c o , H on olulu)

 A m e ri- was te E n vironm e nta l                                        B rokera g e fo r rem e d ia tion . L a m p
 800-343 2179                                                                             .
                                                                            rec y c le rs Drum s o r pa lle ts up to
 Techn o l o g y S e r vi c e s                                             3 ft. H i g h (in origina l
                                                                            p a c k a g in g ) ; c r u s h e d o r i n t a c t

 S . D. M e ye rs              800-444 9 5 8 0                                                    .
                                                                            Ballast r e c ycler Ta k es d ru m s i f
 Tallm idg e OH                                                             lea k in g o r c o r r u g a t e d b o x e s if n o t
                                                                            lea k in g .

 S a le s c o S ys tem s            800-368 8 8 7 8                                                     t
                                                                            L a m p a n d b a l la s rec y c le r    .
 Bra in tree M A                                                            Ballasts 5 5 g a l d ru m s , bu lb s in
 (oth e r l o c a t io n s P h o e n i x , AZ 80 0 - 3 6 8 - 9 0 4 5        o ri g in a l b o x e s o r p r o v i d e d
 S a n D ie g o , C A 619 -22 2 - 5 8 0 8                                   con ta in e r s .
 Chic a g o , IL 7 0 8 - 2 5 9 - 8 3 1 1

 Allie d Te c h n o l o g y G r o u p       510-490 8686                                      .
                                                                            L a m p r e c ycler Also re c ycles P C B
 Frem ont, C A                                                              & N o n-P C B b alla s ts.

 Aptus Environm ental Services                                                                            r
                                                                            Lamp, ballast and b u l be c ycler     .
  612-469 3475                                                                                   D
                                                                            N o t e : T h is is a R O P - O F F
 Lakeville, MN                                                              c e n t e r w h ic h is o n ly o p e n at
                                                                            C E R T A IN T IM ES. Please call

 A-T E C R e c y c ling , In c . 8 0 0 - 5 5 1 4 9 1 2                      R e c ycleslam p s, ba llas ts a n d
 Des M o n ie s , IA                                                        fluo res c en t b u l b s .

 Eco ligh ts N o r thw est            206-343 1247                          R e c ycleslam p s, fluo res c ent bulbs
 Seattle, W A                                                               a n d b a llas ts .

 G le n n H u n te r                                                        L a m p r e c ycler
 Chic a g o E d is o n C orp .
 1 1 7 1 C o m e t Dr.
 Aurora, IL 60505

 A m e rican R e c yclin g C o LTD .,
 P .O. Box #27486                                                           Flou res c e n tlam ps a n d b a l la s ts
 C l e velan d , O H 4 4 1 2 7 - 0 4 8 6
 Phone: (216) 3 4 1 - 4 1 4 1
 F a x: (216) 341 -45 5 1


    D l u b a k’ G l a s s C o.
    1 6 0 0 S a xo n b u r g R o a d                           G l a s s m ate r ia ls in clu d i n g
    N a tr o n a H e i g h ts , P A 1 5 0 6 5                  fl u o r e s c e n t a n d i n c a n d e s c e n t
    P h o n e : (412 ) 22 4 - 6 6 1 1                                               s
                                                               l a m p s, C R T ’ h a lo g e n     lam p s, a n d
                                                               w ind s hield g l a s s .

    E n vi r o n m e n talM g m t S o l u t io n s , In c .,
    P .O . B o x 63 6 4                                        F l u o r e s c e n tl a m p s
    H igh Point, N C 272 62
    P h o n e : (612 ) 62 8 - 9 3 7 0

    L a m p R e c y c l e r s In c .
    7 1 2 P a c k e rl a n d D r i ve
    P .O . B o x 12 0 2 7                                      F l u o r e s c e n tl a m p s.
    G re e n B a y, W I 5 4 3 0 7 - 2 0 2 7
    P h o n e : (800 ) 55 8 - 1 1 6 6

    L i g h ting R e s o u r c e s , In c .
    1 5 2 2 E . V i c to r y S t r e et, # 2
    Phoenix, AZ 85040                                          F l u o r e s c e n tl a m p s a n d b a l la s ts
    P h o n e : (602 ) 27 6 - 4 2 7 8 o r
    (800 ) 64 1-9 2 5 3
    F a x: (6 0 2 ) 2 7 6 - 5 4 3 2

    L u m i n a ir e R e c y c l in g , In c .
    2 1 6 1 u n i vers ity A ve S te 2 0 6                     F l u o r e s c e n tl a m p s a n d b a l la s ts ,
    S t. P a u l , M N 5 5 1 0 4                               m e r c u r y s w itc h e s , b a tte r ie s
    P h o n e : (612 ) 64 9 - 0 0 7 9                          (In c lu d e N i - C d ) , an d va r i o u s
                                                               m e r c u r y - c o n t a i n i n g c h e m ic a ls .

    R e c y c le T e ch n o lo g i e s , In c .,
    1 4 8 0 N o r th S p r i n g d a le R d .                  F l u o r e s c e n tl a m p s a n d b a l la s ts
    W a u k e s h a, W I 53 1 8 6
    P h o n e : 41 4 - 7 9 8 - 3 0 5 0

    U S A L i g h ts
    2 0 0 7 C o u n ty R o a d C - 2                           F l u o r e s c e n tl a m p s
    R o s e vi l le , M N 5 5 1 1 3
    P h o n e : (612 ) 62 8 - 9 3 7 0

    M e rc u ry R e c o ve ry S e rvic e s
    8 1 3 T o w n e C e n te r D r i ve                                                        la
                                                               F l u o r e s c e n t a n d H ID m p s
    P a m o n a, C A 1 9 7 6 7
    P h o n e : (800 ) 61 6 - 7 7 7 5
    F a x: (9 0 9 ) 6 2 5 - 4 5 4 2

    A L R - A m e r ic a n L a m p R e c y c li n g , C
    2 2 s tag e D o o r R o a d                                F l u o r e s c e n tl a m p s
    F is h k il , N Y 1 2 5 2 4
    P h o n e : (800 ) 31 5 - 6 2 6 2

    B e th le h e m A p p a ra tus C o . In c                  F l u o r e s c e n tl a m p s a n d a va r ie ty
    R e s o u r c e a n d R e c yc l i n g D i v i s io n      o f o the r m e r c u r y c o n t a i n i n g i tem s .
    8 9 0 F r o nt S t.,
    P .O . B o x YH e l l e r to w n P A 1 8 0 5 5
    P h o n e : (610 ) 83 8 - 7 0 3 4
    F a x: (6 1 0 ) 8 3 8 - 6 3 3 3

                           MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                K-9

  Bethlehem Apparatus Co. Inc                      lampsand a variety
  Resource and Recycling Division        of other mercury containing items.
  890 Front St.,
  P.O. Box Y         ,
            HellertownPA 18055
  Phone: (610) 838-7034
  Fax: (610) 838-6333

  Safety- leen                                     lampsand a variety
  221 Sutton Street                      of other mercury-containing items.
  North Andover, MA
  Phone: (978)685-2121

  Northeast Lamp Recycling, Inc.                   lamps
                                         Fluorescent   .
  250 M St.
  E. Windsor, CT 06088
  Phone: (860) 292-1992

  Full Circle, Inc.                                lampsand ballasts.
  509M  anida St.
  Bronx, NY 10474
  Phone: (800) 755-1516
           (718) 328-4667

  I.G. Inc.                                                  lamps
                                         Fluorescent computer ,
  3476 Saint Rocco Court                 computer monitors and
  Cleveland, Oh 44109                                  R
                                         televisions (C Ts).
  Phone: (216) 631-7710
  Fax: (216) 631-7711


                                               Appendix L
                                       Infrastructure Control Measures

           (Information taken from the final version of the Mercury Management Guidebook,
      prepared by the Massachusetts Water Resource Authority (MWRA) / Medical Academic and
    Scientific Community Organization Inc. (MASCO) Mercury Work Group, Boston, MA. The full text
              of the Guidebook can be found at the World Wide Web address listed below.)

    Please note: This Appendix cites many regulations which only apply to the state of Massachu-
    setts. While the regulatory information is state-specific, this excerpt on infrastructure control is
    general enough to be of use to any facility concerned with mercury and organic build-up.)

    The MWRA/MASCO Mercury Work Group, public-private partnership of the Massachusetts Water
    Resources Authority (MWRA) and sewer dischargers (including hospitals, universities, and other
    industries), was established in 1994 to study and implement ways to reduce mercury discharges
    to the MWRA sewerage system. One organization, the Medical Academic and Scientific Commu-
    nity Organization Inc. (MASCO) that represents many Boston hospitals, has worked from the
    beginning of this effort to help identify the sources and methods of removing mercury from hos-
    pital waste streams.

    One area studied by the MWRA/MASCO Mercury Work Group was the waste piping infrastructure
    of a facility because elemental mercury waste deposits and mercury-contaminated bacteriologi-
    cal growth (biomass) were identified as possibly significant contributors to chronic mercury con-
    tamination in wastewater discharges. Some of the accumulated mercury could be biologically
    converted to methyl mercury which is both soluble and highly toxic. In addition, research by
    several hospital institutions found that the biomass within their “ Special Waste” plumbing sys-
    tems would readily absorb and accumulate mercury, with concentrations reaching as high as
    1,000 parts per billion. Fragments of biomass were seen to periodically break off and carry the
    absorbed, concentrated mercury to the sewer discharge. Because of these concerns, the Work
    Group developed in its Mercury Management Guidebook a section called “       Infrastructure Control
    Measures”to assist facilities that experience mercury-contaminated biomass within their waste
    piping infrastructure.

    For additional information on source reduction, infrastructure maintenance and end
    of pipe treatment modalities, please refer to the MASCO website at

                       MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                        L-1

   As outlined in Section 2.5 of this Guidebook, infrastructure control measures may include the
   following steps:
                          - source reduction
                          - source segregation, waste piping modifications
                          - waste trap sampling, cleaning, or replacement
                          - waste piping replacement or cleaning (power washing)
                          - wastewater collection for offsite disposal
                          - wastewater pretreatment (possibly consisting of equalization, solids
                            sedimentation, multistage filtration or other process steps)

   While these steps are listed in a possible chronological order, the actual number and order of
   steps could be different depending upon the facility and its Mercury Management Plan. Occasion-
   ally, earlier steps may be repeated before a later step is undertaken.

   Infrastructure control measures have been developed and undertaken at several facilities in the
   MWRA sewer service area because elemental mercury waste deposits and mercury accumula-
   tions in biomass growth from past discharge practices were identified as significant contributors
   to chronic mercury contamination of the wastewater discharges. The accumulation of mercury
   within waste piping systems containing biomass growth contributes to the complexity of wastewa-
   ter mercury management at a facility. In addition, because various biological nutrients may be
   contained in “ Special Waste”(defined below), biomass growth can be promoted in facilities that
   discharge such waste into the building waste piping infrastructure.

   The three appendices that follow are focused on mercury and biomass removal from piping sys-
   tems that carry Special Waste. However, the procedures discussed in these appendices can be
   followed by any facility where discharge of mercury-containing materials to waste piping systems
   has been confirmed or is suspected. The appendices are entitled Special Waste Piping Design
   (Appendix B-1), Special Waste Trap Cleaning/Replacement (Appendix B-2), and Special Waste
   Piping Power Washing (Appendix B-3).

   Before any of the guidelines and procedures presented in these three appendices are consid-
   ered, however, a facility should take all steps needed to prevent any elemental mercury or
   mercury-containing compounds from being disposed to the Special Waste drains of the facility.
   Continued disposal of any amount of mercury to the drains may mean that the waste trap and
   piping cleaning procedures would be totally ineffective or effective only for a short period. Then,
   the waste trap and piping cleaning procedures might have to be repeated to reduce effluent
   mercury concentrations.

             MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                L-2
  In addition, because of a lack of consistent analytical data developed before and after power
  washing of waste piping systems at several facilities, the MWRA is currently developing a policy
  concerning power washing of Special Waste systems. Specifically, the MWRA is concerned that:

           1) Power washing may be improperly considered by some facilities as a substitute for
          comprehensive mercury management that would include source reduction (including
          purchasing and inventory controls), source segregation (including training and
          supervision of waste disposal practices), and/or pretreatment.
          2) Power washing may lead to greater mercury violations for an indefinite period as
          small particles of loosened mercury-contaminated biomass are discharged with normal
           wastewater flows for several days or weeks after the power washing procedure.

  Refer to Appendix B-3 for details on the current state of MWRA power washing requirements.

  To introduce and clarify the following three appendices, Massachusetts Special Waste is defined
  below and the concepts of biomass growth and mercury bioaccumulation and bioconcentration
  are discussed.

  Special Waste

  According to the Massachusetts State Plumbing Code (248 CMR 2.13) “          Special Waste”includes,
  but is not limited to, chemicals, nuclear, radioactive, acids, alkalis, perchloric solvents, organisms
  containing recombinant DNA molecules, and other similar non-domestic wastes from various
  laboratories and industrial activities. These types of wastes are potentially detrimental to a public
  sewerage system and often do not comply with discharge limitations established by a local Pub-
  licly Owned Treatment Works (POTW) such as the MWRA.

  All Special Waste must be conveyed within facilities in a separate, dedicated waste and vent
  piping system. The Code covers piping design, types of waste neutralization systems, testing
  requirements, and inspection requirements for Special Waste piping systems. Allowed materials
  and installation methods are also specified. The Code does not specify the manner by which
  Special Waste piping systems are to be used after installation or what specific chemicals may be
  disposed into the system on a daily basis. On the other hand, the Code does prohibit the introduc-
  tion of solvent-bearing waste (248 CMR 2.13 (8)(e)) and requires the facility owner to submit a
  notarized letter stating what chemicals will be discharged into the Special Waste system (248
  CMR 2.13 (4)). The letter will be part of the basis of the design of the system by a Registered
  Professional Engineer. In addition, the Code states that wastewater treatment systems shall be
  part of the Engineers design when needed for compliance with regulatory limits (248 CMR 2.13

   All proposed Special Waste piping and pretreatment system installations, modifications, revisions
   and additions must be detailed in engineering drawings and specifications and certified by the
   Engineer. The drawings and specifications must be submitted to the local Plumbing Inspector for
   review and approval before construction. The approved documents are then submitted to the
   responsible jurisdictional authority (e.g., the MWRA or the MA-DEP) with the proper permitting
   documents and supporting engineering design data for final approval before the Special Wastes
   can be discharged to the sewerage system.

   Biomass Formation and Mercury Bioaccumulation and Bioconcentration

   Bacterial biomass growth in Special Waste piping systems can be promoted by the presence of
   organic matter such as blood products, urea, soaps, chemical reagents, and infectious wastes
   discharged into the piping system. The combination of organic matter, possibly elevated tempera-
   tures, and high humidity provides a good environment for biomass growth on the interior surfaces
   of the waste piping. The organic matter often contains methyl and dimethyl groups that can be
   combined by certain bacteria with inorganic mercury in the wastewater to create very toxic or-
   ganic forms of mercury (e.g., methyl mercury and dimethyl mercury). In addition, the mercury
   accumulates in the bacterial biomass and concentrates to significant levels. Because of the
   phenomenon of “  bioconcentration,” bacterial biomass mercury concentrations 1,000 times greater
   than that found in the wastewater have been reported.

   Within a flowing pipe, the biomass growth occurs principally below the liquid level with lesser
   amounts above. Within a trap at a sink or elsewhere, the growth can be more pronounced be-
                                                   incubator”with effectively no oxidation or dehy-
   cause the contained liquid creates a continuous “
   dration of the bacteria. A hardened skeleton of carbon, oxidized soap products containing ele-
   ments such as calcium and potassium, and dried blood products can be formed that strongly
   adheres to the piping surface.

   Figures B-1 and B-2 illustrate the mercury bioaccumulation and bioconcentration process in Spe-
   cial Waste traps and piping, respectively. A numeric key for the figures appears in Figure B-3 along
   with a general description of the bioaccumulation/bioconcentration process.

   When wastewater flows through the Special Waste piping system, “  slugs”of mercury-laden biom-
   ass may be carried into the wastewater stream when pieces of the accumulated growth are
   dislodged from the piping wall. Therefore, large amounts of bacterial biomass growth within the
   waste piping can lead to instances of high mercury concentrations in discharged wastewater. To
   move toward compliance with mercury discharge limits, therefore, this phenomenon may have to
   be addressed in facilities that have mercury-laden biomass growth. The following guidelines and
   procedures may help some facilities address the issue properly.

             MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                 L-4

  It should be noted that bacterial biomass formation can also occur within wastewater neutraliza-
  tion tanks. This formation can increase the potential for further mercury bioaccumulation/
  bioconcentration and wastewater contamination. According to the Plumbing Code,6 limestone
  chips are often used in sumps or tanks (i.e., chip tanks) for neutralization of Special Wastes
  containing dilute acids and alkalis. Chip tanks should not be used in facilities discharging signifi-
  cant quantities of organic matter, however, since bacterial biomass growth will tend to coat the
  limestone chips, rendering them useless for neutralization. It is recommended, therefore, that
  facilities check the condition and efficacy of any chip tanks and replace them with active (adjust-
  able) neutralization systems as appropriate. For additional information, refer to Section 2.5 of
  this Guidebook.

                                        Figure B - 1
                              Special Waste Trap Cross-Section
                    Mercury Bioaccumulation/Bioconcentration in Biomass

                                  Figure B-2
                      Special Waste Piping Cross-Section
             Mercury Bioaccumulation/Bioconcentration in Biomass


                                              Figure B - 3
                                  NUMERIC KEY FOR FIGURES B-1 AND B-2

   1 • Liquid wastes enter the Special Waste piping system carrying organic liquid wastes, bacteria, and
       mercury wastes such as elemental mercury (Hg) and mercury salts (represented by HgCl2).

   2 • Elemental mercury and mercury salts are slowly metabolized by certain bacteria. Chlorides are
       oxidized to chlorates and mercuric ions (Hg+2) are released.

   3 • Elemental mercury is partly converted to mercuric ions (Hg+2).

   4 • Mercuric ions (Hg+2) combine with methyl ions (CH3-1) with bacteria acting as biological catalytic

   5 • Toxic methyl mercury ions (CH3Hg+) and dimethyl mercury ( (CH 3) 2Hg ) are formed.

   6 • Methyl mercury ions (CH3Hg+) are absorbed and bioaccumulated/ bioconcentrated in the organic
       biomass growing on the Special Waste pipe wall.

   7 • Dimethyl mercury ( (CH3)2Hg ) molecules are absorbed and bioaccumulated/ bioconcentrated in
       the organic biomass growing on the Special Waste pipe wall.

   8 • Some molecules of dimethyl mercury ( (CH3)2Hg ) take a vapor form.

   9 • Some molecules of dimethyl mercury ( (CH3)2Hg ) vapor are absorbed and bio-accumulated in the
       organic biomass growing on the Special Waste pipe wall.

   10• Some molecules of dimethyl mercury ( (CH3)2Hg ) evaporate and are potentially released into the
       workplace atmosphere from liquid surfaces in traps of the Special Waste piping system.

   Courtesy of Flow-Tech Associates, Inc.

             MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                              L-8
                                      APPENDIX B - 1


      This Appendix presents example design considerations for waste piping infrastructure. Modi-
      fications that may be needed before initiation of any cleaning or replacement activities in
      response to known mercury contamination.

      Facility Infrastructure Inspection

      The first step in dealing with known mercury contamination in the waste piping infrastructure
      of a facility is to conduct an audit of the existing piping systems. Drawings that reflect details
      of the actual waste piping, vent piping, and any associated pretreatment system installa-
      tions should be prepared. Special Waste diagrams are important tools and can show regu-
      lating authorities that the facility has knowledge and control of all Special Waste discharges.
      These diagrams should display all piping materials and sizes, traps, isolation valves, glass
      inspection ports or sections, and sampling/drain valves. The diagrams should also show any
      current areas lacking control or isolation of Special Waste discharges.

      Piping System Design and Modification

      After the piping system audit, the facility may determine that modifications are necessary to
      allow for isolation of waste streams, cleaning, sampling, testing, and monitoring. System
      designs or modifications should consider the following: the type of wastes being discharged
      and the piping material compatibility. Metal piping systems deserve special attention be-
      cause of the potential for mercury to form an amalgam with the metal. Cleaning of metal
      piping systems is not expected to reduce effluent mercury concentrations. The cleaning
      effort may actually cause an increase in effluent mercury concentrations. Thus, redesign
      and replacement of the systems using nonmetal materials should be strongly considered
      instead of attempts at cleaning.

      As outlined in Section 2.5 of this Guidebook, infrastructure control measures may include
      the following steps:

      -       the future uses of laboratory spaces (i.e., a chemical research laboratory
              that is to be changed to a blood testing laboratory).
      -       the need to isolate branch piping from waste and vent stacks to allow pipe
              cleaning (if needed and selected) without constricting waste flows from other
              areas or causing overflows to uncontaminated piping systems.
      -       the investigation of unidentified Special Waste sources and associated
              piping for bacterial
      -       biomass and mercury content before combining with previously identified
              Special Waste piping. Pending the results of investigation of these new sources,
              additional isolation valving and/or new dedicated risers discharging to the
              neutralization system may need to be installed.


    For trap cleaning/replacement and power washing procedures as discussed in Appendices B-2
    and B-3, respectively, any disinfecting or cleaning agents proposed for use must be reviewed in
    relation to possible interactions with the chemicals that may be contained in the waste piping
    system. The potential for incompatible reactions should be considered to ensure that trap clean-
    ing and power washing procedures will not create any unsafe conditions. Reactions that may
    cause fuming and gas evolution into the working environment, and into the piping system, must be

    Isolation Valves

    The facility may determine that isolation valves need to be installed to allow for trap cleaning/
    replacement, removal of noncompliant wastes, sampling of suspect branch piping, and control of
    potential cross-contamination. The location of isolation valves should consider accessibility and
    maintenance especially when co-fitted with a sampling port for testing.

    The location of valves should not cause an overflow of noncompliant wastes into another area
    where a spill may occur. As an example, a floor drain would overflow if too much liquid used for
    pipe cleaning was poured into a counter top sink at a higher elevation. Additionally, the need to
    provide isolation valves in the venting system must not be overlooked for the same reasons.

    Sampling Ports

    Sampling ports should be installed in strategic locations for the periodic collection of wastewater
    samples for monitoring purposes. Design of the sampling ports can follow that shown in Figure 2,
    Recommended Sampling Port for Special Wastes, of the Pretreatment Guidance Manual MWRA/
    MASCO Mercury Work Group, December 1997.

    A sampling port in an isolated branch of piping may not only act as a monitoring point but also as
    a drain leg for any disinfecting or cleaning agents used. The sampling port nozzle may be replaced
    with a full-size drain leg for transfer of suspected noncompliant cleaning wastes to containers for
    off-site disposal.

    Special Waste Risers

    Vertical Special Waste and vent piping risers may need to be isolated to allow for sequential
    disinfection, cleaning, and testing of portions of entire systems in the same manner as has been
    explained for horizontal runs of piping. During these periods, special consideration must be given
    to the isolation of vent piping to reduce the possibility of overflow of reagents back through the

             MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                 L-10
       piping system.

       Glass Inspection Ports

       Inspection ports or sections of clear borosilicate glass piping should be installed within the main
       horizontal runs of the Special Waste piping system fabricated of thermoplastic or other opaque
       piping materials so that flow conditions can be viewed and the bacterial biomass accumulation
       can be periodically observed. If any branch piping may contain undiluted caustic or hydrofluoric
       acid, however, the branch piping sections should be routed separately and connected down-
       stream of a glass fitting and should have its individual isolation valves and sampling port assem-

       The above are examples of the various design considerations needed for modifications of Special
       Waste piping systems before cleaning or replacement activities are initiated. However, before
       modifying any portion of its waste piping infrastructure, a facility should determine if the system
       contains any metal piping or fitting materials that would require replacement and not cleaning.

       In addition, a thorough inspection of any traps and horizontal piping runs (including analyses of
       biomass samples) should be done to find if modification, cleaning, or replacement efforts should
       be done at all. If trap and biomass contaminations are found, the decision would then be made to
       pursue a specific combination of source reduction, source segregation, infrastructure modifica-
       tion, infrastructure replacement, infrastructure cleaning, and pretreatment as a solution to non-

     compliance with mercury sewer discharge limitations.

                                           APPENDIX B - 2

     In Special Waste systems, trap accumulations of elemental mercury and of bacterial biomass
     growth contaminated with mercury has been found a significant source of chronic elevated mer-
     cury concentrations in wastewater discharges. The trap cleaning and replacement procedures
     outlined below have been found of significant value in reducing the levels of mercury in affected
     wastewater discharges.

     Trap Location / Identification

     Trap locations are determined by preparing a detailed inventory of all Special Waste sources.
     Trap identification can be accomplished as part of the facility piping system audit discussed in
     Appendix B-1. After all sources are identified, a facility Special Waste piping general arrangement
     drawing should be generated with all traps identified by unique numbers. A master inventory of all
     traps should be generated to record and track all trap cleaning or replacement events. Each trap
     should be tagged or labeled with its unique number, the cleaning or replacement date, and the
     name and signature of the person doing the cleaning/replacement. A Special Waste Trap Inven-
     tory Form such as shown in Figure B2-1 can be used to document the information and can
     include additional information such as the type and size of piping material.

     Removal of Elemental Mercury

     Elemental mercury is sometimes discharged into sinks and floor drains when mercury-containing
     equipment breaks. Some elemental mercury sources include mercury thermometers, thermo-
     stats, electric switches, and blood pressure manometers. When a sink or floor drain trap is
     removed for the first time, it may contain elemental mercury, identifiable as a pool of heavy silvery
     liquid separated from the trap wastewater.

     Elemental mercury removed from any traps should be collected and disposed as a mercury waste.

             MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                    L-12
              See Appendix C for disposal of mercury wastes.

                                                Figure B2-1

                                  TRAP INVENTORY FORM

 Institution Name      ________________________________________________________

 Address               ________________________________________________________

 Building Name         ________________________________________________________

      Trap          Room/Dept. Name     Plumbing     Trap Type   Type of Waste &   Cleaning
  Identification                        Material                     Hazard          Date


                              Sample Special Waste Trap Inventory Form
   Removal of Biomass

   Almost every trap will accumulate bacterial biomass, identified as a slimy brown film on the i nter-
   nal surface of the plumbing material. The bulk of this growth will occur on the bottom and wetted
   sections but some biomass will grow along the sides and top of the non-wetted section of the
   plumbing materials. This capillary action of growth is the most difficult to remove. Biomass growth
   on non-wetted surfaces can dry out. The dried out biomass develops a strong bond to the plumb-
   ing surfaces. In addition, any elemental mercury disposed into the drain can form an amalgam
   with metal plumbing. The amalgam is very difficult to remove from the trap. Accordingly, some
   facilities have chosen to replace contaminated traps rather than attempt to clean them.

   Trap Removal and Handling Precautions

   Where wastewater is elevated in temperature or where chemical reactions produce heat within a
   piping system, greater amounts of toxic fumes including dimethyl mercury may be formed in the
   accumulated biomass. Both elemental mercury and dimethyl mercury may exist in vapor form
   within the piping systems. Since negative pressures can sometimes exist in laboratory rooms,
   hazardous elemental or dimethyl mercury vapors can emanate from plumbing traps back into the
   rooms. Therefore, proper personnel protection should be practiced at all times. In addition, the
   traps should be of the deep seal type and should continually be filled to afford protection against
   possible vapor “ drawback.”

   Trap Cleaning or Replacement Procedures

   1. Identify traps for cleaning or replacement and discuss the trap removal procedure with the
   affected facility occupants. Explain to them that the procedure will interrupt their operations and
   estimate the duration of the interruption.
   2. Before any traps are removed, it is important to ask the occupants about the nature of their
   wastes, identifying all possible health and safety hazards. Before handling traps that are in areas
   that contain hazardous materials, all traps should be checked by the appropriate administrator
   for approval (i.e., if a radioactive isotope is being used in a room, have the Radiation Safety
   Department check out the trap to assure that it is safe for removal and handling).
   3. After facility occupants have been made aware of the trap cleaning/replacement program
   and after it is determined that it is safe to handle traps, actual trap removal, replacement, and
   cleaning can be started.
   4. It is important that personal protective equipment be worn at all times by any personnel doing
   trap handling. It is recommended that all these procedures be reviewed by an internal Health and
   Safety Officer.
   5. It is recommended that all materials found inside the traps be initially handled as mercury
   waste and then disposed of as mercury waste unless analyzed and found otherwise. See Appen-
   dix C for information on the proper disposal of mercury waste.
   6. If the removed trap is to be cleaned, either a rag or flexible brush can be used. A cleaning
   agent and some type of disinfectant may also be used to help ensure that complete removal of
   bacterial biomass and disinfection is accomplished. For metal traps, replacement is usually pre-

             MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                 L-14

       ferred because of the potential for mercury to form an amalgam with the metal.
        7. After traps are removed, cleaned or replaced, and reinstalled, a tag or label
       should be wired to the trap (or an existing tag should be updated) with the unique
       number of the trap, the date, and the responsible individuals’   initials.
        8. After trap removal, cleaning, or replacement is completed and the area is re-
       turned to its original condition, all access panels and other structural materials
       should be reinstalled. Before leaving the area, inform the occupants that the proce-
       dure has been completed.
       9. All trap cleanings or replacements should be logged on a Trap Inventory Form
       (See Figure B2-1 for an example inventory form).
       10. If it is known that any mercury-containing materials will remain in use, the asso-
       ciated wastes should be segregated and collected for offsite disposal. Otherwise, it
       will be necessary to inspect the affected cleaned traps for recurring contamination
       of the biomass growth. These inspections could serve as a check on actual disposal
       practices and could initially be done quarterly. Once a sufficient level of experience
       has been obtained, inspection frequencies can either be increased or decreased
       depending on the levels of contamination and the rates of returning biomass. The
       inspections should help determine the need for repetition of the entire procedure.
       11. It is highly recommended that spare traps and associated hardware be avail-
       able for each type and size of trap because corroded or otherwise unusable traps
       are often discovered during a cleaning/replacement program.


                                         APPENDIX B - 3
                              SPECIAL WASTE PIPING POWER WASHING


   In the past, Special Waste piping systems were sometimes used for the disposal of mercury and
   mercury-containing materials. Because of the phenomena of bioaccumulation and bioconcentration,
   the bacterial biomass within such Special Waste piping systems could contain concentrations of
   mercury in the part per million range. In some cases, the presence of such mercury-laden biom-
   ass was cited as the sole reason that mercury was detected in discharged wastewater at con-
   centrations exceeding the MWRA enforcement limit of 1.0 mg/L (ppb).

   A few facilities have used power washing of their Special Waste piping systems as a mercury
   control technique because of the scouring effect of power washing on accumulated mercury-laden
   biomass that effectively removes the biomass. Some of these users believe that, after all needed
   mercury source reduction has been carried out, power washing would be a lower cost final step in
   effluent mercury control than removal and replacement of the contaminated Special Waste pip-
   ing system.

   Special Waste piping power washing uses specialized pumping equipment to produce a high pres-
   sure/low volume stream of water. The water stream flows through a high pressure hose and a
   power nozzle to produce a 360 degree high velocity spray that can remove accumulated biomass
   and grease from the inside surfaces of the waste piping while flushing the resulting debris down
   the line.

   Status of MWRA Power Washing Requirements

   Currently, there are uncertainties in the ability of power washing to remove all biomass residues
   thereby possibly exposing new surfaces from which mercury can reach the wastewater. Also,
   there is some evidence that power washing may lead to new and possibly higher mercury viola-
   tions from the discharge of dislodged biomass particles for an indefinite period after power wash-
   ing is performed. Because of these concerns, the MWRA is currently formulating requirements
   for data collection during power washing. As part of this process, a facility must notify the MWRA
   of its intention to perform power washing and participate in a study of power washing effects
   according to specific conditions and protocols. The results of the study will be used to finalize a
   MWRA guidance on acceptable power washing procedures.

             MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                L-16


       Because of the phenomena of bioaccumulation and bioconcentration, the biomass within a
       Special Waste piping system (that has been used for disposal of mercury-containing materi-
       als) may contain concentrations of mercury in the part per million range. Power washing has
       been used as a mercury control technique for such systems because of its scouring effect on
       the accumulated mercury-contaminated biomass. Power washing has been identified as a
       possible lower cost method of biomass control compared to replacement of the facility’    s
       waste piping system. However, because of the issues outlined below, power washing of
       waste piping systems may not be effective at all facilities.

       Power washing uses special equipment that produces a high pressure/low volume stream of
       water. The water flows through a high pressure hose and a power nozzle to produce a high
       velocity spray that removes accumulated biomass and grease from the inside of waste con-
       veyance piping while flushing the resulting debris down the line. Results of a power washing
       effort are dependent upon accessibility to the entire waste piping system (i.e., through use of
       piping isolation valves, cleanouts, access ports, and drains). In addition, there are uncertain-
       ties in the ability of power washing to effectively remove all biomass residues thereby possi-
       bly exposing new surfaces from which mercury can reach the wastewater, and there is evi-
       dence that power washing may actually lead to new mercury violations from continued dis-
       charges of dislodged biomass particles.

       Because of these issues, the MWRA will require prior notice of intended power washing by
       permitted dischargers. The MWRA is considering additional requirements including approval
       of power washing protocols and collection and offsite disposal of the facility wastewater
       during and after power washing until sampling and analyses show that mercury concentra-
       tions in the discharge have returned to the same levels or lower that existed before the
       power wash procedure. A possible alternate approach would be removal of dislodged biom-
       ass particles from the discharge possibly by sedimentation or multistage filtration.

       The temporary or permanent particle removal system could be installed within the piping
       system or at the final discharge point. The particle removal system could be considered
       separately or as part of a mercury pretreatment system. The proposed installation of the
       particle removal system must be disclosed to the responsible POTW, however, since the
       POTW will likely consider the system to be a type of pretreatment system.

       Some facilities have considered power washing to be an effective method for reducing mer-
       cury concentrations in their sewer discharges. If mercury-containing materials continue to be
       disposed to the waste piping system, however, the power washing procedure will not be a
       permanent solution and will likely have to be repeated on a continuing basis. If a facility
       should choose to engage in power washing, the following discussion should be referred to for
       precautions, recommended techniques, and possible compliance issues.


                               Power Washing Precautions

     The following are some precautions that should be considered before starting power
     washing procedures:
     • Waste conveyance piping accessibility is essential for successful power washing.
        Considerable modifications to an existing system may be needed to achieve the
        needed accessibility.
     • Perhaps because of the potential for mercury to form an amalgam with other metals,
        power washing is not expected to be effective in waste piping systems constructed of
        metals (i.e., high silicon cast iron or stainless steel). If a metallic waste piping system
        were mercury-contaminated, total replacement of the system should be considered.
     • All substances contained within the waste conveyance piping should be taken as
        hazardous. Before power washing, the facility’ Health and Safety Officer should
        review the proposed power washing procedure to ensure that proper personal protec-
        tive equipment will be used.
     • Waste conveyance fittings and piping, especially with glass fittings, can be cracked or
        broken during power washing. Inspect the entire run before power washing, and
        identify any potential obstructions, so that if a fitting is broken, a replacement fitting
        can be immediately available for installation.
     • If the waste conveyance piping contains large amounts of biomass, dislodged pieces
        may collect and clog downstream conveyance piping sections. If such clogging occurs,
        there may be wastewater backups in the plumbing system causing flooding at lower
        elevation locations.
     • Dislodged biomass particles can appear in the sewer discharge for some period after
        power washing. To avoid compliance problems from the power washing procedure,
        collection and offsite disposal of the affected wastewater may be needed until testing
        shows no elevated mercury levels. Alternately, the dislodged biomass particles could
        be removed from the discharge by a temporary or permanent removal system within
        the piping system or at the final discharge point. The proposed installation of a
        particle removal system, however, must be disclosed to the POTW since it likely will be
        considered a pretreatment system.
     • Any proposed sanitizing or cleaning agents should be reviewed to prevent possible
        chemical interactions with waste constituents that may exist in the piping system. The
        potential for incompatible reactions should be considered to ensure that trap and pipe
        cleaning procedures will not create unsafe conditions. Reactions that may cause
        fuming and result in gas evolution into the working environment, as well as into the
        piping system, must be avoided.

             MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                             L-18

    Power Washing Techniques

    The following techniques are easily monitored for effectiveness when performed on glass waste
    piping systems. The techniques may require some modification when applied to thermoplastic or
    other waste piping materials.

    1.   Power washing activities usually require a minimum of two people: one serving as the power
         wash operator; and the other as an observer of the nozzle and hose as it moves through the
         waste conveyance piping.
    2.   The operator begins feeding the 80 to 100 feet of hose with the power washing nozzle
         attached, while the observer, with a two-way radio in full communication with the operator,
         watches the hose and nozzle for potential obstructions and other problems. Typical obstruc-
         tions include: tees, reducers, p-traps, drum traps and valves.
    3.   Some facilities have determined that successful power washing occurs when cleaning op-
         erations begin at the collection or treatment tanks in the lower floors. The operator then
         works in the waste piping system toward the sources in a reverse flow direction. This tech-
         nique is preferred because the nozzle is designed with a reverse flow head configuration
                        pulls”the hose away from the power washer operator and toward the sources
         that literally “
         while flushing biomass and debris down the line and to the collection point. In addition, most
         plumbing fittings have smooth swings in the reverse direction and this seems to reduce
         obstruction interference.
    4.   Although reverse flow is preferred, the complexities of the piping infrastructure may require
         some experimentation. For immediate progress, select straight sections observed to con-
         tain biomass. In other locations, piping may have to be removed or modified to reach all
         areas of concern. Power washing on thermoplastic piping will require more experimentation
         and it may be necessary to remove piping sections to verify cleaning effectiveness. The
         installation of sight glasses may help to reduce the required amount of pipe removal.
    5.   At times, it may be difficult or impossible to feed the hose and nozzle in the preferred re-
         verse direction. An alternative method would then be to start at the sources (sink traps or
         floor drains) and work in the direction of flow. This technique, however, is less desirable
         because the nozzle head will not be directly flushing debris as it moves along the piping. It
         may be necessary, then, to apply additional water to aid the flushing process by turning on
         an adjacent sink tied into the same waste conveyance line.
    6.   Regardless of the direction that the power wash nozzle is fed into the system, a final wash
         and high volume rinse in the direction of flow may help to flush residual biomass particles
         from the system.

     Chemical Addition

     Some power washing units are designed for use with water only and do not allow for addition of
     chemical solutions. However, it is recommended that a bleach solution be added to the piping at
     the source, if possible, to accomplish disinfection of the piping system before the power washing
     and aid in the removal of biomass. The bleach or other disinfecting chemical should be analyzed
     before use to ensure that it is mercury free or of a “ low”mercury content. Unfortunately, some
     chemicals and reagents, including many disinfecting products that contain bleach, may contain
     measurable amounts of mercury.

     Other Cleaning Solutions
     The additions of surfactants, dispersants, caustics and/or wetting agents were investigated dur-
     ing the MWRA/MASCO Mercury Work Group Phase I effort. None of these chemicals were rec-
     ommended then because of health and safety considerations. In addition, such chemical addi-
     tions may be costly for waste piping systems at large facilities. However, some power washing
     companies may offer chemical addition services and facilities may find that chemical addition is
     quite feasible, safe, and effective.

     Power Washing Wastewater Disposal

     All power washing wastewater that contains removed biomass should be assumed to contain
     levels of mercury above the MWRA enforcement limit of 1.0 µg/L (ppb) and, therefore, should be
     collected for offsite disposal. The collection of the power wash wastewater is difficult, but since
     power washing will usually occur during non-operating hours, the piping systems can virtually be
     drained. Once normal flow has stopped, existing neutralization or treatment tanks can be emp-
     tied and used as power washing wastewater collection vessels. Additional temporary collection
     vessels may be needed.

     After power washing is completed or the treatment tanks get full, transfer all collected wastewa-
     ter into storage containers. Other collection and pumping methods can be used on a case-by-
     case basis. However accomplished, it is very important that this wastewater be collected and not

     In addition, dislodged biomass particles can sometimes appear in the sewer discharge for some
     period after power washing. To avoid compliance problems, collection and offsite disposal of the
     affected wastewater or removal of the biomass particles from the discharge may be needed. A
     temporary or permanent filtration system within the piping system or at the final discharge point
     should be considered. The proposed installation of a filtration system, however, must be dis-
     closed to the POTW since it will likely be considered a pretreatment system.

             MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                  L-20

       All waste disposal activities should be approved by an Environmental, Health and
       Safety Officer or the person responsible for waste disposal. The MWRA prohibits the
       disposal of chemicals into the sewerage system except for aqueous solutions of
       nontoxic and nonhazardous chemicals. 7 In addition, the Massachusetts Depart-
       ment of Environmental Protection (MA-DEP) prohibits the improper disposal of haz-
       ardous wastes.8
                MWRA Sewer Use Regulations: 360 CMR 10.000.
                MA-DEP Hazardous Waste Regulations: 310 CMR 30.000.


                                                 APPENDIX M
                                         Strong Memorial Hospital (SMH)
                                        Mercury Spill Clean-Up Procedures
                                         Revised November 1996


     Broken Thermometers: (There is not enough mercury involved to present a hazard. If the
         following steps are taken, you do not need to respond with the mercury vacuum*. Never
         use a regular vacuum to clean up a mercury spill.)

     1.   Using two 3" x 5" cards push mercury into a pile.
     2.   Draw up into a syringe (no needle) and place in a sealed container or scoop into a specimen
          container or other sealable container.
     3.   Disposal:
          Non-patient area: Fill out a hazardous waste tag and call the
                             Hazardous Waste Management Unit for pick up.
          Patient area:      Label container (mercury) and place on cart to be returned to Sterile Supply.


     Broken Manometers:

     SMH patient area:    Call should be referred to SMH Housekeeping.
     Other area:          Contact an Industrial Hygienist for immediate clean-up.

     **Note: Any call which sounds unusual (i.e. spilled on patient, on carpet, in toilet, not a ther-
         mometer or manometer) should be referred to an Industrial Hygienist.

     It is important to respond as soon as possible (within 1 or 2 hours) to clean-up any spill.

     1.   Make sure everyone is removed from the room (patient(s), visitors, staff).
          Patient bed should not be removed from the room.

     2.   Gather equipment
          • Specialized mercury vacuum* and attachments (stored in the SMH Housekeeping Office-
            If locked, have one of the supervisors paged.)
          • The mercury vacuum is designed to clean up liquid mercury spills.
            Regular vacuum cleaners can volatilize the mercury and blow the mercury vapors
            into the air. An activated carbon filter in this vacuum will absorb and contain
            the mercury vapors.

             MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                    M-1
               • Tool box. The following items should be in the tool box:
                 • Flashlight
                 • Screwdriver
                 • Putty knife
                 • Mercury holding jar
                 • Respirator (3M 9908 Dust/Mist Respirator)
                 • Yellow or pink wash basin (from clean utility room on unit)
                 • Heavy plastic bag

    3.   Before entering room put on protective equipment.
              • Respirator
              • Long sleeve shirt
              • Long pants
              • Disposable gloves
              • Remove all jewelry

    4.   Assess the extent of the spill. Upon entering the room use flashlight (hold angled at floor
         level, put head close to floor to see where mercury is located). Also check wall, bed frame
         and mattress. Do not walk in contaminated areas.

    If there is anything unusual about the spill (i.e. on carpet, in a toilet, on patient, etc.)
    a member of the Industrial Hygiene Unit should be consulted.

    5.   Set up mercury vacuum using the following steps:
         A. Place plastic dishpan under separator.
         B. Remove red cap off mercury separator and screw jar onto vacuum.
         C. Remove red end cap from hose.
         D. Place required attachment on hose.

    6.   Begin vacuuming at outer edges of spill and work towards center of spill (usually the wall under
         the manometer). Set up an organized approach (i.e. begin vacuuming one block and move
         slowly, in a row to assure that you cover the entire area). Draw vacuum hand-piece slowly
         towards yourself. Pay special attention to floor moldings. If molding is pulled away from the
         wall and you suspect that mercury may have gotten behind it, remove the molding using the
         putty knife and vacuum behind it.

    7.   Once the area under the manometer has been vacuumed, remove the manometer from the
         wall bracket by unscrewing the top holding screw. Place the manometer in the wash basin. If
         the glass tube is not broken on the front of the manometer and there is no visible mercury on
         the outside of the manometer, put the manometer inside the plastic bag. Seal the bag and
         place in wash basin. If the tube is broken, empty mercury into the wash basin to be vacuumed.
         Then put the manometer into plastic bag and seal.


     8.   Once all the mercury has been vacuumed, take the flashlight and check again for beads of
          mercury on the floor, wall and bed. Several attempts may be needed to vacuum all of the
          mercury from a spill.

     9.   Place wash basin under mercury separator and unscrew jar. Place red cap over bottom of
          mercury separator and place red end cap on hose. Any mercury that may have fallen on the
          paper should be dumped into the jar. Place lid on jar and return jar to tool box*.

          If water has been vacuumed, notify Environmental Health and Safety (EH&S) immediately so
          that the appropriate maintenance can be performed.

          Removal of the jar after each use will extend the life of the activated charcoal filter.

     10. Pick up all materials and leave room.

     11. Leave manometer (in sealed bag) in the soiled utility room. The unit secretary should be in-
         formed to call to have the manometer replaced.

     12. Post sign on the door to assure that the room remains browned out and no one enters until
         EH&S has checked the room.

     13. Notify EH&S that the spill has been cleaned up. If the spill occurs during the normal 8-5:30 day,
         call EH&S immediately after clean up is complete. Please give the secretary the room number
         and other important details. If the spill occurs after 5:30 or on a weekend, leave a message on
         phone mail giving the room number and any other details about the spill.

     14. EH&S will respond with the mercury vapor sniffer and a flashlight to assure adequate clean up.
         Mercury vapor levels should be insignificant (<0.02 mg/m3) at floor level.

     15. The patient(s) may be returned to the room after EH&S has approved the room for use.

     *Note:      If mercury and spill debris reach the fill line on the jar, a Hazardous Waste Tag must
                 be filled out. The tag should be completely filled out and attached to the jar. The
                 Hazardous Waste Management Unit should be called to pick up the mercury.

              MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                   M-3
                                          Mercury Spills
                                      Special Circumstances

      • Following the above directions, vacuum up as much of spill as possible.
      • Check using mercury vapor sniffer.
      • Re-vacuum.
      • If, after vacuuming 3 times, levels remain elevated, the carpeting will need to be removed.
           Pull carpet up carefully and place into a plastic bag.
      • Re-vacuum floor under carpet.
      • Check levels using mercury vapor sniffer.
      • If the breathing zone level is <0.02 mg/m 3 then the room will be considered clean.

   ** Note: If it is an area where children will be crawling on the floor,
            then the mercury vapor level taken at the floor should also be less than .02 mg/m 3.


                                                 Appendix N
                                               Glossary of Terms

      Aneroid: Operates by the effect of outside air pressure on a diaphragm forming one wall of an
      evacuated container. Uses no liquid.

      Best management practices: Proven strategies that prevent or reduce the use, release or trans-
      port of toxic substances that adversely impact the environment.

      Bioaccumulate: To accumulate a substance in the tissues of an organism as a result of uptake
      from all environmental sources.

      Biosphere: The part of the world in which life can exist.

      Mercury loading: The amount of mercury that enters a water body per unit of time, such as pounds/

      Pollution prevention: Use of processes, practices, materials, products or energy that avoid or mini-
      mize the creation of pollutants and waste and reduce overall risk to human health and the environ-
      ment. Includes source reduction, recycling, reuse, reclamation or modification of operating prac-

      Source reduction: Waste prevention. Any activity that eliminates or decreases wastes by avoiding
      their creation.

      Toxicity Characteristic Leaching Procedure (TCLP): Test used to determine the ability of a sub-
      stance, such as mercury, to leach from waste in a landfill.

             MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                    M-5

                                          Appendix O

      Agency for Toxic Substances and Disease Registry. Toxicological Profile for Mercury.
      From: National Technical Information Service.

      Board, Michele (August 16-22, 1995). “  Comparison of disposable and glass mer-
      cury thermometers,”Nursing Times, Vol. 91, No. 33, pages 36-37.

      City of Palo Alto Regional Water Quality Control Plant. Best Management Practices
      for Hospitals and Medical Facilities. From: Palo Alto Regional Water Quality Control
      Plant, 2501 Embarcadero Way, Palo Alto, CA 94303; (415) 329-2598.

      City of Palo Alto Regional Water Quality Control Plant. Pollution Prevention for Hospi-
      tals and Medical Facilities. From: Palo Alto Regional Water Quality Control Plant,
      2501 Embarcadero Way, Palo Alto, CA 94303; (415) 329-2598.

      DelConte, M.J., Monroe County Mercury Pollution Prevention Team (May 9, 1997). A
      Mercury Pollution Prevention Study for Medical and Dental Centers: Findings Report
      and Bibliography.

      Environment Canada, Department of Fisheries and Oceans, Health and Welfare
      Canada. March 1991. Toxic Chemicals in the Great Lakes and Associated Effects.
      Minister of Supply and Services Canada, Ottawa.

      Eppstein, David. Pollution Probe Interview. October 16, 1996. Director, Govern-
      ment and Community Affairs, Academic and Scientific Community Organization, Inc.
      Boston, Massachusetts.

      Environment Reporter (July 26, 1996). “ Mercury-Containing and Rechargeable
                                                                   pages 652-655.
      Battery Management Act of 1996: A New Direction in Recycling,”

      Flint, R. Warren and Vena, John (Eds). 1991. Human Health Risks from Chemical
      Exposure. Lewis Publishers Inc. Chelsea, Michigan in Renzetti et al. (1993)

      Gilkeson, John, Minnesota Pollution Control Agency (April 16, 1996). Mercury Prod-
      ucts Study: A Report to the U.S. Environmental Protection Agency, Region V. From:
      Minnesota Office of Environmental Assistance, 520 Lafayette Rd. N., 2nd Floor, St.
      Paul, MN 55155; (612) 296-3417; (800) 657-3843.

     Great Lakes Pollution Prevention Centre:
     • Waste Management and Pollution Prevention in the Dental Community: Workshop
     Resource Guide (1996)
     • Waste Management and Pollution Prevention in the Hospital Community:
     Workshop Resource Guide (1996)
     From: Great Lakes Pollution Prevention Centre, (800) 667-9790.

     Health Care Without Harm (August, 1997). Healing the Harm: Eliminating the Pollution from
     Health Care Practices. From: CCHW Center for Health, Environment and Justice, P Box 6806,
     Falls Church, VA 22042, (703) 237-2249;

     Massachusetts Water Resources Authority, Toxic Reduction and Control Department, MWRA/
     MASCO Mercury Work Group:
     • Mercury Products Database (1998)
     • Facilities Loadings Subgroup Report (December 1997)
     • Pretreatment Guidance Manual (December 1997)
     • Technology Identification Subgroup Report (December 1997)
     • Mercury Management Guidebook (1998, updated 1999)
     From: Massachusetts Water Resources Authority, 100 1st Avenue, Charlestown Navy Yard, Bos-
     ton, MA 02129.

     Michigan Mercury Pollution Prevention Task Force (April, 1996). Mercury Pollution Prevention in
     Michigan: Summary of Current Efforts and Recommendations for Future Activities. From: Michigan
     Department of Environmental Quality, (517) 335-6974.

     Minnesota Office of Environmental Assistance. Mercury Use in Hospitals and Clinics. From: Minne-
     sota Office of Environmental Assistance, 520 Lafayette Road N., 2nd Floor, St. Paul, MN 55155;
     (612) 296-3417; (800) 657-3843.

     Minnesota Pollution Control Agency (1994). Strategies for Mercury Control in Minnesota. From:
     Minnesota Pollution Control Agency, 520 Lafayette Road N., 2nd Floor, St. Paul, MN 55155; (612)
     296-3417; (800) 657-3843.

     Minnesota Pollution Control Agency, Michigan Department of Natural Resources, Wisconsin Depart-
     ment of Natural Resources. Mercury in the Environment (set of fact cards).

     Monroe County Department of Health and New York State Department of Environmental Conserva-
     tion (1997). Rochester Embayment Remedial Action Plan Stage II.

     National Wildlife Federation. January 1993. “  Our Priceless Great Lakes - Economic Benefits of
     the Great Lakes Water Quality Initiative” Great Lakes Initiative - Draft Copy, Ann Arbor, MI, p.11

             MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                                 M-7
       National Wildlife Federation (July 1997). Mercury Pollution Prevention in Health Care: A Prescrip-
       tion for Success. From: National Wildlife Federation, Great Lakes Natural Resource Center, 506
       E. Liberty, 2nd Floor, Ann Arbor, MI 48104-2210; (313) 769-3351.

       Northeast States for Coordinated Air Use Management (NESCAUM); Northeast Waste Management
       Officials’Association; New England Interstate Water Pollution Control Commission; Canadian Eco-
       logical Monitoring and Assessment Network (February 1998). Northeast States and Eastern
       Canadian Provinces Mercury Study: A Framework for Action. From: NESCAUM, 129 Portland St.,
       Suite 501, Boston, MA 02114; (617) 367-8540.

                                       New medical waste and reduction rules take effect,”Vol 6, No.
       Nursing Matters (January 1995). “

       O’Grady, Valerie. Pollution Probe Interview. October 30, 1996. Environmental Coordinator, Hos-
       pital for Sick Children. Toronto, Ontario.

       Pollution Probe and Health Care Environment Network (1996). Proceedings: Mercury Pollution
       Prevention in the Health Care Sector, report of a workshop held in April 1996. From: Pollution
       Probe, 12 Madison Ave., Toronto, ON Canada M5R 2S1; (416) 926-1907;

                                                      Accuracy and Reliability of Temperature Measure-
       Pontius, S.L., et al. (January-February 1994). “
       ment in the Emergency Department by Instrument and Site in Children,” Pediatric Nursing, Vol.
       20, No. 1, pages 58-62.

                                      Less Mercury Lights the Way to TCLP Compliance,” Pollution
       Quinn, Barbara (October 1997). “
       Engineering, pages 23-24.

       San Francisco Water Pollution Prevention Program. Never Down the Drain: Pollution Prevention
       Tips for Dental Offices. From: City and County of San Francisco, Public Utilities Commission,
       Bureau of Environmental Regulation and Management, 3801 3rd St., Suite 600, San Francisco,
       CA 94124; (415) 695-7310.

       Santosefano, Loreto. Pollution Probe Interview. August 27 and September 18, 1996. Customer
       Service Chemist, Laidlaw Environmental Services, 1829 Allan Port Road, Thorold, Ontario, L2V
       3Y9, 1-800-263-2436.

       Smith, David. Pollution Probe Interview. October 4 and October 16, 1996a. Former Division
       Director, Support Services, Riverside Osteopathic Hospital, Michigan.

       Smith, Neil. Pollution Probe Interview. October 30, 1996b. Centenary Health Centre. Scarborough,

       Terrene Institute (1995). The Case Against Mercury: Rx for Pollution Prevention. From: Terrene
       Institute, 4 Herbert St., Alexandria, VA 22305; (703) 548-5473;


     U.S. Environmental Protection Agency (June, 1997). Mercury Study Report to Congress, Volume
     I: Executive Summary, EPA-425/R-97-003.

     U.S. Environmental Protection Agency (June 1995). National Forum on Mercury in Fish: Proceed-
     ings. #EPA-823-R-95-002.

     U.S. Environmental Protection Agency (1994). Green Lights Program: Lighting Upgrade Manual.
     #EPA 430-R-93-001.

     U.S. Environmental Protection Agency (May 1994). Project Summary, “   Mercury Usage and Alter-
     natives in the Electrical and Electronics Industries.” EPA/600/SR-94/047.

     U.S. Environmental Protection Agency, Great Lakes National Program Office; prepared by Ross &
     Associates (1994). Mercury Sources and Regulations: Background Information for the Virtual
     Elimination Pilot Project.

     U.S. Environmental Protection Agency (April 1992). Characterization of Products Containing Mer-
     cury in Municipal Solid Waste in the United States, 1970 to 2000: Executive Summary. #EPA

     U.S. Environmental Protection Agency Fact Sheets:
     • #1. Keeping Mercury Out of Medical Waste (1995)
     • #3. Use of Alternative Products (1995)
     • Keep Mercury Out of the Wastewater Stream
     • Mercury in the Municipal Solid Waste Stream. #EPA 530-F-92-017.

     Western Lake Superior Sanitary District; Great Lakes Protection Fund; Great Lakes Pollution Pre-
     vention Centre (1997).
     • Blueprint for Mercury Elimination: Mercury Reduction Project Guidance for Wastewater Treat-
        ment Plants
     • Get Mad Now, Not Later! (Brochure)
     • How to Manage Waste from Your Dental Practice
     From: Western Lake Superior Sanitary District, 2626 Courtland St., Duluth, MN 55806-1894;
     (218) 722-3336.

     Western Lake Superior Sanitary District; Minnesota Office of Environmental Assistance. MERC
     Concern Fact Sheet.

     Wisconsin Department of Natural Resources. Wisconsin Mercury SourceBook: A Guide to Help
     Your Community Identify and Reduce Releases of Elemental Mercury, May 20, 1997 draft (listing
     permitted by personal communication with Randy Case, Wisconsin Department of Natural Re-

             MERCURY WASTE VIRTUAL ELIMINATION MODEL PLAN                                               M-9

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