Medical Waste

Treatment
Technologies:
Evaluating
Non-Incineration
Alternatives
A Tool for Health Care Staff and
Concerned Community Members

May 2000
HEALTH CARE WITHOUT HARM THE C AMPAIGN FOR ENV IRONMENTALLY RESPONSIBLE HEALTH C A R E

ACKNOWLEDGEMENTS

F E E D B AC K

This document is the result of a collaborative

process between a number of individuals and
organizations. We thank them for their time,
input and dedication in creating and reviewing
this document (in alphabetical order):

Health Care Without Harm would appreciate your

feedback on this document. Please send your
comments to:

Laura Brannen, Dartmouth-Hitchcock Medical

Center, Lebanon, NH
Rob Cedar, Hamtramck Environmental Action
Team, Hamtramck, MI
Doris Cellarius, Sierra Club, Prescott, AZ
Stephanie C. Davis, Waste Reduction
RemediesSM, Berkeley, CA
Jamie Harvie, PE, Institute for a Sustainable
Future, Duluth, MN
Jackie Hunt Christensen, Institute for Agriculture and Trade Policy, Minneapolis, MN
Sarah OBrien, Vermont Public Interest Research Group, Montpelier, VT
Ted Schettler, MD, Science and Environmental
Health Network, Boston, MA
Scott Sederstrom, Great Lakes Center for
Occupational and Environmental Safety and
Health, University of Illinois, Chicago, IL
Laurie Valeriano, Washington Toxics Coalition,
Seattle, WA.
S P E C I A L T H A N K S TO

Laura Brannen, for helping to organize the

document into a more useful format; Stephanie
C. Davis, for supplying her original list of health
care waste disposal technology criteria list; Sarah
OBrien, for supplying criteria for community
concerns; and Jane Williams of California
Communities Against Toxics and Chemical
Weapons Working Group for supplying their
criteria for waste treatment.

Jackie Hunt Christensen

Health Care Without Harm
c/o Institute for Agriculture and Trade Policy
2105 1st Avenue South
Minneapolis, MN 55404
USA
phone: 612-870-3424
fax: 612-870-4846
[email protected] or [email protected]

Medical Waste
Treatment Technologies:
Evaluating Non-Incineration Alternatives

INTRODUCTION

and sharp items such as used needles or scalpel blades.

In general, these items should either be incinerated or
decontaminated prior to disposal in a sanitary landfill.3
The infectious or regulated medical waste stream
accounts for about 15 percent of total hospital waste,
while pathological waste is about two percent. In order
to protect public health, decontamination is required,
but incineration is not a federal legal requirement.
(Individuals should check state and local regulations
regarding pathological waste and chemotherapy drugs.)

Historically, many hospitals with on-site incinerators

burned not only the infectious portion of their waste
stream, but also solid waste and recyclable materials
such as paper and cardboard.1 Public concerns about
incinerator emissions, as well as the creation of federal
regulations for medical waste incinerators, are causing
many health care facilities to rethink their choices in
medical waste treatment technology.
One of the guiding principles of the Health Care
Without Harm (HCWH) campaign is the commitment
to eliminate the non-essential incineration of medical
waste and promote safe materials use and treatment
practices. Regulated medical waste (RMW), also
called infectious waste, requires disinfection prior to
disposal in a landfill. HCWH is committed to helping
hospitals identify the waste considered to be regulated
medical waste in order to minimize the environmental
and human health impacts of treating that waste.

R E V I E W I N G A LT E R N AT I V E S

Waste treatment is but one small piece of a much

larger system of purchasing and materials management that determines the overall environmental and
health impacts of a health care facility. In addition to
regulated medical waste, health care facilities can be
expected to generate recyclable materials, which
may be handled by a single hauler or collected as
individual commodities (e.g., cardboard, aluminum,
glass); food waste, which may be composted or
discarded with solid waste; solid waste, which is
handled like municipal trash; hazardous waste,
which must be handled according to federal regulations; radioactive waste, also subject to federal rules;
and pathological waste (tissue, body parts, etc.) The
types of care the facility provides, as well as purchasing choices (reusable versus disposable items,
packaging), affect the amount and toxicity of the
wastes generated.

The Association of Operating Room Nurses has crafted

a definition of regulated medical waste that includes
four categories of waste: sharps (used and unused),
cultures and stocks of infectious wastes, animal waste
and selected isolation waste.2
According to the Centers for Disease Control and
Prevention, Hospital wastes for which special precautions appear prudent are microbiology laboratory
waste, pathology waste, bulk blood or blood products,

C O N S I D E R AT I O N S F O R M A N AG I N G
H O S P I TA L W A S T E

It seems certain that, given aggressive waste minimization and pollution prevention practices in the health
care facility and the treatment options available that
dont involve combustion, there must be less toxic,
equally cost-effective ways to treat medical waste.
Thus, the Health Care Without Harm campaign decided
to investigate those non-incineration options.

Health care facilities, including hospitals, clinics,

doctors, dentists, morgues, or veterinary offices, generate
a tremendous amount of waste in the course of treating
patients. They generate regulated medical waste or
infectious waste, hazardous chemical waste, recyclable,
reusable and solid waste. In order to fulfill the medical
ethic to do no harm, it is the responsibility of the health
care industry to create and implement waste disposal
polices for all of these waste streams that include worker
safety, public health and environmental considerations,
as well as regulatory compliance. Fulfilling this ethic
also calls for a cultural shift to consider disposal technologies and services as part of a total waste
management system. This system should include
upstream waste management (elimination or minimization of some wastes, reuse and recycling of others) and
the proper, accountable operation of all disposal equipment, post-treatment technology management and
services (e.g., shredding, landfilled material, incineration
ash, air and water emissions).

Non-incineration treatment technologies are a growing

and developing field. Some technologies are still
essentially prototypes, while others, such as autoclave
technology, have been used for decades. Studies are
being done of virtually all the technologies to assess
safety, emissions, ease of operation, and reliability. For
example, the Underwriters Laboratories are creating
safety standards for non-incineration technologies.4
One thing is clear and must always be addressed before
assessing any technology: What goes in, must come
out (or up). Careful waste segregation and management programs, as well as attention to materials
purchased, are essential in minimizing the environmental and health impacts of any technology. These issues
must be included in any analysis of alternatives.
As stated earlier, Health Care Without Harm does not
support the incineration of solid waste or infectious
waste. Infectious waste should not be disinfected or
sterilized in order that it may be sent to a municipal solid
waste incinerator. (For more information about HCWHs
concerns about incineration, see Appendix A.)

In the United States, regulated medical waste about

seven to fifteen percent of the total waste5 must be
treated in order to protect public health from the spread
of potentially infectious diseases. But many facilities,
particularly those with medical waste incinerators onsite, have routinely burned most or all of their waste
(with the exception of hazardous chemicals, which
would be illegal). Incineration, as previously stated, has
significant health and environmental impacts. There are
alternative treatment technologies that render the waste
non-infectious and are believed to be less harmful.

Health Care Without Harm does not

endorse any technologies. We do not
recommend that this checklist serve as
the sole means of evaluating any technology, but instead hope it will be used
to obtain information and to support
informed decision-making.

Furthermore, much of the waste produced in health

care facilities resembles household trash. Therefore, it
is not unreasonable to expect that at least 30 percent of
this waste can be recycled, reused, reduced or eliminated, and up to 50 percent reduction could be achieved
with aggressive actions. Tossing resources in the trash
is not only a waste of resources, but can be extremely
expensive. The economic benefits to managing and
reducing the waste can have a significant benefit to the
health care facilitys overall costs. A case in point: Beth
Israel Medical Center in New York City has found that
a combination of employee education, monitoring of
the waste stream and strategic placement of red bag
waste containers has cut the facilitys medical RMW
disposal costs by 60 percent.6

In order to give full consideration to the effects of the

waste it generates, the health care industry should
reconsider its environmental and waste impacts. These
issues must be included in facility-wide policiesthe
culture around trash and environmental programs must
be institutionalized. Pollution prevention, recycling,
reuse, environmental procurement, safer disposal
choicesthese programs will not only benefit the
environment and the health of the community, but will
provide cost-effective care and instill in healthcare
workers a sense of pride and commitment to the
delivery of effective care while doing no harm.

Using this list: Many of the following

questions are addressed to health
care facility staff who will be involved
in technology selection and possibly
even maintaining and operating the
equipment. However, in discussing
concerns about waste treatment and
disposal, concerned residents are
encouraged to confirm that the
healthcare staff are addressing the
range of the issues mentioned below.

QUESTIONS TO ASK BEFORE

C O N S I D E R I N G A N Y T R E AT M E N T
T E C H N O LO G I E S

The questions can also be used as

an opportunity to bring together
health care decisionmakers and
community members to discuss
which criteria are most important to
their respective constituencies and to
identify areas of common concern or
conflict.

The decision about which medical waste treatment

technology to utilize is a complicated process and goes
far beyond cost considerations.
The following list of questions is designed to help health
care decisionmakers identify criteria to be evaluated and
information needs to be addressed when deciding what
technology and/or disposal services to use.
This checklist may also help to increase overall awareness of environmental, economic and worker safety and
health considerations.

Waste Management in
Health Care Facilities Past, Present and Future

Decisions about the type of waste treatment technology

chosen often have significant impacts on the surrounding community, and the community should be well
informed so that they may participate fully in siting
discussions and technology choices.

W A S T E S E G R E G AT I O N P R A C T I C E S

Properly sizing your equipment has cost, labor, facility

and operational implications. If you size your equipment prior to waste segregation and minimization
activities, you may purchase more capacity than you
need. Consider your current practices. If significantly
more than 15 percent of your facilitys waste is considered regulated medical waste, you may have
opportunities for reductions.

The objective of this checklist is to provide a basic set

of questions that should be considered. The health care
facility or community might have specific issues that
these criteria do not address.

Has your facility done a comprehensive audit of all

of the various waste streams and products/supplies
purchased to better identify impact on disposal
systems and services?

Can your facilitys waste streams be separated by

type (e.g., corrugated cardboard, office paper,
aluminum cans, food waste)? Have the volume
and weight of each waste stream been measured or
estimated?

Can your facilitys staff identify from which

departments or areas of the facility certain types of
waste are more common? And which have the
greatest potential for reduction or elimination?

Most facilities undertaking a comprehensive approach

to managing their waste have an infrastructure to
facilitate the program.

Has your facility considered a facility-wide

computerized tracking system to help identify
waste streams and assist in the waste segregation
program?

Are all employees trained to identify infectious and

hazardous materials and dispose of them according
to safety and disposal regulations?

Does your facility use mercury-containing products? If so, what steps are being taken to ensure
that mercury is not being disposed with infectious
or solid waste?

Does your staff know the procedures for handling

and disposal of low level radioactive wastes? Do
the loading dock and/or packaging areas have
functioning equipment to detect, prior to disposal,
any low-level radioactive wastes (LLRW) that were
discarded?

Does your facility have a recovery program for

utensils and surgical instruments? (Loss of these
items can be a substantial annual avoidable cost.
Some waste companies can provide this additional
recovery and sterilization service.)

O R G A N I Z AT I O N A L / S TA F F I S S U E S

Does your facility have or plan to implement

aggressive waste and pollution prevention, reuse
and recycling programs as part of this process?
This includes defining waste streams, providing
clearly designated waste containers and signage for
different waste streams, and educating staff on the
proper waste segregation.

Has a task force been identified in your facility to

examine current waste treatment and disposal
technologies and become informed, in-house
experts on available options? Are members of the
following departments represented: administration,
infection control, engineering, health and safety,
laboratory staff, physicians, nursing, housekeeping
and environmental services, procurement/ contracts/ purchasing, and union representatives?

What education needs to happen to change historical or cultural habits for current disposal systems
and waste services?

What level of commitment is your facility willing to

undertake to ensure all parameters will be considered?

F AC I L I T Y A N D O P E R AT I O N A L I S S U E S

The type of treatment technology chosen will most likely

affect current practices and procedures in your facilitys
waste management operations. This includes labor
considerations, waste handling practices, implications on
physical space, loading docks, all utility costs, trucking
and transportation. The decision to go with on-site or offsite treatment involves at least some of the considerations listed below. Questions listed under on-site
treatment should also be asked of your off-site treatment
vendors. Some issues are joint considerations.

Does your facility currently have the labor and staff

expertise to maintain the equipment, or would
additional training be needed?

Does your facility have the physical space and

adequate facility design? (e.g., if you are using
offsite treatment, is your facility already equipped
with adequate storage space, loading docks, etc.?)

Are off-site treatment options limited, expensive or

does your facility have concerns about the local
options? (e.g., the local commercial treatment facility
has numerous emissions violations; your hospital/clinic
is in a rural area and the nearest commercial
treatment facility is hundreds of miles away.)

Cost

Does your facility have a battery recovery program?

O N - S I T E T R E AT M E N T
T E C H N O LO GY I S S U E S

How important is volume reduction in choosing a

technology? What is the ratio of waste produced by
your facility to the waste treated by the treatment
technology? Is the technology dependent on a
certain volume of material?

How would waste reduction programs affect the

process? If the waste volume changes radically for
any reason (e.g., reduced patient-days, merger,
better waste minimization efforts), will this
technology still meet the treatment needs?

Have staff from your facility talked to colleagues at

other facilities about their disposal options, made
comparisons, discussed technologies, contracts and
services, as well as violation histories and ranges
of service costs?

What is the local and state regulatory climate for

onsite treatment technologies? (Some types of
technologies require more complicated permits
than others. Incinerators typically have more
complexand thus expensivepermits than most
autoclaves, as an example). Does your facility have
staff on-site who are trained and certified to fulfill
the testing requirements, time, etc., involved in
these permits? If not, consider those staffing and
testing costs in your evaluation.

What is the estimated life of this equipment?

What volume of waste can the technology treat?

Will it always be operating at peak capacity, or will
there be wide variations in the amount of waste
treated?

What are the operational cost implications of using

this technology? What are the environmental and
fiscal impacts of utilities usage (electricity, water
and sewer)?

What is the safety and repair history of the waste

disposal equipment?

What worker safety and ongoing equipment

education is required and who provides it?

What are the cost(s) of equipment failure and need

for a back-up or alternative system?

Is waste fed into the treatment system automatically (by machine) or by hand (stop feed)? What
impact does this have on your facilitys staff
limitations?

Can equipment repair be completed within 24

hours without an emergency clause and/or additional costs?

Does the technology require ancillary equipment

such as shredders? Are they an integral part of the
treatment process? Does the landfill require them?
What are the total associated costs for this equipment? Are there any worker-safety concerns with
this equipment?

How is the volume and weight of the waste

measured with the disposal equipment? Who
measures it? Is it cost-effective to weigh the wastes
on-site?

MANAGEMENT OF SHARPS
AND SPUTUM CANISTERS

How long has the treatment technology been in

use, and where? Has your facilitys staff researched
the various vendors within a type of technology
(e.g., autoclaves, microwaves, chemical treatment)?
Will the vendor give you a list of references to
contact?

How are sharps treated in your facility? Has your

facility considered a sharps container reuse
program? How would this impact the disposal
system? How does the waste treatment technology
your facility is considering handle sharps?

How are sputum canisters treated in your facility?

How does the waste treatment technology your
facility is considering handle them?

O F F - S I T E T R E AT M E N T I S S U E S
( C O M M E R C I A L T R E AT M E N T FAC I L I T I E S )

What are the line-item transportation costs for

intra- or interstate taxes, tipping fees, etc?

How many trucks will enter and leave the facility

daily? Will traffic vary by day of the week, or
remain fairly constant?

From what geographic area will waste be accepted? What sort(s) of waste?

Is it possible to bargain collectively with area

healthcare facilities for RMW treatment waste
disposal services?

Are there any violations against the treatment site

your facility is considering? Is that facility fully
permitted? Are there any community concerns
about the facility?

Supply costs - personal protective equipment, spill

supplies, special bags (for example, some autoclave systems require particular bags), collection
containers (boxes or reusable containers);

Have staff from your facility or a contracted

consultant visited the waste treatment site for a
comprehensive audit and evaluated environmental
health and safety and operational issues?

Indirect costs/benefits - community satisfaction,

environmental leadership.

Are there any community or environmental health

concerns associated with this off-site facility? If so,
in what ways could the health care facility facilitate
positive changes and reconciliation of those concerns?

E N V I R O N M E N TA L A N D E T H I C A L
AND COMMUNITY ISSUES

What are the organic and inorganic emissions to

the environment and to what media (air, water,
land)? Dioxin and mercury are examples of such
emissions. In what volume are these pollutants
released?

There are cost issues associated with every type of

treatment technology. When summarizing cost implications for each treatment and disposal option, also
consider the following issues:

Which emissions are regulated and by which

authorities? (Local, state or federal regulators may
monitor different pollutants. Total emissions of any
pollutant should be considered, not only releases to
one medium, such as air.)

Capital equipment costs;

Installation and facility costs: installation labor,

facility modifications - cement pad(s), curb cuts,
sewers, electricity, space, security, etc.;

Direct labor costs: number of employees needed to

operate the RMW treatment and disposal equipment;

Of the emissions that have been identified, which,

if any, are harmful to human health or the environment? What are those effects (such as cancer,
hormone disruption, reproductive effects or
cumulative impacts)?

Down time costs: including repair (parts and

labor), and alternative treatment;

What is the reputation and reliability of the waste

disposal company, and/or treatment technology?

Should facility waste be disposed outside of the

city/county/state in which it is generated if there is
an economical alternative?

What opportunities have been provided for community input into the waste treatment decision
process?

Does the treatment process produce odors? Has the

facility documented all available options to reduce
odors and related complaints?

How many years is the facility scheduled to

operate?

How will the surrounding community be informed

of any accidents or emissions violations from the
treatment facility?

Will the facility increase traffic in the neighborhood (e.g., through trucks hauling waste,
chemicals, etc.)?

COST

Utility costs;

Permitting and compliance fees: water and air

testing fees should be included in annual operating
costs. For comparison purposes, testing fees for
incinerator ash should be included;

Fines: depending upon permitting requirements

and state and federal regulations, violations of
permits or emissions may result in fines;

Compare cost per-ton of disposal for each technology under consideration. If your facility is
currently using on-site or off-site incineration, be
sure to include ash disposal in your estimate of
current costs to contrast with potential future costs
of new technology. Regular testing of incinerator
ash may designate periodic loads to be hazardous
and must be sent out as hazardous waste. Estimate
at least an annual occurrence;

All transportation, processing and tipping fees;

Is the technology noisy (for workers as well as the

community), and how is this defined and documented?

Is a permit for the treatment facility issued only

once, or is it periodically reviewed, with opportunity for renewed public input?

What are the zoning issues related to the project?

Are there other facilities in the community or

neighborhood that pose the same or similar
problems as those of the proposed treatment
technology?

If chemicals are used to treat the waste, are they

hazardous by themselves? If so, what are the
potential health and environmental impacts for the
workers and the community? Does someone in
your facility know what potential reactions may
occur from a combined mix of facility wastes and
sewer disposal wastes?

Does the production of any chemical required by

the treatment process have harmful environmental
or health impacts?

Does the treatment process release radioactive

isotopes? If so, how are those isotopes contained?

REGULATORY AND COMPLIANCE ISSUES

VENDOR ISSUES

What permits does the technology require in order

to operate?

Does the vendor (of the equipment or waste hauler)

or any of its subsidiaries or contractors have any
violations (environmental, criminal, etc.)? If so,
how have those violations been handled?
Is the vendor willing to meet with your facilitys
staff committee to answer specific questions about
the equipment and technology?

Is a public hearing required?

Does everyone working on waste issues in the

facility know the pertinent federal, state, county or
city regulations and are they working to maintain
compliance?

What pollution control equipment is required for

this technology? Is there additional equipment that
is available to reduce environmental emissions?
What equipment will be used to monitor emissions,
and how often?

C O N T R AC T I S S U E S

Can the facility and surrounding communitys

sewer or septic system handle the waste treatment
equipments discharges?

Has someone at your facility estimated the cost(s)

associated with environmental, health and safety
violations related to prospective waste disposal
equipment?

What are the estimated costs for emissions testing,

liability, violations and clean-up?

Has your facility reviewed current contracts,

whether in a Group Purchasing Organization
(GPO) or not, to better understand disposal options, obstacles and potential discussion areas from
a waste and energy perspective?

Has your facilitys staff discussed the length of

contract that best suits your needs? How does that
compare with the contract being offered?

What is the waste management plan/back-up

service option for down times? Is there an extra
fee, or is it part of the contract?

Have current waste service contracts been reviewed

and rewritten for educational, health and safety
standards, and to maximize reuse, recycling, and
recycled-content?

What contract constraints are negotiable in order to

get the best equipment and services for your facility?

What is the length of the contract? Is it a put or

pay contract, (i.e., one that guarantees the health
care facility will supply a certain amount of waste
or pay to make up the difference)?

H A Z A R D O U S W A S T E M A N AG E M E N T

What residuals (waste still left after treatment)

remain when the treatment process is complete?
Can all potential residuals be fully identified before
disposal? Will any require treatment as hazardous
waste? What are the estimated costs associated
with this disposal? What is the liability attached to
this residual waste?

Please keep in mind that there may be additional

issues that are not raised here but may be very
important to your health care facility or your community. These questions are meant to help people

identify and prioritize issues of concern, as well as to

stimulate the collection and release of new data
about non-incineration technologies to the health
care industry and the public.

REFERENCES
5

Greening Hospitals: An Analysis of Pollution Prevention in

Americas Top Hospitals, Environmental Working Group/Health
Care Without Harm, June 1998, based on Rutala, W.A. and C.G.
Mayhall, Society for Hospital Epidemiology of America position
paper. Infection Control and Hospital Epidemiology 13:38-48.
1992; and personal communication with Hollie Shaner, Fletcher
Allen Healthcare, VT and Laura Brannen, Dartmouth-Hitchcock
Medical Center, NH.

Dwain Winters, USEPA Dioxin Policy Project, Binational

Toxics Strategy Dioxins/Furans Work Group conference call,
October 5, 1999.

Association of Operating Room Nurses, Inc., AORN Position

Statement, Regulated Medical Waste Definition and Treatment:
A collaborative document, in Standards, Recommended
Practices and Guidelines (Denver: Association of Operating
Room Nurses, 1998) 113-116.

Brown, Janet, 1993. Hospital Waste Management that Saves

Money and Helps the Environment and Improves Safety.
Medical Waste: The Environmental Publication for the Healthcare Industry. 1(10), July, 1993 and personal communication
with Janet Brown, as cited in Greening Hospitals.

Infectious Waste factsheet. Hospital Infections Program,

National Center for Infectious Diseases, Centers for Disease
Control and Prevention. Atlanta, GA. Updated: January 21,
1997. http://www.cdc.gov/ncidod/diseases/hip/waste.htm

Standard of Safety for Alternative Technologies for the

Disposal of Medical Waste - UL 2334, http://www.ul.com/eph/
medwaste.htm

10

APPENDIX A

Why is Health Care Without Harm Opposed to Incineration?

e have several concerns regarding the burning of

waste generated by health care (both solid waste
and regulated medical waste).

children exposed in utero during critical periods of

development appear to be the most sensitive and
vulnerable to the effects of dioxin.4 Dioxin exposure
has been linked to disrupted sexual development, birth
defects and damage to the immune system. Specifically, dioxin has been associated with IQ deficits,
hyperactive behavior and developmental delays.5 , 6

Incineration produces both toxic air emissions and

toxic ash residue.1 The air emissions affect the
local environment, and in many cases, may affect
communities hundreds or thousands of miles away.
The ash residue is sent to landfills for disposal,
where the pollutants have the potential to leach into
groundwater. (It must be noted that waste treated
by other methods and then landfilled will also
produce leachate.)

In addition to releasing the pollutants contained in

the waste stream to the air and into the ash, burning
medical waste actually creates new toxic compounds, such as dioxins.

Medical waste incineration has been identified by the

U.S. Environmental Protection Agency as the third
largest known source of dioxin air emissions,2 and
contributes about 10 percent of the mercury emissions to the environment from human activities.3

Many, if not most, on-site medical waste incinerators burn not only infectious waste, but also readily
recyclable items such as office paper and cardboard. This destroys resources and prevents cost
savings that could be recouped through recycling.

The International Agency for Research on Cancer

(IARC), an arm of the World Health Organization, last
year acknowledged dioxins cancer-causing potential
when they classified it as a known human carcinogen.7
The U.S. Environmental Protection Agency (EPA) has
determined that most Americans are exposed to dioxin
through ingestion of common foods, mostly meat and
dairy products. Dairy cows and beef cattle absorb
dioxin by eating contaminated feed crops. The crops
become contaminated by airborne dioxins that settle
onto soil and plants. Dioxins enter the air from thousands of sources including incinerators that burn
medical, municipal and hazardous waste.8

MERCURY

Mercury is a potent neurotoxin, which means it attacks

the bodys central nervous system; it can also harm the
brain, kidneys and lungs. It can cross the blood-brain
barrier as well as the placenta. Mercury poisoning can
cause slurred speech, impaired hearing, peripheral
vision and walking, muscle weakness, mood swings,
memory loss and mental disturbances. The risks of
damage to the nervous systems of developing fetuses
and young children are primary reasons for fishconsumption advisories, aimed at discouraging
pregnant women, women of child-bearing age, and
young children from eating too much fish. Studies done
on women who ate methylmercury-contaminated fish
or grain showed that even when the mothers showed
few effects of exposure, their infants demonstrated
nervous-system damage.

Medical waste incinerations identification as a

primary source of some very toxic pollutants
stands in direct contradiction to physicians oaths
to do not harm.

D I OX I N

Dioxin belongs to a family of 419 chemicals with

related properties and toxicity, but the term dioxin is
often used to refer to the 29 that have similar toxicity.
Dioxin is one of the most toxic chemicals known to
humankind. While exposure of the general population
occurs through the ingestion of many common foods,

If mercury-containing items are put into a red bag for

infectious waste and sent to an incinerator, mercury

11

will contaminate the air. (This can happen with nonincineration technologies as well. If mercury goes into
treatment equipment, it will come out.) Airborne
mercury then enters a global distribution cycle in the
environment, contaminating fish and wildlife.

arsenic, ammonia, benzene, bromodichloromethane,

cadmium, carbon tetrachloride, chromium,
chlorodibromomethane, chloroform, cumene, 1,2dibromoethane, dichloromethane, dichloroethane, ethyl
benzene, lead, mesitylene, nickel, particulate matter,
naphthalene, tetrachloroethane, toluene,
trichloroethane, 1,1,1-trichloroethane, trichloroethylene, trichloromethane, vinyl chloride, and xylenes.9
Analysis of emissions of other treatment methods is
necessary to determine if these emissions occur in the
absence of combustion.

O T H E R H A Z A R D O U S P O L LU TA N T S

Many other hazardous pollutants have been identified

in the emissions from medical waste incinerators:

REFERENCES (FOR APPENDIX A)

1

Issues in Medical Waste Management Background Paper,

Office of Technology Assessment, Congress of the United States,
OTA-BP-O-49, October, 1988.

5
Workshop[s] on Perinatal Exposure to Dioxin-like Compounds. I-VI. Summar[ies], Environmental Health Perspectives
Supplements, Vol. 103, Supplement 2, March 1995.

6
Health Assessment Document For 2,3,7,8-Tetrachlorodibenzo-PDioxin (TCDD) And Related Compounds, Vol. 1 of III, and Vol. II
of III, USEPA, Office of Research and Development, EPA/600/
BP-92/001b and EPA/600/BP-92/001c, external review draft; and
Devito, M.J. and Birnbaum, L. S. (1994) Toxicology of dioxins
and related chemicals. In Dioxins And Health, Arnold Schecter,
ed., NY: Plenum Press, 139-62, as cited in Dying From Dioxin: A
Citizens Guide To Reclaiming Our Health And Rebuilding
Democracy, Gibbs, L.M. and the Citizens Clearinghouse for
Hazardous Waste, Boston: South End Press, 1994, pp. 138-139.

Inventory of Sources of Dioxin in the United States (EPA/600/

P-98/002Aa), National Center for Environmental Assessment,
USEPA, April 1998, p. 2-13.
3

Mercury Study Report to Congress, Volume I: Executive

Summary, USEPA Office of Air, December 1997. p. 3-6

Pluim, HJ, Koope, JG, Olie, K., et al. 1994. Clinical

laboratory manifestations of exposure to background levels of
dioxins in the perinatal period. Act Paediatr 83:583-587;
Koopman-Esseboom C, Morse DC, Weisglas-Kuperus N, et al.
1994. Effects of dioxins and polychlorinated biphenyls on
thyroid hormone status of pregnant women and their infants.
Pediatr Res 36: 468-473; Pluim HJ, de Vijlder JJM, Olie, K, et
al. 1993. Effects of pre- and postnatal exposure to chlorinated
dioxins and furans on human neonatal thyroid hormone
concentrations. Environmental Health Perspectives 101: 504508; Weisglas-Kuperus N, Sas TCJ, Koopman-Esseboom C, et
al. 1995. Immunologic effects of background prenatal and
postnatal exposure to dioxins and polychlorinated biphenyls in
Dutch infants. Pediatr Res 38: 404-410; Huisman M,
Koopman-Esseboom C, Fidler V, et al. 1995. Perinatal
exposure to polychlorinated biphenyls and dioxins and its
effect on neonatal neurological development. Early Human
Development 41: 111-127.

T: 703.237.2249

7
IARC Evaluates Carcinogenic Risk Associated with Dioxins,
International Agency for Research on Cancer press release,
February 14, 1997.
8
Estimating Exposure To Dioxin-Like Compounds, Volume I:
Executive Summary, USEPA, Office of Research and Development, EPA/600/6-88/005Ca. June 1994 review draft, p. 36.
9

Draft Technical Support Document To Proposed Dioxins And

Cadmium Control Measure For Medical Waste Incinerators
California Air Resources Board, 1990, pg.51, as cited in
Medical Incinerators Emit Dangerous Metals And Dioxin, New
Study Says, RACHELS ENVIRONMENT & HEALTH WEEKLY
#179, May 2, 1990.

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