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MEMORANDUM of UNDERSTANDING

Between the United States Environmental Protection Agency and the American Hospital Association

Pollution Prevention and Waste Reduction in Health Care Facilities

On June 24, 1998 the U.S. Environmental Protection Agency and the American Hospital Association signed an agreement for voluntary cooperation toward the goals of reducing waste volumes and toxicity coming from health care facilities. The Purpose and activities of this understanding are included in the text below. The full text of the agreement can be viewed at:

http://www.epa.gov/toxteam/ahamou.htm

PURPOSE

The AHA consists primarily of health care provider organizations across the United States. The Parties enter into this MOU for the primary purpose of transferring to AHA institutional members, PMG personal members and other health care professionals technical information on Pollution Prevention ("P2") opportunities that exist with respect to waste generated by the health care industry. The Parties' believe that this information transfer will provide the health care industry with enhanced tools for minimizing the production of persistent, bioaccumulative and toxic ("PBT") pollutants and reducing the volumes of waste generated. Such reductions are beneficial to the environment and will reduce the waste disposal costs incurred by the health care industry. The Parties to this MOU hereby affirm the Congressional goals and principles set forth in the Pollution Prevention Act ("PPA"), 42 U.S.C. 13101 through 13109, particularly the goal of reducing the generation of pollution at its source, preferentially to the recycling, treatment and/or disposal of such waste.

The Parties intend to undertake the following activities pursuant to this MOU:

  1. Virtual Elimination of Mercury Waste. The Parties intend to work together to develop a Mercury Waste Virtual Elimination Plan that will set forth a strategy for achieving the goal of virtually eliminating mercurycontaining waste from the health care industry waste stream by the year 2005.
  2. Total Waste Volume Reduction. The Parties intend to work together to develop a Model Waste Volume Reduction Plan that will assist in reducing the total volume of all wastes (including both regulated and nonregulated waste) generated by the health care industry, with an initial goal of achieving a thirty-three percent (33%) reduction in all hospitals by 2005 and an overall goal of achieving a fifty percent (50%) reduction by 2010.
  3. Seminars. The Parties intend to co-sponsor a series of Health Care Industry Waste Management Seminars ("Seminars") to be held at various locations across the United States. The Seminars will be the primary vehicle by which technical information on P2 opportunities will be transferred to the health care professionals, and will focus upon transferring technical information related to decreasing health care industry waste volume, minimizing the production of PBT pollutants, improving waste stream segregation, reducing waste management costs and ensuring regulatory compliance for regulated waste streams.
  4. Software Distribution. In order to facilitate the successful completion of the Seminars and the virtual elimination of mercury-containing waste, U.S. EPA intends to provide for distribution at the various Seminars up to 300 copies of the software program entitled "Mercury In Medical Facilities" that has been developed by Purdue University with assistance from the Region 5 Software Development Unit ("SDU"). Purdue University maintains a copyright on this software program, but, insofar as the software was developed with Federal Government assistance, the software may be freely copied and disseminated. The Parties will mutually decide how the up to 300 total software copies will be distributed among the various Seminars.
  5. Industry P2 Information. AHA intends to develop baseline information on the P2 activities of the health care industry and to monitor P2 progress over time. To obtain this information, AHA will develop, with review and comment by U.S. EPA, an information questionnaire to be distributed to health care professionals by AHA at various times in the future. The first distribution will be used to determine the baseline P2 information and subsequent distributions will be used to monitor industry P2 progress. AHA will gather all responses to the questionnaires. Insofar as U.S. EPA will not be sponsoring the distribution of the questionnaire, the distribution of the questionnaire is not subject to the requirements of the Paperwork Reduction Act ("PRA"), 44 U.S.C. 3501 through 3520.
  6. Review of Industry P2 Information. Throughout the duration of this MOU, the Parties intend to work together to review and compile the information obtained from the baseline and progress questionnaires (Item #5). U.S. EPA agrees that, unless required by law, the identity of any survey participant need not be revealed by AHA to U.S. EPA. From this information, the Parties will be able to disseminate more effectively P2 information and to monitor the success of the Mercury Waste Virtual Elimination Plan (Item #1) and the Model Waste Volume Reduction Plan (Item #2).
  7. Chemical Waste Minimization. The Parties intend to work together to develop, for various kinds of chemical waste, a Model Chemical Waste Minimization Plan ("Model Plan"). The first Model Plan will pertain to mercury-containing waste ("Model Plan For Mercury"). The Model Plan For Mercury is presently being developed by the State of Illinois with assistance from U.S. EPA. When that plan is completed, U.S. EPA, with comments from AHA, will make such modifications to the Model Plan For Mercury as are necessary to reflect current knowledge, best management practices and any other circumstances experienced by the health care industry. Other chemical wastes will be addressed by future Model Plans. AHA intends to disseminate each Model Plan to as wide an audience in the health care industry as is reasonably possible. Both AHA and U.S. EPA intend to make each Model Plan available to the public on their respective Internet home pages. Each such Internet presentation shall properly reflect the relative contributions of the Parties and any third party (such as theState of Illinois with respect to the Model Plan For Mercury) to the development of the particular Model Plan.
  8. Ethylene Oxide and PBT Pollutant Information. The Parties intend to work together to investigate P2 opportunities with respect to ethylene oxide and PBT pollutants.
  9. Industry Input on U.S. EPA Guidance. To the extent feasible and practical, U.S. EPA will solicit comments by AHA and the AHA Environmental Leadership Council (as established pursuant to this MOU) on U.S. EPA's policies and technical guidance specifically affecting the health care industry's waste streams. AHA's comments will be limited to the practicality and feasibility of the matters set forth in the policies and technical guidance. Such input shall not be sought with respect to any adjudication or any rulemaking that is subject to the noticeandcomment requirements set forth in the Administrative Procedure Act ("APA") at 5 U.S.C. 553(b).
  10. AHA Environmental Leadership Council. AHA will develop an AHA Environmental Leadership Council ("the Council") that will be responsible for making recommendations to the AHA on educational and outreach activities, recommending content experts to participate in programs and/or the development of products such as the Model Plans, monitoring progress toward established environmental goals, selecting the award recipients for national recognition programs, and assisting in the publication of an annual report documenting the hospital industry's progress toward P2.
  11. Awards/Recognition. The Parties intend to work together to determine national "success stories" of the implementation of P2 activities toward health care industry waste generation. Successful P2 activities shall be recognized by awards or other recognition by U.S. EPA, AHA and/or the Parties acting jointly.

CONTACT

For the AHA:

Katherine Svedman
Executive Director
American Society for Healthcare Environmental Service
American Hospital Association
One North Franklin
Chicago, Illinois 6060
Phone: (312) 422-3860
FAX: (312) 422-4571
ksvedma1@aha.org

For the U.S. EPA:

Christine Urban
Watershed Technical Team Manager
Water Division
77 West Jackson Boulevar
U.S. EPA, Region 5 (WT-16J)
Chicago, Illinois 60604-3590
Phone: (312) 886-3493
FAX: (312) 886-7804
urban.christine@epa.gov

Marsha Coleman Adebayo
Special Assistant to the Director
Office of Pollution Prevention and Toxics
Office of Prevention, Pesticides And Toxics (7401)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Phone: (202) 260-2326
FAX: (202) 260-0575
coleman-adebayo.marsha@epa.gov

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