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Statement
by GAIA, HCWH and BAN
on IFC
Environmental, Health and Safety Guidelines for Health Care
Facilities
Letter
to IFC
18 March 2002
Dr.
Rosa Orellana
Environmental Specialist
International Finance Corporation
2121 Pennsylvania Ave NW
Washington, DC 20433
RE:
Health Facilities: Health Care Waste Management Guidance
Document
Dear
Dr. Orellana:
We have appreciated the opportunities that you have afforded
us to participate in and comment on the process to produce
the IFC guidance document on Health Care Waste Management.
The final document should provide much needed support to IFC
and other institutional personnel working on this issue and
some structure within which to make good decisions that protect
workers, the public and the environment.
In reviewing the draft document we wish to congratulate the
authors on the attempt to provide a succinct overview that
challenges project personnel to acknowledge the very serious
hazards in managing health care wastes (especially those beyond
biohazard/infectious waste), and provide guidance on establishing
plans and programs to mitigate those hazards. The emphasis
on segregation as the essential strategy to minimize the hazardous
portion of the waste stream, and the multiple referrals to
pollution prevention through product elimination or substitution
is also an important contribution to making new health projects
safer to workers, patients and the public. As you know from
a review of the materials that we have shared with you in
the past these are the essential principles through which
we work with health sector projects.
Last year we shared six principles that our coalitions would
like to see reflected in the IFC's guidelines:
1)
Emphasis on Pollution Prevention
2)
Waste Minimization and Segregation
3) Mercury Elimination
4) Non-Combustion Treatment Technologies
5) Community Right-to-Know and Right-to-Consultation
6) PVC Elimination
For
the most part we find that there has been effort to accommodate
these areas in the IFC draft. There are however a series of
issues,
that if addressed, we believe will strengthen this document
by both creating greater internal consistency and taking advantage
of field
experience in health care waste management in facilities in
a number of countries that we have had experience with. The
IFC document
relies significantly on the WHO manual Safe Management of
Wastes from Healthcare Activities. This 1999 publication is
in need of updating according to the authors. There is also
a heavy reliance on European and United States specific sources,
that are applicable for broad standard setting (e.g., best
standards for air emissions standards) but are less helpful
in terms of specific approaches to management.
There are two memos attached to this letter that address a
series of specific points in the document that we hope you
will find
of help in the final revisions, and seriously consider during
your process of finalizing them. The first memo outlines specific
points
section by section with a focus on management. The second
memo is focused on emissions limits that were utilized to
govern incinerator
operations.
Together these memos detail our concerns that are summarized
as follows:
1.
Mercury: There is no mention in the document of mercury. Given
the global concern around mercury pollution from health care
institutions, the prevalence of mercury within such institutions
and the special handling that mercury requires, we find this
omission
particularly surprising. We recommend including a statement
of intent to minimize, properly handle and eventually eliminate
mercury
use in health care institutions. This could be incorporated
in a general statement under "Philosophy" about
the elimination of
hazardous materials including PVC. The Health Care Waste Management
Plan should also include special provisions for handling and
storing mercury and mercury-contaminated wastes.
2.
Incineration: As we have previously stated, incineration as
a treatment technology (often confused as a disposal method)
is a substandard process that globally has caused far more
harm than it has prevented. Minimizing and then eventually
eliminating incineration should be the long term goal of any
initiative, whether it is evaluated through a risk prevention,
environmental health, worker safety, or economic standard.
In addition, the standards selected for emission controls
are based on erroneous interpretations of the least strict
guidelines from the USA and EU. While the IFC phases out its
funding of incinerators, it should insist upon emissions standards
that are at least as stringent as US and EU levels. This is
the subject of the attached second memo.
3.
Waste categorization: The categorization of wastes (introduction
and in Tables 1 and 2) is not consistent, and is constructed
in a
manner that does not lend itself to being applied in a management
framework. These issues are covered in the first attached
memo.
4.
Chemical waste minimization: There is little discussion about
the need for minimization of chemical use, and the proper
handling and
disposal of these chemicals. Currently, they are typically
either discharged to the sewer or sent out for incineration
in technologies
not designed for hazardous chemical wastes. This area tends
to be the weakest link in most international documents addressing
health
care waste. While management of Infectious Wastes is based
on a perception of the possible risk present in those wastes,
the management of chemical wastes must be based on the very
real knowledge of the dangers inherent in these materials,
many of which are toxic and genotoxic.
5.
Occupational safety and health: The focus on worker safety
and health issues is laudable. Additional attention should
be given to
the monitoring and safety concerns of workers regularly exposed
to hazardous chemical substances, whether in the lab working
with
solvents and formaldehyde, or among incinerator or other treatment
technology operators.
6.
Community involvement: Again this is a particularly good addition.
Much of what we have observed about health care waste
management programs in different countries that is positive
has resulted from an open process between the institution
and its
neighbors, educating the public about the reality of health
care wastes (e.g., most of it is safe general trash), and
the ways in
which the institution will operate to minimize the risks associated
with the small amount of hazardous wastes.
These key points are further elaborated in the attached memos
that we hope will provide some valuable assistance in the
final development of the document. We would be happy to discuss
any of these points with you, or provide you with additional
materials
if they would be of value.
This
letter has been written on behalf of four international coalitions:
Health Care Without Harm, the Global Alliance for Incinerator
Alternatives, and the Basel Action Network.
Health
Care Without Harm is a collaborative campaign for environmentally
responsible health care made up of more than 350 organizations
in 38 countries. Its mission is to transform the health care
industry so it is no longer a source of environmental harm
by eliminating pollution in health care practices without
compromising occupational safety or patient care.
The Global Alliance for Incinerator Alternatives is a growing
international alliance of individuals, non-governmental organization,
community-based organizations, academics and others working
to end the incineration of all forms of waste and to promote
sustainable waste prevention and discard management practices.
GAIA comprises over 200 members from 54 countries.
The
Basel Action Network (BAN) is a global alliance of activist
organizations dedicated to halting the proliferation of trade
in toxic waste, toxic products and toxic technologies. BAN
has been active in helping shape the Basel Convention's guidelines
on the environmentally sound management of health care wastes.
Sincerely,
Jim
Puckett
Coordinator, Basel Action Network
Ann
Leonard
Co-coordinator, Global Alliance for Incinerator Alternatives
Charlotte
Brody, RN
Executive Director, Health Care Without Harm
cc: IFC Executive Directors
Ron Anderson, IFC
Josefina Doumbia, IFC
Rob Horner, IFC
Yasmin Tayyab, IFC
Rachel Kyte, IFC
Steve Gorman, World Bank
Ellen Tynan, World Bank
Graham Saul, BIC
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