Environmental Compliance, Pollution Prevention and JCAHO

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Environmental Compliance, Pollution Prevention
and JCAHO

• Catherine Zimmer, BSMT, MS
• MnTAP Healthcare Specialist
• Northwest Healthcare Pollution Prevention
  Conference, Boise, ID
• October 28, 2004

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Overview

• Hazardous Waste Regulations
• Beyond Compliance with Pollution Prevention
• JCAHO Standards
• General
• Environment of Care (EC)
• Leadership
• Performance Improvement
• H2E Goals
• Using H2E to meet JCAHO exceed Regulations

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Why Reduce Waste?

• Management of waste is difficult
• Healthcare multiple waste streams
• Labor intensive
• Risk
• Waste is really lost resources
• Natural, time and money
• Waste pollutes air, land and water
• Incineration
• Dioxins, mercury, acid gases, particulate, sulfur
  and nitrous oxides
• Landfill
• Loss of land and habitat
• Leachate
• Heavy metals, solvents, chlorinated compounds.
• Sewer
• Many chemicals not treated at the plant
• End up in lakes, rivers, streams, oceans.

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What is Pollution Prevention (P2)?

• Waste Management Hierarchy
• Source Reduction Waste volume or the toxicity
  of the waste should be prevented at the source
  whenever feasible.
• Reuse through Remanufacture or Recycling- Waste
  that cannot be prevented should remanufactured or
  recycled.
• Treatment Waste that cannot be prevented,
  reused, or recycled should be treated in an
  environmentally sound manner.
• Disposal Waste disposal or other release into
  the environment should be employed only as a last
  resort, and such activity should be conducted in
  the most environmentally safe manner possible.
• adapted from EPA definition established in the
  Pollution Prevention Act of 1990.

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More About Pollution Prevention

• Source Reduction
• Using items that dont create waste. Or using
  items that reduce the toxicity of the waste.
• Reusable containers
• Reusable packaging
• Minimizing the amount used
  or not using it at all (energy,
  water)
• Substituting a non-chlorinated
  product for chlorinated.

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Recycling is not Source Reduction

• Glass bottle reused
• is cleaned and refilled for reuse.

• Glass bottle recycled
• glass is cleaned
• melted
• mixed with new glass
• formed into new bottle.

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Recycling better than Disposal

• If an item is not reusable
• choose items that are recyclable
• back into the original item
• into another item
• paper
• cardboard
• metal aluminum cans
• glass containers
• most plastic
• not recycled back into original item
• Close the loop
• Buy Recycled

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What is the Joint Commission for the
Accreditation of Healthcare Organizations
(JCAHO)?

• Accrediting agency for the healthcare industry
• Accreditation in lieu of licensure by state or
  federal government
• Required for Medicare/Medicaid reimbursement
• Goal to ensure appropriate planning, procedures,
  processes policies are enacted improved upon.

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JCAHO Standards

• Leadership (LD)
• Patient Rights Organizational Ethics (RI)
• Assessment of Patients (PE)
• Care of Patients (TX)
• Education (PF)
• Continuum of Care (CC)
• Improving Organization Performance(PI)
• Management of the Environment (EC)
• Management of Human Resources (HR)
• Management of Information (IM)
• Surveillance, Prevention Control of Infection
  (IC)
• Governance (GO)
• Medical Staff (MS)
• Performance Measurement (PM)

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JCAHO Process

• Surveys
• reviews records and documents
• interviews staff patients
• observation
• interviews leadership
• information from public
• tracer
• Surveyors doctors, administrators, nurses,
  engineers

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Environment of Care (EC) Standard Areas

• Safety (General Staff)
• Security
• Hazardous Materials and Waste
• Emergency Management
• Life Safety
• Medical Equipment
• Utility Systems

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Environment of Care Standards EC. 1.10 Safety

• EC.1.10 The organization manages safety risks.
• EP 1 written management plan describing how it
  manages environmental safety
• EP 2, 3 safety coordinator with authority
• EP 4 conduct a proactive risk assessment
• EP 5 procedures designed to minimize risk
• EP 6 safety procedures are practiced and
  maintained
• EP 9 all grounds and equipment are maintained

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Environment of Care Standards EC.1.20 Safe
Environment

• EC.1.20 The organization maintains a safe
  environment.
• EP 1, 2, 3 Environmental tours are conducted
  regularly to identify deficiencies, hazards and
  unsafe practices.

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Environment of Care Standards EC.2.10 Security

• EC.2.10 The organization identifies and manages
  its security risks.
• EP 1 Written management plan with processes for
  security
• EP 2 Security Manager
• EP 3 Proactive risk assessments are conducted
• EP 4 Procedures implemented achieve best
  security
• EP 5, 6 Access to facility and
• secure areas is controlled.

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Environment of Care Standards EC. 3.10 Hazardous
materials and waste

• The organization manages it s hazardous materials
  and waste risks
• EP 1. Written management plan describes
  processes to manage hazardous materials and
  waste.
• EP 2. Inventory of where HM W are stored or
  generated
• EP 3. Processes are implemented for selecting,
  storing transporting, using and disposing of HM
  W
• HM materials whose handling, use and storage
  are guided by state, federal or local regulation,
  e.g. OSHA, EPA. NRC,
• etc.

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EC.3.10 Hazardous materials and waste (cont.)

• EP 4. Adequate space and equipment are provided
  for the safe handling and storage of HM W
• EP 5. Monitoring and disposal of hazardous gases
  and vapors
• EP 6. procedures implemented to manage spills
• EP 7. Documentation is maintained of permits,
  licenses and adherence to regulations
• EP 8. Required manifests are maintained.
• EP 9. HM W are properly labeled.
• EP 10. HM and W storage and processing areas
  effectively separated from facility.

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Environment of Care StandardsEC. 9.10-30
Improvement of Conditions in the Environment

• EC.9.10 The organization monitors conditions in
  the environment
• EP 1 Process for tracking
• Injuries
• Occupational safety
• Security incidents
• Hazardous materials incidents
• Fire safety
• Equipment and utility problems
• EP 2 Coordinator for environmental improvement
  activities
• EP 3 Implement processes for monitoring

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Environment of Care StandardsEC. 9.10-.30
Improvement of Conditions in the Environment

• EC. 9.20 The organization analyzes environmental
  issues and develops recommendations for
  resolution.
• EP 1,2 A multidisciplinary team is established
  and meets monthly
• EP 3 EC issues are analyzed in a timely manner
• EP 4, 5 Recommendations are developed,
  measurement guidelines are established
• EP 6-9 EC issues are communicated to
  leadership.

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Environment of Care StandardsEC. 9.10-30
Improvement of Conditions in the Environment

• EC.9.30 The organization improves the
  environment.
• EP 1 Appropriate staff involved
• EP 2 Appropriate staff monitor effectiveness of
  implementation
• EP 3-5 Measurement is communicated to team and
  leadership.

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Leadership (LD)

• Leaders provide framework for
• Planning, directing, coordinating
• Providing care, treatment, services
• Improving care
• Respond to community
• Improve healthcare outcomes.

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Leadership Standards

• LD.1.30 The organization complies with
  applicable law and regulation
• LD.3.10 Leaders engage in short-term and
  long-term planning
• EP 3.10.1 Leaders create vision, mission and
  goals.
• LD.3.90 Leaders develop and implement policies
  for care, treatment and services.
• LD.4.40 Leaders ensure an integrated patient
  safety program is implemented throughout the
  facility
• LD.4.60 Leaders allocate adequate resources for
  measuring, assessing and improving performance
  and
• patient safety.

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Performance Improvement (PI)

• Is a continuous process
• Involves measuring of services
• And, when indicated changing to enhance
  performance
• Effectively reduce factors that contribute to
  adverse events.

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Performance Improvement

• Must consider principles of good design
• Consistent with hospitals mission, values and
  goals
• Meets patient needs
• Reflects currently accepted practices
• Doing the right thing
• Using resources responsibly.

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Performance Improvement Standards

• PI.1.10 Data is collected to monitor performance
• EP 1 data is collected in priority areas, e.g.
  safety
• EP 2 the organization considers collecting data
  in response to staff perceptions of risk to
  patients
• EP 3 the organization collects data on how it
  can improve patient safety.

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PI Standards (cont.)

• PI.2.10 Data is systematically aggregated and
  analyzed
• PI.2.20 Undesirable trends in performance are
  analyzed
• PI.3.10 Information from data analysis is used
  to improve performance and patient safety
• PI 3.20 A proactive program for identifying and
  reducing adverse events is defined and
  implemented.

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Crosswalking between Hospitals for a Healthy
Environment (H2E) and JCAHO
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What is Hospitals for a Healthy Environment?

• Partnership between
• American Hospital Association
• U.S. Environmental Protection Agency
• American Nurses Association
• Healthcare Without Harm
• Vision
• All healthcare facilities consider pollution
  prevention and environmental health as key to
  patient safety, community health and their
  operations.

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H2E Goals

• Virtually eliminate mercury-containing waste from
  hospitals waste by 2005.
• Reducing the overall volume of waste (both
  regulated and non-regulated) 33 by 2005 and 50
  by 2010.
• Identifying hazardous substances for pollution
  prevention waste reduction opportunities,
  including hazardous chemicals and persistent,
  bioaccumulative and toxic pollutants.

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JCAHO Focus Areas

• Patient Safety
• Quality of Care
• How Environment affects Patient Safety

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Meeting JCAHO Standards with Pollution Prevention

• H2E Goals
• Virtual elimination of mercury by 2005
• 50 reduction of solid waste by 2010
• Identification and reduction of persistent and
  toxic chemicals
• Meet the following JCAHO standards
• EC.1.10 The organization manages safety risks.
• EP 5 procedures designed to minimize risk
• EP 6 safety procedures are practiced and
  maintained.
• EC. 3.10 The organization manages its hazardous
  materials and waste risks.
• EC.9.30 The organization improves the
  environment.

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Meeting JCAHO Standards with Pollution Prevention
(cont.)

• H2E goals meet the following standards
• PI.3.10 Information from data analysis is used
  to improve performance and patient safety
• PI 3.20 A proactive program for identifying and
  reducing adverse events is defined and
  implemented.
• Mercury reduction makes an excellent performance
  improvement goal to meet JCAHO requirements.
  Environment of Care Essentials for Healthcare,
  2nd Ed.

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Summary

• JCAHO standards
• Have environmental compliance elements
• Have environmental improvement elements.
• Community health and patient safety can be
  related to activity of healthcare facilities.
• Pollution prevention makes ideal improvement
  activity for healthcare facilities.

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Resources

• MnTAPs Meeting JCAHO Standards with Pollution
  Prevention. www.mntap.umn.edu/health/jcaho.htm
• H2Es Mercury Elimination Plan
• www.h2e-online.org/tools/merc-over.htm
• H2Es Chemical Minimization Plan
• www.h2e-online.org/tools/chem-p2.htm
• H2Es Waste Reduction Plan
• www.h2e-online.org/tools/waste-rhc.htm
• Healthcare Environmental Resource Center
• 2005
• Watch H2E listserve

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Never doubt that a small group of thoughtful,
committed citizens can change the world.

• Indeed, it is the only thing that ever has.
• Margaret Mead