During a construction and renovation project, chemical contamination and improper hazardous materials management can be the source of many adverse environmental impacts. Historical contamination in a health care facility or mismanagement of C&D waste during a project can open the door to penalties and fines from both state and federal environmental agencies. Paperwork trails can also cause significant compliance headaches, cost overruns and project delays.

Many hospitals predate the existence of the Environmental Protection Agency (EPA) or any of its associated statutes. As a facilities manager, it can be difficult to know how the laboratory and other departments are handling hazardous materials now, never mind how materials management practices were controlled generations ago. Historical contamination is extremely common in old hospital buildings and is a potential budget buster, whether it be in soil, infrastructures or a workspace targeted for renovation.

Contamination in internal workspaces or infrastructures could potentially come from many more places than one might imagine. Many chemicals used in the various departments of a hospital can potentially be a source of historical or chronic contamination in a health care facility.

If any laboratory space is being renovated (clinical, pharmacy/oncology or research), for instance, on-site contractors will often refuse to work in that laboratory space without written certification that all surfaces have been properly decontaminated. The same may be true for any lab equipment being relocated to new or temporary space. This might mean bringing in a crew of environmental specialists to decontaminate the space and provide written documentation. These services can sometimes be quite expensive if they are contracted at the last minute.

Before large-scale demolition begins, it is necessary to identify what lies in the building infrastructure. For instance, one of the most pervasive chemicals on old hospital sites is mercury. Mercury’s harmful properties are well-documented and most facilities strive to be “mercury-free.” However, old cast-iron or glass piping in buildings generally contain enough mercury to raise serious concern about contamination unless every line between the laboratories and the final discharge has been replaced in recent years.

Mercury can be present not only from historical use, but from current practices. Occasionally, there is certain equipment for which staff do not want to utilize mercury-free alternatives. Laboratory and/or medical staff are sometimes reluctant to change procedures for fear of impacting patient care. Mercury thermometers, for example, are often still used in laboratories to monitor temperatures in water baths.

If contractors are surprised by the presence of mercury, the project could be shut down until a decontamination occurs. The associated costs of an urgent decontamination and having contractors on hold can be significant.

Do not repeat others’ mistakes by tearing down a building without first removing contaminated piping, draining cooling systems and removing all window air conditioners. Damaging this equipment during demolition can turn large amounts of debris into hazardous waste. All thermostats, fluorescent lamps and ballasts should also be removed before bringing in the heavy equipment. Window casings from older buildings have a high probability of lead paint and may need to be removed separately and disposed of as hazardous waste. Failure to do so can also create contamination in ordinary construction debris waste.

External contamination may not only entail waste disposal, but possible impacts to the environment. This can lead to extensive cleanup costs and fees or fines issued by state, local and federal agencies.

For instance, if a project includes any type of excavation, it may impact storm drains. Storm drains often contain evidence of automotive fluids and, if not maintained routinely, a disturbed catch basin can release contaminants into the groundwater and sewer systems. Likewise, if a project entails demolition work on or in a parking garage, oil/water separators must be decontaminated before demolition to avoid contaminating soil or debris.

Additionally, if any underground storage tank is being removed, risk of having contaminated soil is high. Tanks must be properly cleaned before removal and, if being replaced, must be installed by a licensed contractor. This will ensure compliance with state and federal requirements for underground chemical and oil storage.

A contractor is never responsible for any hazardous wastes generated on a job site. The contract agreement may indicate that waste disposal is the contractor’s responsibility, and the contractor may live up to the agreement, but any waste created on-site at a health care facility is linked to that property; therefore, it is tied to the hospital’s EPA generator’s identification number. 

This means that it is the hospital’s responsibility and liability, and any hazardous waste generated during a project counts toward monthly and annual waste generation. The hospital’s name appears on the shipping papers, not the contractor’s, so it is necessary to be certain that only approved hospital personnel are signing the papers.

It is also necessary to confirm that the waste is being characterized and stored properly as well as being shipped to a fully permitted disposal facility. If the hospital is registered with the EPA as a small quantity generator of hazardous waste, the project can potentially cause limits to be exceeded and subject the hospital to additional fees, requirements and even fines on a state or federal level.

Still, a project manager should fully understand the contractor’s training, capabilities and requirements for working in a potentially contaminated area. If they require certificates of decontamination, these procedures should be appropriately planned. Typically, a plumbing contractor will not be trained to manage hazardous materials, and should not work with chemically contaminated piping. Clear, concise communication and proper planning will ensure that the appropriate contractor is employed on each phase of the project. If expectations and qualifications are clear, costly delays can be avoided.

For example, a hospital in New England recently removed an underground storage tank and, in turn, had to ship several tons of contaminated soil to be properly disposed. Although state contingency plans require off-site shipment of the soil, the material did not meet the definition of a hazardous waste in this case. When the contractor arranged disposal through its hazardous waste subcontractor, the soil was improperly characterized as hazardous waste. The improper characterization of the soil caught the attention of the state agency, and caused the additional requirement of completing and submitting an EPA biennial report. Ultimately, the shipment caused the hospital to exceed its generator limits for the year and this waste management error became the source of unbudgeted consulting services and increased scrutiny by the state.

Many states perform their own on-site inspections for environmental compliance. Events like this one can put a facility under the microscope and increase chances of a state inspection.

If a project involves adding or replacing boilers, it will certainly have an effect on the air emissions during and after the project. To avoid Clean Air Act violations, it may be necessary to go through a new source registration process and update air emissions permits.

Permits also come into play under the Clean Water Act. A project involving excavation will likely require a storm water discharge permit. With significant amounts of additional mobile equipment on-site, storm water runoff can potentially be the cause of groundwater contamination. Inside buildings, engineering staff is responsible for maintaining wastewater neutralization systems. These systems were designed as a result of the Clean Water Act regulations and associated permits. Project managers should consider how the project may impact current wastewater permits. Will there be flow increases during or after the project? Is the current system adequate to handle the changes? Will there be new processes that require new treatment or collection systems to be installed? Any significant changes could potentially cause a violation of the hospital’s wastewater discharge permit. Individual state and local agencies may have other permit requirements related to environmental issues. Be sure to understand all local as well as federal requirements.

Additionally, many states have a ban on certain C&D materials from disposal at municipal landfills. For example, Massachusetts will not allow municipal landfill disposal of cathode ray tubes, lead-acid batteries, asphalt, brick or concrete. Nor will wood or metal waste be accepted in any significant quantities at solid waste landfills. These materials must be recycled and the list continues to grow, including white goods such as stoves and refrigerator units. It is a good idea to check individual state requirements.

There are many potential pitfalls of a C&D project, and any of the issues mentioned above could result in compliance enforcement and fines as well as project delays and cost overruns. Of course, it all equates to bad publicity that does not go unnoticed by potential customers, benefactors and the Joint Commission.

Making the extra effort to identify and address environmental issues prior to the project commencing is highly recommended. A proactive approach can help ensure that projects stay on time, on budget and will minimize liability by foreseeing the potential environmental impacts.