The following includes information excerpted and adapted
from the EPA Sector Notebook Profile
of the Healthcare Industry:
Water regulations establish different permitting programs
for direct and indirect wastewater discharges.
- "Direct discharge" refers to wastewater discharged
directly into a stream or other receiving body. Direct discharges are
regulated under the National Pollutant
Discharge Elimination System (NPDES) program.
- "Indirect discharge" refers to wastewater that
is sent to a sanitary sewer. Indirect discharges are subject to regulations
by the local sewer authority.
Most hospitals are indirect dischargers.
Sewer authorities that serve significant industrial users
are required to implement industrial
pretreatment programs (IPPs). At present, approximately 1,500
of the nation's largest municipalities have been required to develop IPPs. Some
municipalities have determined hospitals to be significant industrial users.
Most municipalities have established local prohibitions that
apply specifically to medical waste discharges. For example, some municipalities
have set a prohibition on "all medical waste." Other prohibitions
include, for example, no discharge of discernible body parts, no human remains
greater than 0.5 inches in diameter, and/or no radioactive wastes. The
ability of municipalities to establish prohibitions to meet their specific
needs/interests is very flexible.
In addition, Federal Pretreatment Regulations prohibit:
- discharges of fire or explosion hazards
- corrosive discharges (pH < 5.0)
- solid or viscous pollutants
- heat (in amounts that cause the treatment plant influent
to exceed 104 degrees F)
- pollutants that cause toxic gases, fumes, or vapors
- any other pollutant (including oil and grease) that will
interfere with or pass through the treatment plant
There are very few direct discharging hospitals. For
example, in 2004, 11 hospitals in the U.S. and obtained "non-major" NPDES
permits, and only one had obtained a major NPDES permit.
NPDES permits are issued either by EPA or by the state in
which a facility is located, in cases where the state has been specifically
authorized to implement the NPDES Permit Program. In either case, the
overall form of the permit application and the general permit requirements
are those established under federal regulations. But more specific regulations
may apply in individual cases, depending on technology-based discharge standards
(40 CFR 460) and on water quality standards for the water body receiving the
Because the numeric limits that apply to a given facility
are site specific, the best way to get more detailed information is to contact
Regional pretreatment coordinator responsible for the region where the
facility is located.
Common areas for inspections
While an EPA inspector is authorized to examine a wide range
of documents and operations, he or she will probably be interested in three
areas in particular that relate to Clean Water Act compliance:
- wastewater discharges
- stormwater discharges
- any aboveground or underground oil storage containers
Typical records that an EPA inspector may ask to review include:
- Industrial User permit (IU permit) for discharges to the
- Spill Prevention, Control, and Countermeasure (SPCC) Plan. (The
purpose of an SPCC plan is to prevent any discharge of oil into or upon navigable
waters of the United States or adjoining shorelines.)
- Phase II stormwater permits under the NPDES program, for
public hospitals located in urbanized areas
- NPDES construction stormwater permits (Phase I and Phase
II), required for any construction activity greater than 1 acre for any hospital
located in urban or rural areas)
- NPDES general permit for discharging directly to a water
body (direct discharge
EPA’s Office of Water operates a Water Resource Center
with a 24-hour voice mail system for publication orders or reference questions. They
can be reached:
Long-distance callers in the United States may also use
the Wetlands Helpline ((800) 832-7828), operating weekdays from 8:30 a.m. to
4:30 p.m., EST, excluding federal holidays.
Visit the Office
of Water web site and the NPDES
website for additional information.