Replacing Mercury in Veterinary Facilities—A Step-by-Step Approach

Taking the Leap....

How do you get a mercury reduction program rolling? Here's a step-by-step plan for making mercury reduction a priority at your hospital.

• Assess
• Commit
• Manage
• Replace:
  • clinical devices
  • facility devices
  • lab chemicals
  • other chemicals
• Universal waste
• Keep it out
• Recognition and Awards

Step 1—Assess the mercury in your facility

Start by creating an inventory of mercury-containing products in your facility. Record where the mercury is, and how much is in each location.

The inventory will provide:

• a perspective to help you develop realistic reduction goals and well-targeted action plans
• a baseline against which you can measure your progress

Step 2—Make a Commitment

Get support from the top. Talk to your hospital leadership, and get a signed statement to be mercury-free.

Establish a mercury-free team. Designate a program leader who will be enthusiastic and dedicated to the program. The leader should recruit support from a key person in each department who has the authority to make departmental changes.

Step 3—Manage What You Have On-Hand

Until you are able to eliminate all mercury-containing items in your facility, you should have a comprehensive management plan in place. This includes

• a Mercury Management Policy
• a Mercury-free Purchasing Policy (see step 9)
• a general Employee Education program covering mercury use and disposal issues
• a Spill Prevention and Education program targeted specifically toward spill prevention and response

Step 4—Replacing Mercury-Containing Clinical Devices

Once you understand the types, number and location of your clinical devices that you have assessed in Step 1, you can set reasonable goals for elimination.

The first step, already taken by healthcare facilities across the country, is to replace mercury thermometers with electronic devices, to make sure they are no longer being sold in your outpatient pharmacy, and to ensure that you are not sending them home with patients.

Sphygmomanometers are more expensive to replace, so you might have to consider a phased in multi-year replacement plan. But always consider that the cost of a mercury spill clean-up from a sphygmo may cost thousands of dollars. Include avoided costs of labor, disposal and liability when determining your cost benefit.

For other clinical devices, non-mercury alternatives exist for each one.

Step 5—Replacing Mercury-Containing Devices in Facilities

Facility devices include items like switches, gauges, thermometers, x-ray tubes, barostats and thermostats.

Next to replacing these devices, the most important task is to inventory and tag them as mercury-containing.  When the device is replaced, it can then not only

1.  be replaced with a non-mercury alternative, but also

2.  be removed and safely disposed of as universal waste

Step 6—Replacing Mercury-Containing Laboratory Chemicals

Every lab should put together an action plan including operational and policy initiatives to a phased in approach to prioritizing chemicals.  We recommend a phased-in approach to mercury reduction.

1. The first phase is to review and understand your current practices, including disposal, based on the inventory from step 1.

2. The second phase is to identify the fixative and stains that contain significant amounts of mercury and to determine which of them can be replaced by effective mercury-free alternatives.

3. The third phase is to identify and list those chemicals that contain mercury but that do not have readily available substitutes.  Your mercury management plan should include a provision for periodic review of this list to determine whether alternatives have become available.

Step 7—Replacing Other Mercury-Containing Chemicals

Cleaning Chemicals

Pharmaceuticals

Step 8—Mercury as a Universal Waste

Many mercury-containing products when discarded are considered "universal waste". Examples include batteries, pesticides, thermostats, and fluorescent lamps, and may also include cathode ray tubes, depending upon your state's universal waste rule.

The universal waste rule enables you to avoid some of the more cumbersome RCRA requirements, and helps encourage recycling. Understand the universal waste rule and let it help you manage and recycle your mercury waste.

Step 9—Keep the Mercury Out

Begin at the source.  Work with your purchasing department to make sure that mercury products do not find their way back into the hospital.

• Establish a mercury-free purchasing policy.

• Require that vendors sign a mercury-content disclosure agreement covering products that you intend to purchase.

Then use your mercury inventory (from Step 1) to monitor the effectiveness of the policy.  Repeat the inventory periodically and re-evaluate your facility.  Identify your successes and modify your plan as necessary.

Step 10—Recognition and Awards

Getting recognition from the work is often a critical component of its continued success.

Practice Greenhealth's Making Medicine Mercury Free (MMMF) Awards are given to facilities that have virtually eliminated mercury and developed policies to sustain the elimination.

Most importantly, get the message out to hospital staff that they are making a difference!

To apply to the award or for more information, go to

http://www.practicegreenhealth.org/awards/mmmf