MultiYear Integrated Strategy for Funeral Home Compliance with

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Multi-Year Integrated Strategy for Funeral Home Compliance with the Safe Drinking Water Act Presented

Multi-Year Integrated Strategy for Funeral Home Compliance with the Safe Drinking Water Act Presented by: Margaret Halley, EPA Region 2 Division of Enforcement and Compliance Assistance

Mandate of EPA’s UIC Program is to protect Underground Sources of Drinking Water

Mandate of EPA’s UIC Program is to protect Underground Sources of Drinking Water

Suffolk County, NY ØPopulation of nearly 1, 500, 000 Ø 912 square miles ØAll

Suffolk County, NY ØPopulation of nearly 1, 500, 000 Ø 912 square miles ØAll potable water from federally designated Sole Source Aquifer ØTwo-thirds (2/3) of the county with no sewer access • Primarily septic systems and cesspools ØAn estimated eighty funeral homes with on-site disposal systems

Long Island, NY

Long Island, NY

Exterior of Funeral Home

Exterior of Funeral Home

Element 1: Develop a Statement of the Environmental Problem and Justification Embalming waste fluids

Element 1: Develop a Statement of the Environmental Problem and Justification Embalming waste fluids disposal to on-site waste system Ø Sampling and analysis results: l Embalming chemicals Ø • chlorinated solvents • formaldehyde • phenol

Element 2: Establish Goals and Measures Bring funeral homes into compliance with UIC regulations

Element 2: Establish Goals and Measures Bring funeral homes into compliance with UIC regulations in Suffolk County Ø Compliance Assistance Ø l Ø Voluntary Compliance Inspections and Enforcement • ü ü Number with on-site embalming and injection Voluntarily ceasing injection Large Capacity Septic Systems ü Seepage pits ü Leachfields ü ü ü Ø Large Capacity Cesspools Install septic system Require soil clean-up in the seepage pit(s) Set target dates for completion of goals

Prep Room

Prep Room

Element 3: Selecting and Sequencing Tools Ø Tools and Sequencing • • • Data

Element 3: Selecting and Sequencing Tools Ø Tools and Sequencing • • • Data Compliance Assistance Compliance Monitoring Enforcement Compliance as Part of Doing Business

Element 4: Establish roles and Assign Responsibilities Internal strategy was to maximize UIC inspector

Element 4: Establish roles and Assign Responsibilities Internal strategy was to maximize UIC inspector resources Ø External strategy was to establish working relationships with local and state governments, and with national, state and local funeral home trade organizations Ø

Element 5: Develop an Implementation Plan, Schedule, and Milestones Identify facilities with no sewer

Element 5: Develop an Implementation Plan, Schedule, and Milestones Identify facilities with no sewer access – 61 targeted July, 2006, selected as three-day inspection initiative with overnight stay Ø Three teams of two inspectors, each to inspect at least 30 funeral homes (10 per day) Ø Hold meetings with inspectors Ø Ø • • • Clarify issues specific to funeral homes Distribute inspection materials Communicate how to follow-up Ø Determine: • • Number with on-site injection of embalming fluids Number with large capacity septic systems (over 20 uses per day), Number with large capacity cesspools (over 20 uses per day), banned as of April 5, 2005 Number ceasing injection – 100 % because of innovative technology Number requiring cesspool/seepage pit clean-up • •

Remedial soil excavation of funeral home cesspool contaminated with chlorinated solvents, formaldehyde and phenol

Remedial soil excavation of funeral home cesspool contaminated with chlorinated solvents, formaldehyde and phenol

Element 6: Designing Resources/Workforce Deployment 24 funeral homes remained to be inspected Ø Inspectors’

Element 6: Designing Resources/Workforce Deployment 24 funeral homes remained to be inspected Ø Inspectors’ workloads deemed heavy Ø Individual inspectors, not teams Ø Day trips Ø No overnight stays because of funding reduction Ø

Element 7: Communicating the Strategy EPA Region 2 website: www. epa. gov/region 02/water/compliance Ø

Element 7: Communicating the Strategy EPA Region 2 website: www. epa. gov/region 02/water/compliance Ø New York State Funeral Directors Association (NYSFDA) diligent in outreach to members to advocate use of new technology to assist UIC compliance Ø Encourage the NYSFDA in its efforts • Region 2 awarded NYSFDA with 2006 National Water Efficiency Leader Award and 2007 Region 2 Environmental Quality Award for their outreach efforts. Ø

Element 8: Monitoring and Evaluating the Strategy Ø Ø Ø Lab data = foundation

Element 8: Monitoring and Evaluating the Strategy Ø Ø Ø Lab data = foundation Good relationships with state and local governments critical as regulators & facilitators of EPA effort Communicating with trade organizations a success Increased UIC compliance Implementation of innovative hold and haul technology, while concurrently reducing water consumption, from the traditional 120 gallons per embalming to only 5 gallons per embalming Capacity building for compliance of funeral homes in rural areas of NYS obstacles because new technology not yet readily available

Element 9: Exiting the Strategy Inspections completed as of April 30, 2008 Ø Follow-up

Element 9: Exiting the Strategy Inspections completed as of April 30, 2008 Ø Follow-up compliance orders to be completed by September 30, 2008 Ø

Medical Waste Blood Storage Box Waterless Aspiration Utilized

Medical Waste Blood Storage Box Waterless Aspiration Utilized