The Massachusetts Water
Resources Authority (MWRA) currently prohibits the discharge of
mercury by industrial facilities to its sewer system and imposes
an effective discharge limitation for mercury of 1.0 part per
billion (ppb) from its regulated sources, including hospitals
and institutions. Meeting the MWRA's standard for sewer
discharge presents a formidable challenge for hospitals because
of the nature of the testing performed and the type of equipment
used by health care providers in their effort to effectively
diagnose and treat disease. Key substances used in research and
diagnostic work, reagents in particular, often contain trace
amounts of mercury that are usually not listed in the content
descriptions.
These trace amounts of
mercury tend to collect in the organic material (biomass) that
may be present in waste piping systems and, as a consequence,
can slough off into the wastewater stream at any time. This
problem is further complicated by the fact that laboratory
testing procedures vary significantly, depending upon the type
of testing or research being conducted, making standardization
of procedures exceedingly difficult.
To address this complex
issue, the MWRA established a Mercury Products Work Group in the
Fall of 1994 to examine the problem and develop strategies to
reduce the amount of mercury being discharged. Hospital
participation in this process was coordinated through MASCO (a
not-for-profit provider of services and technical assistance to
Longwood Medical and Academic Area institutions), and involved
the active participation of twenty-eight (28) hospitals.
One of the innovative
aspects of this project involved the MWRA's and hospitals'
willingness to suspend their usual rules of engagement by moving
beyond the traditional use of enforcement mechanisms including
fines as the primary means of pursuing compliance. Specifically,
the MWRA distributed a memorandum stating that the MWRA would
not fine a hospital for mercury violations, so long as they were
actively participating in Work Group activities. This not only
provided direct economic relief to some of the institutions
(prior to formation of the Work Group, one of the members had
received a fine in excess of $100,000), but it served to create
a climate in which all parties were able to focus more clearly
on the search for solutions to the problem at hand. The
repercussions of this paradigm shift caused institutions to also
consider and change their normal ways of interacting with each
other. Rather than competing, as is so often the case these
days, the participating institutions focused on bringing their
collective resources to the table. The pooling of knowledge and
the allocation of staff in this fashion has helped to produce
results much more quickly and thoroughly than would have
otherwise been possible. In addition, this collective approach
to addressing common concerns has thus far saved those
institutions more than $2 million through the elimination of
duplicate efforts that would have been required as part of
individual compliance programs.