Multi-Year Integrated Multi-Year Integrated Strategy for Funeral Home Strategy for Funeral Home

ComplianceCompliance with thewith the Safe Drinking Water ActSafe Drinking Water Act

Presented by: Margaret Halley, Presented by: Margaret Halley, EPA Region 2EPA Region 2

Division of Enforcement Division of Enforcement and Compliance Assistanceand Compliance Assistance

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

Population of nearly 1,500,000912 square milesAll potable water from federally designated

Sole Source AquiferTwo-thirds (2/3) of the county with no sewer access

•Primarily septic systems and cesspoolsAn estimated eighty funeral homes with on-site disposal systems

Suffolk County, NY

Long Island, NYLong Island, NY

Exterior of Funeral HomeExterior of Funeral Home

Element 1:Element 1: Develop a Statement of the Develop a Statement of the Environmental Problem and JustificationEnvironmental Problem and Justification

Embalming waste fluids disposal to on-site Embalming waste fluids disposal to on-site waste systemwaste system

Sampling and analysis results:Sampling and analysis results: Embalming chemicalsEmbalming chemicals

• chlorinated solvents chlorinated solvents • formaldehyde formaldehyde • phenolphenol

Element 2: Element 2: Establish Goals and MeasuresEstablish Goals and Measures

Bring funeral homes into compliance with UIC Bring funeral homes into compliance with UIC regulations in Suffolk Countyregulations in Suffolk County

Compliance AssistanceCompliance Assistance Voluntary ComplianceVoluntary Compliance

Inspections and EnforcementInspections and Enforcement• Number with on-site embalming and injectionNumber with on-site embalming and injection Voluntarily ceasing injectionVoluntarily ceasing injection Large Capacity Septic SystemsLarge Capacity Septic Systems

Seepage pitsSeepage pits LeachfieldsLeachfields

Large Capacity CesspoolsLarge Capacity Cesspools Install septic systemInstall septic system Require soil clean-up in the seepage pit(s)Require soil clean-up in the seepage pit(s)

Set target dates for completion of goalsSet target dates for completion of goals

Prep RoomPrep Room

Element 3: Element 3: Selecting and Selecting and Sequencing ToolsSequencing Tools

Tools and SequencingTools and Sequencing• DataData• Compliance AssistanceCompliance Assistance• Compliance MonitoringCompliance Monitoring• EnforcementEnforcement• Compliance Compliance • Compliance as Part of Doing BusinessCompliance as Part of Doing Business

Element 4: Element 4: Establish roles and Assign Establish roles and Assign ResponsibilitiesResponsibilities

Internal strategy was to maximize UIC inspector Internal strategy was to maximize UIC inspector resourcesresources

External strategy was to establish working External strategy was to establish working relationships with local and state governments, relationships with local and state governments, and with national, state and local funeral home and with national, state and local funeral home trade organizationstrade organizations

Element 5: Element 5: Develop an Implementation Develop an Implementation Plan, Schedule, and MilestonesPlan, Schedule, and Milestones

Identify facilities with no sewer access – 61targetedIdentify facilities with no sewer access – 61targeted July, 2006, selected as three-day inspection July, 2006, selected as three-day inspection

initiative with overnight stayinitiative with overnight stay Three teams of two inspectors, each to inspect at Three teams of two inspectors, each to inspect at

least 30 funeral homes (10 per day)least 30 funeral homes (10 per day) Hold meetings with inspectorsHold meetings with inspectors • Clarify issues specific to funeral homesClarify issues specific to funeral homes• Distribute inspection materialsDistribute inspection materials• Communicate how to follow-upCommunicate how to follow-up

Determine:Determine:• Number with on-site injection of embalming fluidsNumber with on-site injection of embalming fluids• Number with large capacity septic systems (over 20 uses per day),Number with 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, 2005large capacity cesspools (over 20 uses per day), banned as of April 5, 2005• Number ceasing injection – 100 % because of innovative technologyNumber ceasing injection – 100 % because of innovative technology• Number requiring cesspool/seepage pit clean-upNumber requiring cesspool/seepage pit clean-up

Remedial soil excavation of funeral home cesspool contaminated with

chlorinated solvents, formaldehyde and phenol

Element 6: Element 6: Designing Designing Resources/Workforce DeploymentResources/Workforce Deployment

24 funeral homes remained to be inspected24 funeral homes remained to be inspected Inspectors’ workloads deemed heavyInspectors’ workloads deemed heavy Individual inspectors, not teamsIndividual inspectors, not teams Day tripsDay trips No overnight stays because of funding reductionNo overnight stays because of funding reduction

Element 7: Element 7: Communicating the StrategyCommunicating the Strategy

EPA Region 2 website: EPA Region 2 website: www.epa.gov/region02/water/compliancewww.epa.gov/region02/water/compliance

New York State Funeral Directors Association New York State Funeral Directors Association (NYSFDA) diligent in outreach to members to (NYSFDA) diligent in outreach to members to advocate use of new technology to assist UIC advocate use of new technology to assist UIC compliancecompliance

Encourage the NYSFDA in its effortsEncourage the NYSFDA in its efforts• Region 2 awarded NYSFDA with 2006 National Region 2 awarded NYSFDA with 2006 National

Water Efficiency Leader Award and 2007 Water Efficiency Leader Award and 2007 Region 2 Environmental Quality Award for their Region 2 Environmental Quality Award for their outreach efforts.outreach efforts.

Element 8: Element 8: Monitoring and Monitoring and Evaluating the StrategyEvaluating the Strategy

Lab data = foundationLab data = foundation Good relationships with state and local governments Good relationships with state and local governments

critical as regulators & facilitators of EPA effort critical as regulators & facilitators of EPA effort Communicating with trade organizations a successCommunicating with trade organizations a success Increased UIC complianceIncreased UIC compliance Implementation of innovative hold and haul technology, Implementation of innovative hold and haul technology,

while concurrently reducing water consumption, from the while concurrently reducing water consumption, from the traditional 120 gallons per embalming to traditional 120 gallons per embalming to only only 55 gallons gallons per embalmingper embalming

Capacity building for compliance of funeral homes in Capacity building for compliance of funeral homes in rural areas of NYS obstacles because new technology rural areas of NYS obstacles because new technology not yet readily availablenot yet readily available

Element 9: Exiting the StrategyElement 9: Exiting the Strategy

Inspections completed as of April 30, 2008Inspections completed as of April 30, 2008 Follow-up compliance orders to be completed by Follow-up compliance orders to be completed by

September 30, 2008September 30, 2008

Medical Waste Blood Storage Box Medical Waste Blood Storage Box Waterless Aspiration UtilizedWaterless Aspiration Utilized