Various Locations, Nationwide

Nationwide Audit of Veterans Health Administration Solid Waste Streams and Recycling Program Activities

Nationwide Audit of Solid Waste Streams for VHA

First Environment conducted a national independent assessment of Municipal Solid Waste (MSW) generation activities, waste diversion practices and recycling programs occurring within the VA’s Veterans Health Administration (VHA). In partnership with a subconsultant, the team conducted site visits and data reviews at 140 VHA medical centers representing each of the VHA’s 21 Veterans Integrated Service Networks (VISNs).

As the prime contractor, First Environment’s personnel self-performed more than 80% of the scope of work under the contract, including 111 on-site assessments in 35 states across the country.  All of the 140 site assessments were executed in only seven months by a field team comprised of 21 lead auditors and field technicians, calling for extensive planning, scheduling, and logistical arrangements that concerned employee travel, packaging and shipping equipment, site notification and pre-assessment conference calls, and accommodating auditee conflicts. Up to five assessment teams worked simultaneously during the seven-month field assessment period.

Information derived from the project allows the VA to measure progress towards achieving the waste management and diversion goals presented under federal Executive Order 13514, with the potential to advance further waste utilization and minimization throughout the VHA. 

Assessment activities at each of the sites included three principal review actions, including:

A lead assessor and supporting technician executed on-site assessment activities at each of the facilities lasted two days at each location. The first day was dedicated to the operational review and metrics verification, the second dedicated to the field waste characterization.  As necessary, the two-day assessment schedule was modified to account for shared reporting actions amongst multiple facilities in a common VA healthcare system. 

The operational review and metrics verification focused on MSW and select recyclable commodities, including wood, corrugated materials, white paper, ferrous and non-ferrous metals, and plastics.

The field waste characterization included the characterization of a select portion of MSW generated by the facilities and included sorting the waste into pre-defined categories. In general, a targeted sample weight between 375 – 425 pounds was selected from reserved MSW receptacles or chosen directly from site waste containers (dumpsters) to obtain a representative waste sample. We composited (mixed) the waste sample on-site, with roughly half of the amount subject to rough and then fine sorting into 19 pre-determined waste categories. We weight waste materials comprising each category on-site in order to populate field characterization documents.

For field waste characterization efforts, we identified hazardous materials inadvertently placed in the MSW stream for proper disposition by VHA authorities. Such materials included infectious and regulated medical waste and waste materials potentially regulated under the federal Resource Conservation and Recovery Act (RCRA). To help ensure the safety of personnel conducting characterization activities, First Environment prepared a project specific health and safety plan (HASP) complemented by a bloodborne pathogens program (BBP) that established strict personal protective equipment and hygiene requirements, safe work distance guidelines, and stop work criteria.

The project team executed on-site assessment activities and provided observations and recommendations in conformance with First Environment’s Field Assessment Protocol. The protocol concerned all aspects of assessment activities at the facilities, including pre-assessment review activities, on-site review activities, and project QA/QC. Field personnel use pre-approved checklists—including standardized questions and data requests—from in the protocol to conduct the assessment at each of the 140 locations.

At the conclusion of each site review, we prepared a facility-specific executive summary to summarize the results of the FY 2011 metrics verification, verified site waste recycling practices and policies, and site MSW characterization results.

Using the results drawn from the assessment of all facilities, First Environment identified opportunities to divert or eliminate waste from VHA MSW streams via recycling, beneficial re-use, or other source reduction techniques.

At the conclusion of the project, First Environment prepared a final comprehensive report that provided a VHA-wide picture of MSW and waste diversion program assessment results as well as a prioritized listing of waste diversion scenarios that can be implemented by the VHA to further advance waste utilization and minimization.