First, Do No Harm

The Haw River Medical Waste Incinerator

© BREDL 2001

Louis Zeller

Medical waste incinerators are the second largest known source of dioxin in the United States. Health effects of prolonged dioxin exposure include impairment of immune, nervous and endocrine systems. Dioxin is a known human carcinogen. In addition to dioxin, toxic air pollutants from medical waste incinerators include arsenic, chromium IV, cadmium, lead, hydrochloric acid, and mercury. Medical waste incinerators are even bigger polluters than other types of waste burners; North Carolina permits medical waste incinerators to emit 60% more cadmium, 108% more dioxin, and 580% more mercury than solid waste incinerators.

Stericycle, Inc. is a huge medical waste management company with operations in The United States, Mexico, Canada, Argentina, Brazil, South Africa, Japan, and Australia. The company headquarters are in Lake Forest, Illinois. In a 1999 expansion, Stericycle bought BFI Medical Waste, Inc. (part of Browning Ferris Industries) and the medical waste incinerator in Haw River, NC became a Stericycle operation.. The Haw River medical waste incinerator is one of the nation’s largest, importing waste from many states.

Although many, less harmful techniques exist which render medical and infectious waste harmless, Stericycle has steadily expanded its lucrative business. In the first quarter of 2001, Stericycle reported a 37% annual increase in net income.

Incinerator Neighbors See Smoke

January 15, 2001: Sam Kiser, who lives in Haw River, complains to the NC Division of Air Quality’s regional office about black smoke coming from the incinerator. He says he observed the smoke at about nine o’clock in the evening. He adds that the stacks emit smoke frequently. Rather than going to the facility to check, the inspector at DAQ calls Stericycle’s plant manager on the phone. The manager faxes records which reveal elevated carbon monoxide emissions and a spike in scrubber pH at 9:15 PM on the 15th. DAQ concludes that medical waste with a high moisture content could have caused the increase in visible emissions seen by Mr. Kiser. In his report, the state inspector wrote, “Since the emission occurred at night, it is difficult…to categorize a visible emission, and there is no real reason to believe the incinerators were operating…in violation.” Also, he cites stack tests completed in October which showed that the incinerator was operating within permitted limits.

February 21, 2001: Sam Kiser again sees black smoke coming from the incinerator. This incident begins at 6:00 AM and lasts for two hours. DAQ’s second investigation-by-telephone determines it may have been the “lighting conditions” on that morning. No further action was taken.

Stericycle’s Record Of Non-Compliance: Two Cases

Overloading the Incinerator

Stericycle is permitted to burn 1,911 pounds per hour in each of the two units, a total of 33,480,720 pounds of medical waste a year. Investigations by the Blue Ridge Environmental Defense League show that the company exceeded its allowable burn rate eight times in a five months period during 2000. Stericycle’s operators overloading waste by as much as 11% over the maximum, oftentimes between the hours of midnight and 7:00 AM.

In November 2000 the state recommended civil penalties for five episodes of excess waste burning in the incinerator. But Stericycle said the computer system which recorded the weight violations was only a “billing tool for accounting purposes,” and that the hand written operating logs recorded no excess weights. After issuing a series of violations to Stericycle, North Carolina’s Division of Air Quality, which can levy fines of $10,000 per violation, opted to let the company off the hook. No fines were imposed.

Failed Stack Tests

Stericycle’s must test its incinerators periodically to demonstrate compliance with pollution limits. In October 2000 Stericycle submitted test results which indicated that state and federal standards were met. But the Division of Air Quality discovered “computational errors” in the report filed by Stericycle which falsely indicated compliance with the particulate matter (PM) standard. The incinerator had actually emitted PM 5.4% above the maximum. Each day of operation over the limit makes the operator subject to a civil penalty of $10,000 per day. In February DAQ issued a notice of violation and recommended enforcement.

In March Stericycle employed the same testing firm, Custom Stack Analysis, Inc., to repeat the PM emission test and analysis. This time the results indicated a PM emission rate in compliance with state regulation. The DAQ, upon reviewing the data, levied a fine of only $4,000.

The Blue Ridge Environmental Defense League is asking for a further, independent verification of the test results at Stericycle. We question the validity of emissions tests for dioxins and furans two highly toxic products of waste combustion. Medical waste incinerators are known to emit high levels of dioxin, but the October test results for dioxin were below detection limits, virtually zero. Even one state official remarked that non-detection of dioxin was “surprising.”

Stericycle Granted Two Year Delay for Pollution Reduction

In November 1999 the NC Division of Air Quality notified Stericycle it was required to meet new state and federal emission standards by July 2000. In December Stericycle petitioned the state for a two-year extension of the compliance deadline in order to evaluate and install new pollution control devices. The new regulation, adopted by the NC Environmental Management Commission, requires stricter limits on toxic air pollutants: for example, mercury must be reduced by 85% and visible emissions are limited to 10% opacity. The DAQ approved Stericycle’s request. The US EPA also granted an extension of the compliance deadline, now set for September 15, 2002.

BREDL Community Action Campaign


The state of North Carolina cannot at present ensure that medical waste incinerators are operated without threatening public health and the environment. BREDL is working with our members to end pollution from commercial medical waste incineration in two North Carolina communities: Matthews in Mecklenburg County and Haw River in Alamance.

Our campaign made two major advances in August. First, the NC Division of Epidemiology met with the residents to discuss their concerns. Dr. Ken Rudo gave an overview of what the state could do to determine the public health impacts of the medical waste incinerator. Second, BREDL held a training session on toxic air pollution testing. The Bucket Brigade program puts low-cost air testing devices in the hands of community volunteers. Sam Kiser, the leader of the Haw River group, and several other residents attended. The combination of solid scientific data and a community health investigation will give residents the backing they need to organize for pollution reductions in Alamance County.

Blue Ridge Environmental Defense League continues to work with the residents of Haw River and the nearby communities of Graham and Mebane in Alamance County to end the negative health impacts caused by Stericycle and to end toxic business-as-usual in the medical waste incineration industry.

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Hospitals in the United States produce an estimated 2 million tons of waste per year. Much of this medical waste is disposed of in incinerators. About 10-15% of hospital waste is regulated as infectious, requiring a special disposal process called “red-bagging.” Studies show that red-bagging for infectious waste is overused in most institutions and that some hospitals dispose of up to 30% of their waste as infectious. For example, in surgical units, surveys show that a considerable amount of so-called infectious waste is generated before the patient even enters the operating room.

Plastics comprise 15-30% of the medical waste stream twice that of ordinary household waste. And hospital waste includes a greater proportion of polyvinyl chloride. Plastic made with PVC contains about 50% chlorine and represents a large source of dioxin formation in incinerators. One analysis found that PVC gloves and IV bags alone accounted for over 80% of the chlorine content in medical waste. Vinyl chloride, from which PVC is made, is a known human carcinogen.

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Sept 19, 2003: BREDL comments on Title V permit for Stericycle, Inc, Haw River, Alamance County, NC (.pdf)

June 25, 2003: BREDL comments on reopened Title V permit for Stericycle, Inc, Haw River, Alamance County, NC (.pdf)

Jan. 15, 2002 - BREDL comments on Stericycle, Inc, Haw River, Alamance County, NC Title V permit