| Please note that this page
refers to federal requirements. State and local
regulations may differ.
This page provides information on equipment
and materials for which veterinary facilities may be required to obtain air
See the VetCA
Clean Air Act page for additional information on the federal law that
authorizes the EPA to impose air quality permit requirements.
Sources of Air Emissions
At veterinary facilities, air
emissions can come from numerous sources, including:
conditioning and refrigeration units
oxide sterilization units
Permits that may
be Required under the Clean Air Act
Title I: Some large pieces
of equipment may be subject to New
Source Performance Standards (NSPSs) under the Clean Air Act. Information
on NSPS requirements for certain specific pieces of equipment can be found
on VetCA pages dealing with incinerators.
Many types of emission involving Hazardous
Air Pollutants (HAPs) are also regulated under Title I. Specific
cases are discussed in more detail in the next section.
Title V: This section of
the CAA requires that all "major sources" (and certain minor sources)
obtain an overall operating permit. A veterinary facility that qualifies as
a major source would be required to have a Title V permit, and may be required
to submit a permit application that includes information about emissions, control
devices, and the general process at the facility. Permits may limit pollutant
emissions and impose monitoring, recordkeeping, and reporting requirements.
Monitoring requirements for many facilities
with Title V permits are specified in the Compliance
Assurance Monitoring (CAM) regulations. For facilities that meet emissions
requirements on their permits by using pollution control equipment, CAM may
require that the facilities monitor the control equipment to assure that it
is operated and maintained as prescribed in their permits.
40 CFR Part 60:
Under the CAA, EPA regulates air emissions from
hospital medical/infectious waste incinerators (HMIWI). When burned,
medical waste may emit air pollutants, including:
gases, such as
EPA has developed emission standards that apply
both to incinerators used by hospitals and veterinary facilities as well as
to those used by commercial waste treatment and disposal companies to treat
The emission guidelines are intended to meet
the requirements of the federal CAA. States can establish their own standards,
but they must be at least as protectiveas the federal standards. These standards
will result in reductions in the air emissions of concern from HMIWI.
The EPA provides an index
page with links to detailed information on the HMIWI rule.
Reciprocating Internal Combustion Engines)
CFR 63 subpart ZZZZ)
Stationary reciprocating internal combustion
engines (usually gas or diesel generators) at veterinary facilities are probably
subject to this standard if they:
- Are part of a facility that is major source for HAP (i.e. that has the
potential to emit at least:
tons/year of a single HAP, or
tons/year of a combination of HAPs
- Are over 500 horsepower
- Were built after December 19, 2002
Note: Only healthcare facilities that
are part of a large entity such as a prison, university or military base are
likely to be major sources under the CAA. The full set of applicability
criteria for various cases is somewhat elaborate. To find out more about how EPA regulates stationary engines and the applicability of the RICE Rule, see the EPA Region 1 RICE page.
CFR 61 Subpart M)
A veterinary facility that performs demolition
and renovation operations will be subject to the CAA NESHAP for asbestos. Here
is a brief summary of requirements; please refer to the additional resources
listed below for more details:
- A written notice of intention to
demolish or renovate must be submitted to EPA at least 10 working days
prior to the start of construction.
- No asbestos is to be stripped, removed,
or otherwise handled or disturbed unless at least one authorized
representative trained in NESHAP asbestos regulations is present.
- Asbestos must be removed prior to
demolition or renovation and proper precautions must
be made such as wetting down the material to keep it intact.
Additional resources for asbestos:
- The Asbestos
Informer gives a concise explanation of the risks posed by asbestos
and applicable regulations.
Region 10 (northwestern states) also provides an
index page with asbestos-related resources.
of Service: 8:30 a.m. - 5:00 p.m. (EST) M - F
800-368-5888 (available 24 hours a day)
Asbestos in Place: A Building Owner's Guide to Operations and Maintenance
Programs ("Green Book", available in paper copies only)
can be ordered through the Ombudsman.
Ethylene oxide (EtO)
Some healthcare facilities use ethylene oxide as a sterilant for certain types of healthcare supplies and devices. In some cases, manufacturers recommend this practice to ensure the sterility of a product.
On December 28, 2007 the Environmental Protection Agency published the Final National Emissions Standards for Ethylene Oxide Sterilizers, used by some healthcare facilities to sterilize medical devices. The standards generally require hospital ethylene oxide sterilization facilities to sterilize full loads of items to reduce hazardous emissions. Exceptions include when central services staff, a hospital administrator or physician on duty determine that a less than full load is medically necessary, or the sterilizer has an acceptable air pollution control device.
The purpose of Section 608 of the CAA is to
maximize the recovery and recycling of refrigerants during the servicing and
disposal of stationary air conditioning and refrigeration equipment. Requirements
covered under this section include:
EPA Region 2 provides an information
page on the Refrigerant Recycling Rule that includes compliance and technical
information for facility managers and contractors.
EPA Region 6 provides an information
page with links to documentation of recent rules related to leak repair
requirements and refrigerant venting, and to technical information.