1. Multi-Year Integrated Strategy for Funeral Home Compliance with the Safe Drinking Water Act Presented by: Margaret Halley, EPA Region 2 Division of Enforcement and Compliance Assistance

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

3.  Population of nearly 1,500,000  912 square miles  All potable water from federally designated Sole Source Aquifer  Two-thirds (2/3) of the county with no sewer access Primarily septic systems and cesspools  An estimated eighty funeral homes with on-site disposal systems Suffolk County, NY

4. Long Island, NY

5. Exterior of Funeral Home

6. Element 1: Develop a Statement of the Environmental Problem and Justification  Embalming waste fluids disposal to on-site waste system  Sampling and analysis results: Embalming chemicals Embalming chemicals chlorinated solventschlorinated solvents formaldehydeformaldehyde phenolphenol

7. Element 2: Establish Goals and Measures  Bring funeral homes into compliance with UIC regulations in Suffolk County  Compliance Assistance Voluntary Compliance Voluntary Compliance  Inspections and Enforcement Number with on-site embalming and injection Number with on-site embalming and injection Voluntarily ceasing injection Voluntarily ceasing injection Large Capacity Septic Systems Large Capacity Septic Systems Seepage pits Seepage pits Leachfields Leachfields Large Capacity Cesspools Large Capacity Cesspools Install septic system Install 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 goals

8. Prep Room

9. Element 3: Selecting and Sequencing Tools  Tools and Sequencing DataData Compliance AssistanceCompliance Assistance Compliance MonitoringCompliance Monitoring EnforcementEnforcement ComplianceCompliance Compliance as Part of Doing BusinessCompliance as Part of Doing Business

10. Element 4: Establish roles and Assign Responsibilities  Internal strategy was to maximize UIC inspector resources  External strategy was to establish working relationships with local and state governments, and with national, state and local funeral home trade organizations

11. Element 5: Develop an Implementation Plan, Schedule, and Milestones  Identify facilities with no sewer access – 61targeted  July, 2006, selected as three-day inspection initiative with overnight stay  Three teams of two inspectors, each to inspect at least 30 funeral homes (10 per day)  Hold meetings with inspectors Clarify issues specific to funeral homes Clarify issues specific to funeral homes Distribute inspection materials Distribute inspection materials Communicate how to follow-up Communicate how to follow-up  Determine: Number with on-site injection of embalming fluids Number with on-site injection of embalming fluids 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, 2005 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, 2005 Number ceasing injection – 100 % because of innovative technology Number ceasing injection – 100 % because of innovative technology Number requiring cesspool/seepage pit clean-up Number requiring cesspool/seepage pit clean-up

12. Remedial soil excavation of funeral home cesspool contaminated with chlorinated solvents, formaldehyde and phenol

13. Element 6: Designing Resources/Workforce Deployment  24 funeral homes remained to be inspected  Inspectors’ workloads deemed heavy  Individual inspectors, not teams  Day trips  No overnight stays because of funding reduction

14. Element 7: Communicating the Strategy  EPA Region 2 website: www.epa.gov/region02/water/compliance www.epa.gov/region02/water/compliance  New York State Funeral Directors Association (NYSFDA) diligent in outreach to members to advocate use of new technology to assist UIC compliance  Encourage the NYSFDA in its efforts Region 2 awarded NYSFDA with 2006 National Water Efficiency Leader Award and 2007 Region 2 awarded NYSFDA with 2006 National Water Efficiency Leader Award and 2007 Region 2 Environmental Quality Award for their outreach efforts.

15. Element 8: Monitoring and Evaluating the Strategy  Lab data = foundation  Good relationships with state and local governments critical as regulators & facilitators of EPA effort  Communicating with trade organizations a success  Increased UIC compliance  Implementation of innovative hold and haul technology, while concurrently reducing water consumption, from the traditional 120 gallons per embalming to only 5 gallons per embalming  Capacity building for compliance of funeral homes in rural areas of NYS obstacles because new technology not yet readily available

16. Element 9: Exiting the Strategy  Inspections completed as of April 30, 2008  Follow-up compliance orders to be completed by September 30, 2008

17. Medical Waste Blood Storage Box Waterless Aspiration Utilized