Health Care Without Harm recently sent a letter to the Veterans Health Administration to re-evaluate their current policy that categorically prohibits SUD reprocessing, an essential component needed to meet their sustainability goals.
September 19, 2024
The Honorable Dr. Shereef Elnahal
Under Secretary for Health
U.S. Department of Veterans Affairs
810 Vermont Ave. NW
Washington, D.C. 20420
Re: Reprocessing of single-use devices essential for VHA's sustainability goals
Dear Dr. Elnahal,
In October 2022, the U.S. Department of Veterans Affairs released a sustainability plan outlining an ambitious series of goals toward a more sustainable future in response to Executive Order 14057 by the Biden administration, which requires federal agencies to achieve a 50% reduction in greenhouse gas emissions by 2030 and net-zero emissions by 2050.
Ensuring access to high-quality health care for our veterans requires large-scale mitigation of climate change. This responsibility extends to the Veterans Health Administration (VHA) and is recognized in the VHA’s sustainability plan with commitments to 100% carbon pollution-free electricity (Scope 2 emissions) and a 100% zero-emission vehicle fleet (Scope 1 emissions), among other items. However, 82% of emissions from the U.S. health care sector are Scope 3 emissions, with the purchase of goods and services making up about half of this percentage.
Currently, VHA Directive 1850.06 prohibits VHA facilities from utilizing Food and Drug Administration regulated reprocessing services that allow for collection and buyback of single-use devices (SUDs) by hospital systems.
The refusal to utilize a more environmentally preferable approach for disposing of SUDs is compromising the VHA’s ability to achieve its sustainability goals.
Given the environmental consequences of U.S. health systems’ increased reliance on SUDs, Health Care Without Harm analyzed data from Practice Greenhealth partner hospitals – including many in the VHA network – that submitted an Environmental Excellence Awards application in 2024.
This year, 293 non-VHA inpatient facility applicants reported their annual reprocessed device tonnage, with the median amount per inpatient facility being 1.42 tons. Using this calculation, Health Care Without Harm estimates that if all 172 VHA hospitals began reprocessing SUDs, the VHA could divert an estimated 244.9 tons – approximately 489,800 pounds – of waste annually.
There are good reasons to think this estimate of waste reduction opportunity is too conservative. The median VHA facility already performs better than other Practice Greenhealth hospital partners across a range of related sustainability metrics, per the 2024 Environmental Excellence Awards data. Specifically, VHA facilities achieved a median recycling rate of 32.6% of total waste, compared to an overall Practice Greenhealth median of 23.6%, ranking impressively at the 72nd percentile among all 2024 applicants. If VHA facilities similarly ranked in the 72nd percentile for tonnage of waste avoided due to SUD reprocessing, the median VHA facility could be expected to avoid 3.8 tons of waste per year. In the aggregate, such performance would mean that all 172 VHA hospitals could collectively avoid an additional 684.4 tons – or 1,368,800 pounds – of waste annually from SUD reprocessing.
Another reason the aforementioned analysis is likely too conservative is that it does not include the waste reduction opportunity associated with any VHA outpatient facilities beginning to reprocess SUDs. (This exclusion was due to Practice Greenhealth having limited access to SUD reprocessing data from non-VHA outpatient facilities, making it irresponsible to provide an estimate of the sustainability opportunity associated with VHA outpatient facilities potentially launching reprocessing programs. Of course, with nearly 1,200 outpatient facilities in the VHA network, it is reasonable to assume substantial additional waste avoidance could be realized from these facilities beginning to reprocess SUDs).
Assessing the emissions impact of this opportunity is difficult, given that medical device manufacturers are not required to conduct life cycle analyses on the climate impacts of their newly manufactured devices, nor is this a requirement for companies that reprocess SUDs. However, recent research supports that reprocessed SUDs have a substantially lower emissions impact compared to new versions of the same devices.
Earlier this year, Cardinal Health published a life cycle assessment showing their reprocessed compression sleeves had a 40% lower environmental footprint than new compression sleeves. A December 2022 study similarly found that remanufacturing of electrophysiology catheters can achieve up to a 60% reduction in emissions per use and a 57% reduction over the total lifespan of the device. Another analysis by Stryker Sustainability Solutions that evaluated the climate impacts of reprocessed SUDs found 23-51% lower emissions from five different commonly reprocessed SUDs compared to buying new.
For millions of SUDs purchased annually by all 172 VHA hospitals, there exists the opportunity to reduce Scope 3 emissions by anywhere from about one-quarter to nearly two-thirds. Not all of a hospital’s demand for SUDs can be met through reprocessing, but robust collection rates of used, reprocessable devices maximizes the sustainability opportunities associated with any reprocessing program – and the VHA has a robust track record of non-reprocessing-related waste diversion efforts.
Health Care Without Harm joins the Office of Inspector General’s recent recommendation to the VHA to re-evaluate the current policy that categorically prohibits SUD reprocessing. The VHA’s journey toward reducing Scope 3 emissions and achieving the goals set out in its sustainability plan will not be easy. Fortunately, partners within and outside of government – including Health Care Without Harm – are prepared to further support this commendable goal.
Health Care Without Harm appreciates the opportunity to contact you about the VHA’s sustainability goals and the importance of SUD reprocessing as an essential component of these goals. If you have any questions regarding this information, please contact me and my team at emediate@hcwh.org.
Respectfully,
Emmie Mediate, MSc, MPP
U.S. Chief Program Officer
Health Care Without Harm
Health Care Without Harm is an international NGO founded in 1996 that mobilizes the health care sector’s influence to create an ecologically sustainable, equitable, and healthy world. We work with health systems in the United States and around the world to reduce their climate impact and build climate-resilient facilities and communities.
Health Care Without Harm’s membership network, Practice Greenhealth, is the U.S. health care sector’s go-to source for information, tools, data, resources, and expert technical support on sustainability in a health care setting. We provide our growing membership of more than 1,700 hospitals with practical programming around governance for sustainability, impact areas to consider, and best practice protocols to achieve and measure meaningful results. We educate, motivate, and engage the entire sector to move toward the creation of high-performance healing and sustainable environments.