April 2001

The Director - Features

CJD and the Environment

Creutzfeldt-Jakob disease presents environmental issues for funeral service

In four previous articles appearing within The Director during the past year, issues relating to Creutzfeldt-Jakob disease (CJD) and funeral service have been considered: Dr. Paul Brown and George Lamb, “Creutzfeldt-Jakob Disease and the Mortuary Profession,” March 2000; James F. Burnside III, Curtis Rostad and Kurt Soffe, “A CJD Primer – Information funeral service practitioners should know when facing a case of Creutzfeldt-Jakob Disease,” July 2000; T. Scott Gilligan, “ADA vs. CJD – The legal aspects of handling Creutzfeldt-Jakob disease cases,” August 2000; and Edward M. Ranier, “CJD & OSHA – An examination of the OSHA requirements surrounding the preparation of victims of Creutzfeldt-Jakob disease,” September 2000. This article highlights the issues relating to CJD and the environment.

Although much has been written about CJD, the potential risk that CJD presents, and the steps required to minimize (but not necessarily avoid) the potential for transmission of CJD, little appears to have been written about CJD in the environment, including its short- or long-term viability and whether CJD survives over time in water, soil or air. 1

In March 1999, the World Health Organization (WHO) convened a three-day meeting in Geneva, Switzerland, of experts on CJD. Dr. Paul Brown, a senior research scientist at the National Institutes of Health in Bethesda, Maryland, and author of the March 2000 CJD article in this magazine, chaired the meeting. Guidelines on the prevention of exposure to CJD were prepared following the meeting – “WHO Infection Central Guidelines for Transmissible Spongiform Encephalopathies, Report of a WHO Consultation, Geneva, March 24-26, 1999” (WHO Consultation Report). The guidelines confirm that CJD is highly resistant to conventional chemical and physical decontamination methods. 2 The guidelines also document that CJD is not destroyed by formaldehyde, phenol, gluteraldehyde, alcohol, dry heat, boiling, ultraviolet radiation, autoclaving at 121 degrees C for 15 minutes, or standard gravity sterilization.

Despite these conclusions about the resistance of CJD-contaminated wastes and other materials and equipment to treatment, there appears to be no standard, generally accepted practice for waste handling and disposal of CJD-contaminated fluids. In fact, recommendations for waste handling and disposal – even within the WHO Consultation Report – appear to be inconsistent. The WHO Consultation Report recommends that waste liquids and solids from persons with confirmed or suspected CJD must be captured and treated as infectious waste. 3 With regard to embalming fluids, the WHO Consultation Report recommends that, at the conclusion of the embalming procedure, the container of drainage fluids should be decontaminated by adding sodium hydroxide (lye) pellets at the rate of 40g per liter of fluid and “disposed of as for any other mortuary waste.” 4 In addition, preparation-room working surfaces are to be flooded with sodium hydroxide or with sodium hypochlorite (bleach) and left undisturbed for an hour. In his article in The Director in March 2000, Dr. Brown reiterated these recommendations. 5

The addition of the recommended amount of sodium hydroxide to embalming fluids will dramatically change the regulatory character of the resulting fluid, causing it to be a regulated hazardous waste under the Resource Conservation and Recovery Act (RCRA). Ordinarily, embalming fluids discharged to sewers and septic systems are not regulated hazardous wastes. The addition of sodium hydroxide causes the pH of the fluid to become extremely basic, around 13 or 14, depending upon the composition of the fluid to which the sodium hydroxide is added. This pH is highly “corrosive” or “caustic.” Because of the high pH – above 12.5 – the resulting solution and all other wastewater with which it is mixed are considered RCRA-regulated hazardous wastes.

Contrary to the statement in the article, this RCRA-regulated wastewater can no longer be disposed of “as for any other mortuary waste.” Because the liquid has become an RCRA-regulated hazardous waste, special handling, notification and other requirements must be met if the wastewater is to be disposed of in the sewer system. This high-pH wastewater may be disposed of in the sewer only if it mixes in the sewer with domestic sewage, and only if specific notification (including a description of the nature and character of the waste) is provided to the Environmental Protection Agency (EPA), the state EPA, and the local wastewater-treatment authority. The local wastewater-treatment authority may have a prohibition against the discharge of this high-pH solution into the sewer system. This change in pH may be considered a substantial change in the character of the funeral home's discharge, in which case advance notification must given to the regulatory authorities prior to discharge. The wastewater may not be trucked or hauled to the sewer system because of the prohibition on such disposal of RCRA-regulated waste. If the mixture is trucked or hauled, it must be handled as a hazardous waste, transported by a licensed RCRA hauler, and taken to a permitted RCRA hazardous-waste facility.

Disposal of this high-pH solution into a septic tank is strictly prohibited. No RCRA-regulated hazardous waste may be disposed of in a septic system. Beyond that, disposal of the solution into a septic tank will most likely lead to process failure. A pH in this high range would be expected to kill system microbes.

Both sodium hydroxide and sodium hypochlorite can be quite dangerous to handle. Both are potentially hazardous, 6 especially when mixed with other compounds. Neither of these chemicals – or other chemicals generally – should be used without full knowledge of their properties, appropriate training, and work-practice or engineering controls for those who use or otherwise are exposed to the chemical. 7 Sodium hydroxide is highly caustic and will cause the fluid to which it is added to become quite hot. Contact with sodium hydroxide or with sodium hypochlorite may cause severe burns to skin and eyes, and skin contact should be avoided. Special precautions need to be observed with respect to the handling of these chemicals to ensure that injury does not result from their use.

The fact that there is so little known about CJD in the environment, the inconsistencies in CJD-waste handling recommendations, and the hazards associated with the chemicals available to detoxify CJD all raise serious – and unanswered – questions for funeral service practitioners and their handling of CJD-contaminated wastes.

Footnotes

1 There is some indication – based upon one study – that the infectivity of scrapie, the name given to the CJD disease in sheep, continues when tissue infected with scrapie is mixed with soil, embedded in a soil-containing pot, and buried in a garden for three years. (Brown P., Gajdusek DC. “Survival of scrapie virus after 3 years' interment.” Lancet 1991. 16:98-99.)

2 WHO Consultation Report, Section 6.1, Decontamination procedures, General considerations.

3 WHO Consultation Report, Section 6.4, Decontamination of wastes and waste-contaminated materials.

4 WHO Consultation Report, Section 8.4.2, Embalming.

5 The article also states that the 40 grams sodium hydroxide per liter of fluid is approximately one pound of sodium hydroxide per gallon of fluid. One pound is 454 grams and one gallon is 3.785 liters. This corresponds to 120 grams per liter, which is three times the 40-grams-per-liter dose. The pH at 25 degrees C with a dose of 120-grams-per-liter sodium hydroxide will be 14.48. Prof. Edward Bouwer, Dept. of Geography and Environmental Engineering, The Johns Hopkins University, Baltimore, Maryland, calculated the pH values of the sodium-hydroxide solutions.

6 EPA has designated both sodium hydroxide and sodium hypochlorite as hazard substances under the Clean Water Act and the Comprehensive Environmental Response, Compensation and Liability Act (Superfund).

7 See Edward M. Ranier, “CJD & OSHA,” The Director, September 2000, p. 68.

Carol Lynn Green, Bethesda, MD, is NFDA's specialty counsel for environmental compliance.