Commitment to Continuous Improvement

Even though BD employs best available technology, we believe in continuous improvement to further reduce emissions beyond government requirements. This includes periodic upgrades to technologies and processes. Our priority is to ensure a safe environment for employees and surrounding communities.

On August 20, BD committed in writing to Governor Kemp that the company will voluntarily further reduce emissions through an $8 million investment in BD’s world-class sterilization operations in Covington and Madison. Below are the actions BD committed to take, along with our current expectations of a timeline for the improvements that were included in the letter to Governor Kemp.

These actions include a proposed reactive dry bed system to control fugitive emissions of ethylene oxide (EtO). This new system is the result of innovations by BD and the medical technology industry to discover new systems and processes that will further reduce EtO emissions at our facilities. It is our understanding that there are no current systems employed anywhere in the world that capture and control fugitive EtO emissions to this extent. Once completed, BD will be among those leading the industry to capture and control trace levels of EtO that make up fugitive emissions at the facility. 

BD expects to continue operating the facility as improvements are implemented, although the company will need to temporarily suspend sterilization operations to ensure employee safety during certain stages of the implementation process. BD will advise EPD in advance when those will occur and will also announce any temporary suspension of sterilization operations on this website. 

Committed Improvements:

  • September 9-20, 2019: Licensed and accredited third party to perform stack testing in Covington to confirm EtO destruction efficiency from the regenerative thermal oxidizer (Pending availability of stack testing team from independent third-party firm recognized by Georgia EPD). The stack testing protocol will be sent to Georgia EPD five to 10 days before the test.
  • On or before October 31, 2019: Results of stack testing to be submitted to Georgia EPD as soon as possible after completion of test (estimated 30-45 days from day of stack test).
  • On or before October 31, 2019: Evaluate options for proposed reactive dry bed system to control fugitive emissions of EtO, prepare preliminary design of system, model effectiveness of proposed controls, and prepare and submit permit application to Georgia EPD for installation of dry bed system and any other fugitive emission control enhancements (approximately eight to twelve weeks).
  • Approximately two to four weeks after receipt of permit: Order equipment for control of fugitive emissions of EtO.
  • Approximately 26 to 40 weeks after receipt of permit: Install equipment for control of fugitive emissions of EtO, pending equipment vendor lead time

Historical Improvement Initiatives and Investments:

1991-2000:

  • Built current sterilization facility in Covington, which eliminated the use of Freon-12 to eliminate CFC emissions
  • Installed a regenerative thermal oxidizer to achieve greater than 99.95% EtO destruction
  • Captured and treated back vent exhaust. BD continued to capture and treat back vent exhaust, even as U.S. EPA rescinded this requirement.

 

2001-present:

  • Built current sterilization facility in Covington, which eliminated the use of Freon-12 to eliminate CFC emissions
    Installed a regenerative thermal oxidizer to achieve greater than 99.95% EtO destruction
    Captured and treated back vent exhaust. BD continued to capture and treat back vent exhaust, even as U.S. EPA rescinded this requirement.
  • Implementation of process improvements to reduce the use of EtO;
  • Control upgrades for enhanced monitoring and control; and
  • Further process adjustments for improved removal of EtO.
  • BD’s Madison facility was built in 2006 with latest technologies and processes that are used in the Covington facility.