Environmental Health

Page Updated: Oct. 10, 2024

CHA Advocacy Principle: Address the adverse effects of environmental issues on public health while preventing overly burdensome regulations on hospitals that could limit access to care.

What Has Been Completed:

Origin: Hospitals are facing a plethora of environmental regulation as Governor Polis has made addressing climate change a top priority for his administration. Among the ones CHA is tracking are House Bill (HB) 21-1286 (Energy Performance for Buildings), HB 22-1244 (Public Protections from Toxic Air Contaminants), and HB 22-1355 (Producer Responsibility Program for Recycling). Additionally, CDPHE and the Environmental Protection Agency (EPA) are working to re-classify ozone standards with implications for air permits.

Background: These laws and subsequent regulations will have varying impacts on the health care industry, as explained below.

Outstanding Items:

CHA continues to monitor and engage in these regulatory processes as necessary with respect to hospital’s unique role as both businesses with critical energy needs and advocates for public health improvements.

• HB 21-1286: Building Performance for Buildings – Implements Building Performance Standards (BPS) in order to meet sector-wide greenhouse gas (GHG) reduction targets of 7% by 2026 and 20% by 2030 from a 2021 baseline. This will impact hospital facilities.
• HB 22-1244: Public Protections from Toxic Air Contaminants Outstanding Items – A new program is being created in CDPHE over the next few years to regulate toxic air contaminants based on adverse health effects. This has a public health impact and could impact hospital facilities.
  • CHA Comment Letter (November 2023)
  • CHA Comment Letter (May 2024)
• HB 22-1355: Producer Responsibility Program for Recycling – A producer responsibility program is being created to provide recycling services to covered entities in the state. Companies that sell products in packaging, paper products, and food serviceware must fund a statewide recycling program to recycle these materials. Many medical products are exempt.
• CHA does not track or engage in local regulatory changes. However, for hospitals located in Denver, you can learn more about Energize Denver, a similar energy benchmarking requirement here.

Resources: 

• • HB 21-1286: Building Performance for Buildings
    • Draft Technical Resource Guide
    • Colorado’s Building Performance Website
    • Issue Brief on HB 21-1286, Energy Performance for Buildings
    • Building Performance Colorado Website
    • Finalized Rules
    • CHA Comment Letter
  • HB 22-1244: Public Protections from Toxic Air Contaminants Outstanding Items
    • • • AQCC Website on Toxic Air Contaminants
        • Initial Toxic Air Contaminant List (Oct. 2022)
  • HB 22-1355: Producer Responsibility Program for Recycling
    • CDPHE webpage on Producer Responsibility Program
  • State compliance with Clean Air Act
    • Coalition letter to EPA
    • Coalition letter to AQCC
    • Pre-hearing statement to AQCC
    • Proposed 2008 SIP
    • Proposed 2015 SIP

Meetings/Dates of Note:

• • HB 21-1286: Building Performance for Buildings
  • HB 22-1244: Public Protections from Toxic Air Contaminants Outstanding Items
    • April 2025: ACQQ designates priority toxic air contaminants
    • April 2026: Health-Based Standards and Emissions Controls established
  • HB 22-1355: Producer Responsibility Program for Recycling
    • Wednesday, Jan. 1, 2025: Producers begin paying producer responsibility dues.
    • Tuesday, July 1, 2025: Producers may not sell, offer for sale, or distribute any products that use covered materials unless they are participating in program.
  • State compliance with Clean Air Act

CHA Staff Contact: Phoebe Blessing, CHA manager, public policy, [email protected].