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Industry Overview
Healthcare is a paradox: an industry dedicated to human wellbeing that simultaneously contributes significantly to the environmental conditions that threaten it. If the global healthcare sector were a country, it would rank as the fifth-largest emitter of greenhouse gases on the planet. In the United States alone, healthcare accounted for about 8.5% of national GHG emissions in 2018, according to a 2020 study in Health Affairs—driven by energy-intensive facilities, complex supply chains, and enormous volumes of single-use materials.
The COVID-19 pandemic exposed both the sector's fragility and its wastefulness. Hospitals consumed unprecedented quantities of disposable PPE, generated mountains of infectious waste, and ran facilities at maximum energy intensity. But the pandemic also demonstrated healthcare's capacity for rapid operational change—a capacity that sustainability advocates argue should be directed toward decarbonization and resource efficiency.
The business case is increasingly clear. The U.S. healthcare system spent $5.3 trillion in 2024, according to the Centers for Medicare & Medicaid Services, with energy and waste representing significant controllable costs. Health systems that have invested in sustainability—Kaiser Permanente, Cleveland Clinic, NHS England—report material savings alongside emissions reductions. As climate-related health impacts increase (heat-related illness, vector-borne disease, respiratory conditions from wildfire smoke), healthcare organizations face a dual imperative: reduce their own environmental impact while building resilience to serve communities facing climate-driven health crises.
Key Sustainability Challenges
Energy-Intensive Operations
Hospitals operate 24/7/365, with HVAC systems maintaining precise temperature and humidity controls, surgical suites requiring high air-change rates, and diagnostic equipment drawing substantial power. U.S. inpatient hospitals use nearly three times as much energy per square foot as office buildings, according to the Energy Information Administration's 2018 Commercial Buildings Energy Consumption Survey. Decarbonizing these operations without compromising patient care or infection control requires careful engineering and phased investment.
Medical Waste and Single-Use Culture
U.S. hospitals generate approximately 5.9 million tons of waste annually, according to Practice Greenhealth, with regulated medical waste representing only a fraction. The World Health Organization estimates that about 85% of health-care waste is general, non-hazardous waste, yet conservative segregation practices send some of it into costlier regulated medical waste streams. Single-use devices, surgical draping, and pharmaceutical packaging contribute to an enormous waste stream. Shifting toward reprocessed devices, reusable textiles, and reduced packaging encounters resistance rooted in infection control concerns, even when evidence supports the safety of alternatives.
Pharmaceutical and Supply Chain Emissions
The pharmaceutical supply chain is carbon-intensive, involving chemical manufacturing, cold-chain logistics, and global distribution networks. Health Care Without Harm's 2019 global analysis found that 71% of health care's emissions come from the supply chain (Scope 3), through the production, transport and disposal of goods and services. Engaging pharmaceutical companies, medical device manufacturers, and distributors on emissions reduction requires purchasing leverage and consistent demand signals that individual health systems rarely possess alone.
Regulatory Landscape
Healthcare sustainability regulation is emerging but unevenly applied. The NHS in England has committed to reaching net-zero by 2040 for direct emissions and 2045 for its supply chain—the first national health system to set such targets, backed by regulatory requirements for NHS trusts. The EU's CSRD, narrowed by the 2026 Omnibus I directive, applies to healthcare companies with more than 1,000 employees and more than €450 million in net turnover; companies newly in scope first report for financial year 2027. The EU's revised F-gas Regulation has also banned the use of desflurane, a potent greenhouse gas used as an anesthetic, since January 1, 2026, except where no other anesthetic can be used on medical grounds.
In the U.S., federal regulation is limited. Medical waste is regulated mainly by state environmental and health departments, multiple states regulate pharmaceutical waste disposal, and EPA sets air emission standards for hospital and medical waste incinerators. The Joint Commission and CMS conditions of participation include environmental management requirements, though these are primarily focused on safety rather than sustainability.
The Inflation Reduction Act's elective pay provision lets tax-exempt hospitals and health systems receive clean energy investment credits (section 48 and its successor, section 48E) as cash payments, incentives previously available only to taxpaying entities. The July 2025 budget law narrowed them: solar and wind projects now qualify only if they began construction by July 4, 2026 or are placed in service by the end of 2027, while storage and other technologies keep the credit longer. The section 179D deduction for energy-efficient commercial buildings, which tax-exempt owners could allocate to a building's designer, ended for projects whose construction began after June 30, 2026.
Opportunities
Energy efficiency represents the largest near-term opportunity. ENERGY STAR data show that certified hospitals, which rank in the top quarter nationally, use 35% less energy than the typical hospital, suggesting significant headroom for improvement. LED lighting, variable-speed drives, heat recovery systems, and building automation upgrades deliver strong returns. Combined heat and power (CHP) systems are particularly well-suited to hospitals' simultaneous need for electricity, heating, and cooling.
Waste reduction and diversion generate both cost savings and environmental benefits. Health systems implementing waste segregation programs, reprocessing of single-use devices, and food waste reduction initiatives report lower waste disposal costs. Hospitals and surgical centers saved $495 million by using reprocessed single-use devices in 2025, according to the Association of Medical Device Reprocessors.
Climate resilience is an increasingly urgent investment area. Hospitals that invest in backup power, flood protection, supply chain redundancy, and heat-resilient design protect both their communities and their financial viability. Climate-resilient facilities maintain operations during extreme weather events that can shutter unprepared competitors.
How Council Fire Can Help
Council Fire works with health systems, hospital networks, and healthcare companies to develop sustainability strategies that respect the sector's unique constraints. We conduct facility-level energy audits and portfolio carbon assessments, develop decarbonization roadmaps aligned with science-based targets, and design waste reduction programs that maintain clinical safety standards. Our team understands healthcare's regulatory environment, infection control requirements, and the operational realities of 24/7 clinical facilities.
We support health systems in engaging their supply chains on sustainability, building internal governance structures, and reporting under frameworks relevant to healthcare including GRI, CDP, and the Health Care Climate Council's guidance. For health systems accessing Inflation Reduction Act incentives, we provide technical guidance on project qualification and implementation.
Frequently Asked Questions
How can hospitals reduce energy use without compromising patient care?
Start with systems that don't directly affect clinical operations: lighting, building automation, plug load management, and central plant optimization. Retro-commissioning—ensuring existing systems operate as designed—cut energy use by a median 5% at inpatient hospitals in a 2020 Lawrence Berkeley National Laboratory study of commissioning projects. For deeper savings, consider ventilation optimization in non-clinical areas (lobbies, offices, storage) and demand-controlled ventilation in spaces with variable occupancy. ASHRAE Standard 170 provides evidence-based ventilation rates for healthcare facilities that, when applied correctly, can reduce energy use while maintaining appropriate air quality.
Is reprocessing of single-use medical devices safe?
Yes, when performed by FDA-regulated reprocessors. The FDA regulates reprocessed single-use devices under the same quality standards as new devices. Third-party reprocessors like Stryker Sustainability Solutions must validate cleaning, sterilization, and functional testing for each device type. In 2025, 11,458 hospitals and surgical centers in 18 countries used reprocessed devices, according to the Association of Medical Device Reprocessors. Studies published in peer-reviewed journals have found no difference in clinical outcomes between new and reprocessed devices across multiple device categories.
What is the Health Care Climate Council and should we join?
The Health Care Climate Council, convened by Health Care Without Harm, brings together leading health systems committed to climate action. Members include Kaiser Permanente, CommonSpirit Health, Mass General Brigham, and other major systems. Membership provides access to peer learning, technical resources, and collective advocacy. For health systems serious about sustainability, it offers a structured framework for benchmarking progress and learning from peers. Members must also belong to Practice Greenhealth, Health Care Without Harm's membership organization, and commit to a baseline emissions inventory and a public goal of net zero by 2050, with a 50% cut by 2030.

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