Comment - 22016 - Kelly Wright, MD, FACOG, FACS

To whom it may concern: I am a surgeon and healthcare sustainability researcher in Los Angeles. I appreciate the scrutiny of ethylene oxide and its risks for cancer. From a clinical perspective, I would like to see its use decreased and eliminated wherever possible. Ethylene oxide allows for the sterilization of surgical equipment and supplies that cannot undergo high heat or steam autoclaving. Largely it is used to sterilize single use products and their packaging, almost all of which is plastic or petroleum-derived. These single use supplies have created a culture of overconsumption and waste in medicine, leading us to vulnerability in the supply chain, a huge environmental impact, and increased healthcare costs. Currently US healthcare accounts for 8-10% of carbon emissions as well as significant plastic pollution in community waste facilities. Most of these emissions come from simple single use supplies that are cleaned with ethylene oxide. Healthcare textiles are largely plastic-derived, possibility representing an occupational hazard to those of us in operating rooms who wear these materials all day long. The use of ethylene oxide perpetuates these risks. Instead, evidence shows that reusable supplies and instruments are just as safe for patients, and cloth healthcare textiles are actually more protective for the user. Ethylene oxide has risks when it comes to proximity of use, and it builds in increased risk in our healthcare system as well, while polluting local communities. Therefore, its use should be scrutinized as much as possible, both from an exposure risk to an end-of life system risk as well.