The U.S. healthcare system produces roughly 8.5% of the country’s total carbon emissions. While the federal government remains polarized on issues surrounding healthcare and the environment, a new paper argues that healthcare systems can mitigate this impact by adopting the principles of Private Environmental Governance (PEG), a model for private action that has already produced significant benefits inother industries.
“Private Health Governance and the Environment,” by Lauren R. Roth and Ethan Thorpe, calls for hospitals and accreditors to adopt what they call Private Health Governance standards to promote energy efficiency while reducing waste and emissions. They argue that efforts like Walmart’s Project Gigaton, which eliminated more than 1 billion tons of carbon dioxide from its operations in less than seven years, prove PEG’s ability to reduce environmental degradation, even if they are not solutions unto themselves.
Because environmental and human health are intertwined, “applying PEG tactics to healthcare is not just a practical, but a necessary step forward for the U.S. healthcare system,” they write.
“Private Health Governance” analyzes the history of PEG, how private organizations have adopted its tactics, and where it could help in the healthcare sector. They also discuss the value of promoting PEG’s economic benefits and maintaining a connection between environmental and health law in the wake of the EPA’s decision to stop considering lives saved when setting rules on air pollution.
“Isolating environmental and health law at a time when both face unprecedented retrenchment is a tactic that can be combatted with efforts to promote synergies between the two fields,” the authors note.
The Economic Benefits of Private Health Governance
While the article concedes that PEG initiatives would involve significant up-front investment for healthcare providers, it denotes many tactics that provide significant savings at little to no cost. Managing usage of energy-intensive imaging technology like MRIs, automated medication dispensing systems, and transitioning from inhaled to intravenous anesthetics quickly reduce energy consumption and expenditures.
For larger, capital-intensive efforts, “green” financing opportunities can help offset the expense, allowing systems to undertake resilience projects that save assets in the event of extreme weather events.
How to Implement Private Health Governance
The authors recommend any PHG initiative start “with the most apparent changes.” They point to airlines, which have been slow to adopt costly sustainable aviation fuel but more willing to eliminate single-use plastics on flights. “Simple methods like this,” they note, “can help organizations fill gaps between environmental needs and current practices.”
Likewise, they advocate for setting standards that include carrots as well as sticks, with flexibility to account for the realities of healthcare providers operating in different environments. Large organizations can lend resources to help partners meet their own goals; they cite Walmart’s partnership with HSBC to offer better financing terms for suppliers engaging in sustainability projects as a prominent example.
A Stopgap That Addresses Environmental and Health Challenges
The article confronts stark realities about the state of healthcare in the U.S. “Excessive costs are passed on to patients who pay more in the United States than peer countries but receive inferior care. Meanwhile, overtreatment, waste, and low-value care make the U.S. healthcare system the most environmentally damaging in the world.”
At a time when “public governance is unlikely to address the underlying problems,” the authors propose using private alternatives “as a gap-filling measure.”
“Embedding environmental sustainability into accreditation, which is already overwhelmingly performed by private organizations, can induce life-saving and cost-effective changes throughout the healthcare system while promoting every pillar of healthcare quality.”
“Private Health Governance and the Environment” is published in the July / August 2026 edition of the Environmental Law Reporter. Lauren R. Roth is an Associate Professor of Law at the Elisabeth Haub School of Law at Pace University. Ethan Thorpe is the Climate Governance Fellow at the Private Climate Governance Lab at Vanderbilt University Law School.