SAIF Golden Charter

Clinical waste compliance

Working in the clinical environment on a regular basis – I act as risk manager for several private hospitals – the issue of waste management often comes up. I have written on this subject before, but it is worth reiterating the facts.

The correct and proper management of clinical waste is vital for any organisation that produces hazardous waste, due to strict regulation in place to prevent harm being caused to the environment and human health.

Clinical waste refers to any waste that consists wholly or partly of:

* Human or animal tissue
* Blood or bodily fluids
* Excretions
* Drugs or other pharmaceutical products
* Swabs or dressings
* Syringes, needles or other sharp instruments which, unless rendered safe, may prove hazardous to any person coming into contact with it.

Waste legislation – know the key principles

The key principles of clinical waste regulations relate to the correct segregation, storage, disposal and documentation of waste.

The Safe Management of Healthcare Waste Memorandum (HTM 07-01), issued by the Department of Health, provides guidance on the secure and legally compliant management of clinical waste.

This recommends the segregation of clinical waste occurs at the point of production using colour coded waste receptacles and outlines a best practice waste segregation colour coding scheme for producers of waste to follow.

This separation ensures clinical waste legislation is adhered to and waste is stored, transported and disposed of in the correct manner.

Clinical waste transportation – ensure you are compliant with clinical waste transportation and packaging

The safe packaging and transport of clinical waste is governed by the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG) and ADR.

All vehicles transporting healthcare waste streams must meet the rigorous ADR regulations and comply fully with the carriage of dangerous goods.

The regulations outline the requirements for compulsory driver training to ensure the correct segregation of the waste within the vehicles. This prevents waste spillages and any potential harm to the environment or human health.

All waste carriers, with a few exceptions, must be registered under the Controlled Waste (Registration of Carriers and Seizure of Vehicles) Regulations 1991.

What you can’t do is to put the waste into your car and take it to a disposal site or your main funeral home for later collection.

Waste transfer notes

Appropriate documentation must be provided for all waste transfers. For non-hazardous waste this is usually in the form of a waste transfer note.

All clinical waste handling and disposal procedures must comply with the following regulations:

* The Environmental Protection Act 1990 (including the Duty of Care Regulations)
* The Controlled Waste Regulations 2012
* The Hazardous Waste Directive 2011
* The Carriage of Dangerous Goods Regulations

The main legislation governing clinical waste disposal is the Environmental Protection Act 1990. This states all producers of waste have a duty of care to ensure the correct and proper management of waste is performed and states that it is “unlawful to deposit, recover or dispose of controlled clinical waste without a waste management licence, or in a way that causes pollution of the environment or harm to human health”.

The main principles of ‘duty of care’ are about documenting the transfer of waste and ensuring that your waste is handled correctly by waste carriers (e.g. are you using a registered carrier of waste? Are they are taking waste to suitably licensed/permitted sites?). You should only use a contractor who can provide proof of compliance with the legislation.

Help is at hand – from your SAIF approved health and safety advisors

Safety for Business Ltd has been providing health and safety advice to SAIF members for many years. But just what is this help that’s available?

Well firstly, it is there to provide free telephone and email guidance to all members of SAIF. If you are uncertain about a matter to do with health and safety, you are entitled to use our support service completely free of charge. Safety for Business will not send you an invoice or try to get you to join a membership scheme.

If you need a more permanent relationship, Safety for Business can do two things for you. Initially it can come and visit you to see where you are with health and safety, and provide you with a full report on what was found and what you need to do to improve health and safety.

This really beneficial service costs just the price of the travel. But if you do want its assistance to fully comply with health and safety legislation the next thing we can do for you, as part of your SAIF membership, is offer a sizeable discount on Safety for Business’ fees. This stands at 20%, so why not take advantage? Talk to a safety professional at Safety for Business today by calling 08456 344 164.