SAIF Golden Charter

Don’t get bogged down in waste

The various laws and regulations governing the disposal of clinical waste are, without wishing to put too fine a point on it, a little dry.

Yet compliance is something no funeral director – regardless of size – can afford to ignore, with large fines and potentially serious reputational damage awaiting the ill-prepared. The good news is that putting the correct processes in place need not be too onerous, according to Inspector and former SAIF President Gemma O’Driscoll.

“It’s easy to get bogged down in the legislation, but the rules as they apply to funeral directors are actually relatively straightforward.

“They boil down to understanding what constitutes clinical waste, how you handle it, and identifying a provider who can dispose of it.”

One fundamental area over which there is still considerable confusion is what constitutes clinical waste. One common misconception is that only funeral directors offering embalming need concern themselves with the regulations. In her training courses, Gemma says a good rule of thumb is that any item that has touched the deceased during transportation, preparation and presentation must be treated as clinical waste.

“That includes everything from needles to disposable gloves, sheet or clothing,” she says. “Even cotton wool that you may have used to clean the deceased’s eyes. So when people say ‘we don’t have any clinical waste’ – and people do genuinely think that – I have to tell them that yes, they do.

“Processes vary across the country. Some hospitals will remove the clothing the deceased was wearing and place them into a gown, whereas others will leave the person’s clothing for the funeral director to deal with. But even if it’s just soiled gloves or tissues, at the most basic level everyone will have some clinical waste.”

The task of segregating waste into different types is a common headache, throwing up questions over how individual items are categorised. However, for the majority of firms, Gemma says all waste can usually go into yellow ‘infectious waste’ bags (obviously except for sharps, which must be disposed of in a sharps box).

In her role as an inspector, Gemma says she still encounters funeral directors who have disposed of clinical waste by incinerating it themselves, which is absolutely prohibited. “Regardless of the quantities involved, you will need to contract a specialist waste disposal company to collect your clinical waste. These companies are generally very approachable and prepared to work with funeral directors to find a solution that suits them.

“Even if you’re a very small business, it is usually possible to have a collection of one or two bags every month, or even every couple of months. The cost per bag is obviously less for larger or more frequent collections, but even for small collections it’s a relatively minor expense.”

There are also specific regulations regarding the transportation of clinical waste, which are often overlooked. According to Gemma, one common mistake among firms with several sites is driving waste themselves to a central office for collection and disposal, rather than arranging separate collections from each office.

Finally, with all the correct processes and services in place, funeral directors must ensure they have a good handle on their paperwork.

“You can follow the rules to the letter, but that’s no good if you don’t have the paperwork to prove it,” says Gemma. “When you’re running a business there’s so much paperwork flying around, but you really need to keep track of your clinical waste records. Have a box file and put all of the collection notes in there. Don’t treat it like a receipt you can throw away.”

“Where funeral directors break the rules around clinical waste, it’s almost always ignorance rather than anything malicious. But even unintentional breaches can result in a hefty fine, not to mention the reputational damage if it ends up in the local paper. Every funeral director needs to be on top of this, and it’s really not as onerous as it first seems.”