Dealing with a hazardous waste stream

The management of healthcare and clinical waste is an essential part of ensuring that healthcare activities do not pose a risk to the environment or human health and are securely managed.  
You will probably already be well aware of the series of brightly coloured bins and bags that are used to collect particular wastes, from syringes and needles (sharps) to drugs, vaccines, cultures and cytotoxic wastes. What you might not necessarily be aware of are the stringent regulations that apply to the handling and disposal of these wastes.
Current regulation concerning clinical waste disposal is strict, and there exists a sizeable range of legislation relating to healthcare waste. To effectively manage this waste stream, those responsible for the management of the waste should understand and must comply with the requirements of the various regulatory regimes, which include environment and waste; controlled drugs; infection control; health and safety; and transport.
Key requirements
The key regulatory requirements are found under the Controlled Waste (England and Wales) Regulations (2012), which were implemented on 6 April 2012. These regulations replaced earlier regulations and set out what is classed as clinical waste. Essentially, this is waste from a healthcare activity (including veterinary healthcare) that contains viable micro-organisms or their toxins which are known or reliably believed to cause disease in humans or other living organisms. It is classed as waste that contains or is contaminated with a medicine that contains a biologically active pharmaceutical agent. Clinical waste is also waste that is a sharp, or a body fluid or other biological material (including human and animal tissue) containing or contaminated with a dangerous substance within the meaning of Council Directive 67/548/EEC on the approximation of laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances, and waste of a similar nature from a non-healthcare activity.
The definition also includes any other waste arising from medical, nursing, dental, veterinary, pharmaceutical or similar practice, investigation, treatment, care teaching or research, or the collection of blood for transfusion, being waste which may cause infection to any person coming into contact with it.

In practice, the term ‘clinical waste’ is used to describe wastes produced directly from healthcare and which require specialist treatment and disposal, such as infectious wastes and pharmaceutical products.
The Governments Guidance on the safe management of healthcare lists the relevant legislation and sets out best practice for clinical waste. This is often classified as ‘hazardous’, ‘offensive’ or ‘infectious’ and, using the Department of Health terms of definition, ‘offensive waste’ is waste that: may cause offence due to the presence of recognisable healthcare waste items or body fluids; does not meet the definition of an infectious waste; does not possess any hazardous properties; and is not identified by the producer, or holder, as needing disinfection, or any other treatment, to reduce the number of micro-organisms present.

Hazardous Waste
Many clinical wastes are also classified as ‘hazardous waste’ and are therefore subject to further legislative controls. Environment Agency guidance on Hazardous Waste identifies the following clinical wastes to be ‘hazardous’: known or potentially infectious waste; cytotoxic and cytostatic medicinal wastes; and dental amalgam.

‘Infectious’ and ‘potentially infectious’ wastes include all wastes which have been sent for specialist treatment and disposal because of their potentially infectious nature. Therefore, all wastes placed in clinical waste bags and sharps boxes and sent for treatment and disposal as clinical waste should be considered ‘hazardous‘.
There is no definitive list of cytotoxic and cytostatic medicinal products, but producers should consult material safety data sheets and seek specialist advice to establish whether the products have any specific hazardous characteristics.
Around 4.3 million tonnes of hazardous waste were transported from nearly 160,000 businesses and industry in England and Wales in 2011, so it is fundamental that professionals are aware of their responsibilities in dealing with this waste stream.

Segregation and Labelling
The Hazardous Waste Regulations place a duty on producers to segregate hazardous and non hazardous wastes. In addition a national colour coded healthcare waste segregation system has been published by the Department of Health and is considered best practice – this is available from page 52 of Safe management of Healthcare Waste.

Duty of Care
All waste producers are legally obliged to ensure that information about the nature of the waste is accurately described on Duty of Care transfer notes and where necessary on Hazardous Waste Consignment notes, to ensure that the waste is treated and disposed of properly. If these notes are completed by a third party (a waste contractor), producers have a legal duty to ensure that the information provided is correct and accurately reflects the waste being transferred.
A key element to the duty of care is the requirement for producers (other than householders) to ensure that a written description, adequately describing the type and quantity of waste, is provided for transfer of the waste as it is moved from point of production to point of final disposal. Waste can only be handed to such authorised persons as registered carriers, permit/licence holders or someone who is exempt from either being a registered carrier or operating under a permit/licence.

Health and Safety
Health and safety legislation is based on the assessment of risk. COSHH and the Management of Health and Safety at Work Regulations, in line with health and safety at work legislation, specifically require those dealing with potentially infectious substances (including waste) to assess the risk to the public and staff that may come into contact with it. Arrangements for managing healthcare waste should be part of an employer’s overall health and safety management system. In practice, this involves the development of risk assessment policies and procedures and putting in place arrangements to manage the risks effectively.

Transport and carriage legislation is based on the principles of hazard and risk assessment, and substances (including waste) are classified according to their primary hazard. The legislation requires consideration of: training of personnel involved in the chain of distribution; substance classification and identification; packaging; marking, labelling and documentation; safety advisor, equipment and emergency procedures; safe loading; vehicle specification and operation.

Further Information