Understanding the NHS clinical waste strategy

The NHS is one of the largest providers of waste in the country, producing approximately 156,000 tonnes of clinical waste a year. That waste is either sent to high temperature incineration (HTI) or for alternative treatment (AT), which is equivalent to over 400 loaded jumbo jets of waste

In January, NHS England produced a clinical waste strategy, which is aimed at addressing how best to deal with the large amounts of waste created.
The strategy is part of a group of documents, which includes the NHS waste planning tool. The documents are aimed at helping the NHS reach its targets of net zero for direct carbon emissions by 2040 and net zero for indirect carbon emissions by 2045.
The foreword to the report, by Simon Corben, director of estates and head of profession at NHS England recognises the large amount of waste produced by the organisation and acknowledges “it is vital that the NHS disposes it in a safe, efficient and sustainable manner, and we are only creating waste when absolutely necessary”.
Corben says: “The best waste management practices reduce waste, improve compliance and can lead to significant cost savings from lower waste volumes. They also have a significant part to play in minimising harm to the environment and increasing resource utilisation. This all leads to a reduction in carbon generated from waste and saving taxpayers money.”
It is expected that with the implementation of the strategy over the next ten years, the NHS can save approximately £11 million a year in recurrent revenue costs and reduce carbon emissions from waste by around 30 per cent – equivalent to 2 million road miles a year.
Corben adds: “I encourage all NHS providers to embrace and adopt this strategy and embed the steps from the action plan as part of their daily waste management practices.”

The strategy has among its aims improving waste management practices across providers including NHS trusts, NHS foundation trusts and primary care and to make them more sustainable and efficient and therefore save on cost, improve hospital function and reduce the impact on the environment.
The key objective of the strategy is to eliminate waste and turn it into a resource.
It is important that waste is minimised, treated and disposed of in a safe way that minimises environmental harm and therefore protects patients, staff, the NHS and the wider community. Providers must comply with waste legislation and regulations.
It is a rolling ten-year strategy, comprising of annual reviews and implementation plans for one and three years ahead. Though it mainly covers clinical and offensive waste, it is relevant for all types of waste produced by the NHS.
Clinical waste refers to waste containing viable micro-organisms or their toxins which are known or reliably believed to cause disease in humans or other living organisms; waste which contains or is contaminated with a medicine that contains a biologically active pharmaceutical agent; and sharp waste, or a body fluid or other biological material (including human and animal tissue) containing or contaminated with a dangerous substance as defined by EC No 1271/2008 (The Classification, Labelling, and Packaging Regulation).
Waste that has the highest potential of harm to people or the environment must be treated with high temperatures, for example with incineration (HTI). Lower risk waste can be treated using alternative treatment methods (AT) including sterilisation.
Offensive waste (OW) has no hazardous properties and can be treated or disposed of in a similar manner to municipal waste.     

Areas of improvement
The strategy outlines six areas of focus for improvement: data, workforce, compliance, commercial, infrastructure and sustainability. Each area of improvement has a KPI against which to measure improvement.
Three areas of improvement come under “Productivity” – data, workforce and compliance. In order to “use better data”, comprehensive, consistent data from across all NHS organisations and Integrated Care Systems needs to be utilised to drive decision making and proactive risk management. The KPI for this area is that all clinical waste generated by NHS providers will be regularly reported with a minimum of 95 per cent accuracy by 2024.
For workforce, the aim is to invest in a skilled workforce. This means investing in developing a skilled and diverse waste management workforce with appropriate support and defined career paths. The measure of success in this respect will be 100 per cent of NHS trusts and foundation trusts having a dedicated waste manager role by 2023.
With regards to compliance, the strategic priority is to “improve our ability to comply”, by ensuring all NHS staff understand and adhere to compliance requirements.
Two other areas for improvement – commercial and infrastructure – come under the heading “Resilience”. A commercial model should be established that delivers better value. This involves supporting the standardisation of contracting arrangements and developing a commercial model which encourages healthy market conditions. The KPI here is the average net cost of clinical waste management reducing by 15 per cent per tonne of waste by 2030.
With regards to infrastructure, it is intended that resilient infrastructure that meets future demand will be developed. This involves investing in clinical waste infrastructure to increase capacity and regional resilience and support sustainable waste processing practices. As a measure of success, all NHS providers will introduce arrangements for the management of the offensive waste stream by 2023.
Finally, Sustainability comes under Net Zero Carbon. The aim is to improve use of resources and reduce carbon impact by proactively working to reduce harmful emissions, improve local air quality and achieve the 2045 net zero carbon target. The measure of success here is achieving a 50 per cent reduction in the carbon emissions produced from waste management by 2026 and an 80 per cent reduction by 2028-32.

Staff awareness
It is important that all NHS staff are aware of and actively involved in improving waste management practices. All members of staff, clinical and non-clinical are responsible for sustainable waste management, which reduces cost and has a smaller impact on the environment. This starts with improved compliance in the segregation of waste types.

Waste hierarchy
DEFRA describes a waste hierarchy which ranks waste management options according to what is best for the environment, with highest priority given to avoiding waste in the first place. Then if waste is created, it should be correctly segregated, with priority then given to preparing it for reuse, recycling, recovering for energy use and disposal in that order – with the last option landfill. The strategy states: “Following the waste hierarchy when making all waste management decisions in the NHS is central to good practice and to achieving the objectives of this strategy.”
The strategy highlights the responsibility that the NHS has when it comes to reducing and managing waste effectively and sustainably. It is important that everyone is on board and involved with waste management practices. If this strategy is implemented effectively, then it will have a significant impact on the amount of waste produced and how that waste is then treated in terms of monetary cost and cost to the environment.

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