Special or Hazardous Waste

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Revision to Safe Disposal of Clinical Waste

• Wendy Rayner, Enviros Consulting Ltd.

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In summary

• Why re-write the guidance ?
• Steering Group changes in UK Regulation
  guidance
• Hazardous waste
• Classification of infectious Waste
• Classification of medicinal wastes best practice
  colour coding
• Classification of sharps waste
• Guide to Waste Management Licences Exemptions
• Consultation process

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Why re-write the guidance ?

• Changes in waste management regulation, notably
  Landfill Waste Regulations 2002, Hazardous
  Waste Regulation 2005
• Changes in carriage regulations, notably
  amendments to CDGTPE 2004 Regulations (ADR 2005)
• Changes in waste segregation the need to
  segregate and identify waste destined for
  different disposal routes.

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Project Management
NHS Estates
Steering Group
Classification Segregation
Transport
Treatment Disposal
Working Groups
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Who influenced the guidance

• Steering Group included representatives from
• NHS NI
• NHS Scotland
• NHS Wales
• NHS England
• PASA
• SEPA
• EHS
• EA
• DEFRA
• Total 14

• Working Group included representatives from
• SMDSA
• FTA
• NHS Trusts
• NPAG
• PIRA
• DoT
• WAMITAB
• Total 28

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Devolved Regulation of Hazardous Waste
Scotland The Special Waste Amendment (Scotland)
Regulations 2004. (1st July 2004) England The
Hazardous Waste (England and Wales) Regulations
2005. (16th July 2005) Wales The Hazardous
Waste (Wales) Regulations 2005 (16th July 2005)
Northern Ireland The Hazardous Waste
(Northern Ireland) Regulations 2005 (16th July
2005)
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Hazardous Properties

• H1 Explosive H8 Corrosive
• H2 Oxidising H9 Infectious
• H3A Highly Flammable H10 Toxic for Reproduction
  
• H3B Flammable H11 Mutagenic
• H4 Irritant H12 Substances that release toxic
  gases
• H5 Harmful H13 Substances capable of yielding
  substances listed above
• H6 Toxic H14 Ecotoxic
• H7 Carcinogenic

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What is HazardousWaste ?

• Regardless of regulatory regime-
• guidance on the interpretation and classification
  of hazardous waste available
• in one document WM2
• Available to download from
• http//www.environment-agency.gov.uk

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WM2 is Based on the EWC

• 20 Chapters relating to industry sectors
• For example
• Chapter 1 Wastes Resulting from Exploration,
  Mining, Quarrying, and Physical and Chemical
  Treatment of Minerals
• Chapter 2 Wastes from Agriculture,
  Horticulture, Aquaculture, Forestry, Hunting
  and Fishing, Food Preparation and Processing.
• Chapter 20 Municipal Wastes (Household waste and
  similar commercial, industrial and
  institutional wastes) including separately
  collected fractions.
• (Chapter 16 Wastes not Otherwise Specified on the
  List)

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EWC is Colour Coded

• The EWC is colour coded to aid the identification
  of hazardous waste.
• Non-hazardous entries are shown in BLACK text.
• Absolute entries are shown in RED text.
• Mirror (or threshold entries) are shown in BLUE
  text.

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New Classification of Infectious

• Not new originates from Hazardous Waste
  Directive
• In WM2 Joint Agencies Hazardous Waste guidance
• Infectious
• Substances containing viable micro-organisms or
  their toxins which are known or
• reliably believed to cause disease in man or
  other living organisms.
• WM2 provides additional guidance

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Appendix C9 WM2

• Is the waste listed in chapter 18 (Healthcare
  Waste) of the EWC?

YES
Does the waste arise from (or is contaminated
with) material from a human / animal clinically
assessed to have a disease caused by a
micro-organism or its toxin ?
NO
YES
Is the waste a culture, or enrichment of a
micro-organism or toxin known or reliably
believed to cause disease in man or other living
animal. OR A sample for an animal or animal known
or clinically assessed to have a disease caused
by a micro-organism or its toxin.
Does the waste contain the viable causal pathogen
or toxin ?
YES
NO
YES
NO
Special Requirements DO NOT Apply NOT Hazardous
by H9
Special Requirements Apply Hazardous by H9 EWC
Codes 18 01 03 / 18 02 02
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Unified Classification - New Guidance

• 'Unified approach linking waste and carriage
  (transport) definitions
• Take into account Hazardous Waste and transport
  changes.
• Practical interpretation of WM2
• What is infectious

It should be noted that waste contaminated with
the fluids (liquid or dried) listed in column 2
may be considered infectious if they contain
visible blood or there has been a clinical
assessment that an infection pathway exists from
the waste
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Better segregation
18 01 03
18 01 04
20 03 01
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Classification of Medicinal Wastes

• Old Special Waste Regulations reference to
  POMs
• EWC does not have a category for POMs

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Defining cyto toxic cyto static waste

• Term cyto toxic defined and understood (BNF
  Chapter8)
• Proposed UK definition for cyto static
• Proposed definition based on tried tested
  approach in USA, based on hazardous properties of
  pharmaceutical product
• Reliance on pharmacists to identify these
  products safety data sheets ?
• Opportunity for increased segregation

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Classification of sharps

• From Healthcare
• 18 01 01 Sharps
• 18 01 03 Waste whose collection disposal is
  subject to special requirements in order to
  prevent infection (infectious)
• 18 01 08 Cytotoxic cytostatic medicines
  (Hazardous drugs)

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Classification of sharps

• From Non-Healthcare Sources
• Sharps from the application of tattoos
• Sharps from cosmetic or body piercing
• Sharps from substance abuse (where not arising
  from healthcare)
• 20 01 99 Sharps waste for treatment
• Waste needs to be labelled and packaged
  appropriately still clinical waste still
  requires appropriate treatment/disposal.
• No need to register as a hazardous waste
  producer.

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Best Practice Colour Coding
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DRAFT NOT FINAL
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Waste Management Licences

• What is a waste management licence ?
• A conditional authorisation with the objective
  of ensuring that the storage, treatment or
  disposal of waste does not cause pollution of the
  environment, harm to human health or serious
  detriment to local amenities.
• When do you need one ?
• A waste management licence is required for all
  activities which involve the storage, treatment
  or disposal of waste. A licence is not generally
  required to store waste on the site of production
  however, there are limits to the quantities that
  may be stored without a licence.
• Are there any exemptions ?
• Yes - Exemptions from waste management licensing
  are mainly for small-scale waste storage and
  waste recovery operations and are subject to
  certain limitations.

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Common Exemptions (WML Regs1994)

• Storage of returned medicines to dispensing
  pharmacy by householder.
• Storage of waste on site of production
  (limitations apply).
• Preparatory treatment of certain wastes
  (shredding / bailing, etc).
• In addition the EA has identified certain low
  risk activities where they
• do not believe it is in the public interest to
  expect the operators to obtain a licence.

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Low Risk Activities - Exemptions

• Treatment by laboratory autocalve of containment
  level 1-3 microbiological laboratory waste on the
  premise it is produced
• Storage of waste medicines and denaturing of
  controlled drugs at a pharmacy returned by
  householders and by individuals
• Secure storage of sharps at a pharmacy returned
  by householders and by individuals.
• Secure storage of sharps as a result of
  operational work by local authorities, public
  bodies, emergency services, utility and transport
  companies pending disposal.
• In general exemptions should be registered with
  the EA

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Consultation

• Due October 2005
• Department of Health Estates web site.
• 6 week consultation period.
• Final guidance due to be published Spring 2006
• Incorporated in regional guidance throughout the
  UK.

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Wendy RaynerTel 07800 624364

• wendy.rayner_at_enviros.com