Updated Clinical Waste Guidance Issued

Late 1999 saw the publication of "Safe Disposal of Clinical Waste" by The Health Services Advisory Committee of The Health & Safety Commission (HSE Books 1999), a long awaited revision of the 1992 publication.  The new document however does not deal solely with health & safety issues but also covers risks to the environment, having been produced jointly by Health Services Advisory Committee (HSAC) and The Environment Agency (EA) and agreed by The Scottish Environment Protection Agency (SEPA).  In expanding and revising the previous publication, it also replaces Waste Management Paper Number 25 'Clinical Waste' issued by the Department of the Environment in 1983 which gave guidance on environmental aspects of handling these types of waste.

Although retaining the main feature of the previous publication in classifying clinical wastes into five main Groups (A to E), a number of important revisions have been made, reflecting changing legislation and practice within the industry.  One area that had always been a contentious issue is the classification of feminine hygiene and nappy waste collected from offices, shops, sports facilities and similar premises, with previous guidance often being ambiguous.  The new guidance advises that waste from human hygiene can usually be assumed not to be clinical waste, although due to their offensive nature and handling problems they should still be separately collected from other wastes. Many members of the Association offer services of this type.

A further area of confusion has been the differing requirements and definitions of clinical waste for  transport purposes to that in environmental legislation.  The issue of the carriage of clinical waste as 'dangerous goods' is now dealt with in a section of the guidance dealing with transport issues.  The need for UN Approved rigid containers for transport of clinical wastes from 1 Jan 2002 rather than the current practice of transporting loose sacks is highlighted, the UK having been allowed to continue with this practice unlike other European countries.

Advice on The Special Waste Regulations 1996 (which deal with more hazardous wastes) is also provided, reflecting the Environment Agencies policies regarding clinical waste generally not being special waste. Unfortunately the position regarding needles/syringes (which contain residues of prescription only medicines) being special waste does not refer to these Agencies policies in relation to failure to complete the required consignment documentation.

In dealing with disposal of wastes, the landfilling at suitably licensed sites of feminine hygiene, nappy and clinical waste classified as 'Group E' (ie: incontinence pads and related items assessed as having low risk of infection) is recognised as satisfying environmental and human health considerations and may be properly considered as an option for disposal.

The increasing use of thermal and chemical treatment systems for disinfection of wastes is also recognised as an alternative to incineration for those types which cannot be landfilled, subject to suitable verification of the effectiveness of the process on an ongoing basis. However in addition to the need for waste to be rendered safe and non-infectious dictated by current Regulations, the Agencies now require that treated wastes can not be distinguished from other similar non-clinical wastes.

Overall the guidance provides a useful reference document for both health and safety and environmental purposes to those involved in the production, collection, carriage, treatment and disposal of clinical and related wastes. This includes not only hospitals, doctors, dentists and clinics, but also premises such as nursing homes, vets, tattooists, chiropodists, funeral parlours and in the home. In addition to providing a summary it also signposts to more detailed sources of information and relevant legislation. The issue of the new guidance is welcomed by the Association as a step forward in defining and handling clinical and related waste as we enter a new millennium.