Safe Management and WM2 comment /discussion document
The following represents of White Rose Environmental Ltd and are based upon
 Simple practical measures to help health practitioners comply with the legal
requirements which
 It matches nursing practice so reducing the re-training/educational burden on the
NHS
 Lowers the cost burden on the NHS
 Aligns requirements with ADR
 Provides real benefits to NHS and the environment through change
The main questions raised by the consultation process:
Q: Do you agree with the recommendation that clinical waste is redefined as
hazardous infectious waste? If not, please give explanations? (Section 4.15)
Comments
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No. Not all of the waste in the HSAC categories A-D is from known
infectious agents. The majority of this waste is treated before landfill
disposal on a precautionary basis.
Hazardous infectious waste i.e. that requiring special precautions should
be waste containing or suspected to contain those biological agents in
o ADR category A or
o Where particular practices are carried out i.e. barrier nursing
that occur when there are known infection risks. Where
barrier nursing is carried out then the waste should be
regarded as being hazardous waste as special precautions are
in place to avoid infection. This would allow the
consignment of waste to follow to match nursing practice be
easier to train and educate nursing staff to the required
segregation practices required.
This would allow other healthcare wastes to be treated before landfill on
a precautionary basis but classed as non-hazardous.
Q: Do you agree with the methodology proposed of identifying and classifying infectious
and medicinal waste? If not, identify what alternative approach or methodology would
be more acceptable? (Section 5.0)
Comments
 The methodology proposed for infectious waste is a sensible approach to
identifying vectors of transmission. If this methodology is used in conjunction with,
as above, particular nursing practices i.e. barrier nursing, then this would enhance
the assessment of the waste stream identifying clearly to producers those wastes
that are hazardous.
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We would agree with the methodology for identifying hazardous medicinal
products and non-hazardous medicinal products, however the route for disposal
should also be made clear and this should be to incineration only. We also feel
there should be no deminimus i.e. even a discharged syringe that has contained
medicinal/chemical material should be sent for incineration.
Q: Do you agree with the benefits of introducing an “offensive waste” stream?
(Section 5.3)
Comments
 A non-hazardous healthcare waste stream has always existed, HSAC
category E waste. If the identification and consignment of hazardous waste
is matched to ADR cat A groups and nursing practice i.e. when barrier
nursing is instigated, then the majority of clinical waste i.e. that from
general nursing practices would be regarded as non-hazardous. This has the
cost advantage of reducing consignment costs to the NHS (estimated at
£30-£40 mill per annum in the regulatory impact assessment to the
Hazardous Waste Regulations consultation). The non-hazardous waste from
general nursing practice should be treated before landfill on a precautionary
basis.
Q: Do you agree with the benefits of a nationally based system of colour-coded
packaging? If not, please suggest any recommendations for an alternative
approach? (Section 7.1)
Comments
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Yes, provided it is not overly complicated. A national based system of
colour-coded packaging is beneficial, however the suggested colour coding
only allows for infectious hazardous and non-hazardous waste description.
Further to comments above a colour code should be introduced to allow
non-infectious waste to go to treatment before disposal. A suggested
scheme is
o Cytotoxic/cytostatic waste would be coded purple (18 0108)
o Incineration only waste would be coded yellow (180101, 180102,
180106, 180107, 180109)
o Waste for Treatment would be coded orange (treatment or
incineration) (180103, 180104)
o Waste going direct to landfill would be tiger stripe bag (180104)
Q: Views are sought on the practicality of segregating sharps waste contaminated
with cytotoxic/cytostatic medicinal products and sharps boxes not contaminated
with cyto-medications. Suggestions are sought as to how waste products can
demonstrate effective waste segregation. (Section 7.2)
Comments
The risk of improper segregation at Ward level is too great.
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All areas using Cytotoxic/Cytostatic should code all sharps as Hazardous
waste. The document suggests that sharps are knives and scapel blades and
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syringe needles without the syringe body. Given current nursing practice for
health and safety reasons it is impractical to suggest that syringe needles
will be separated from syringe bodies after administering a medicine.
Current practice is also to dispose of tubing/giving sets, spent ampoules,
medicine bottles and tablet bottles and blister packs in the nearest receptacle
after administering the drug; this is usually the sharps box.
Given these practices it is not currently possible for hospital premises to
practically segregate sharps waste. Given this information it is
recommended that all sharps waste should go to incineration.
If the definition given in the document for clinical waste were approved
then as all sharps containers are pre-marked UN 3291 then all sharps waste
would become hazardous waste by infection, regardless of the fact that they
may contain chemical/medicinal products. Materials with infection risk are
suitable for alternative treatment technologies; therefore it is reasonable that
a large amount of sharps waste will find its way to alternative treatment
plants. For this reason we would recommend that all sharps waste should be
sent to incineration.
Q: Do you have any other general comments you would like to make?
Comments
1. This document introduces a binding definition of ‘rendered safe’
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The definition and requirements given for ‘rendered safe’ would appear
to be a significant enhancement above the guidance given in the EA
document Technical Guidance on Clinical Waste Management
facilities. It is considered that a DH guidance document is not the
appropriate document for the EA to introduce new/significantly revised
guidance i.e. mandatory pre- or integral shred.
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The definition of rendered safe in the Ea Technical Guidance on
Clinical Waste Management Facilities includes the footnotes that the
waste need not be shredded if anatomical or sharps are not present in
the waste. If the segregation/colour coding practices described earlier
are followed i.e. all sharps to incineration, anatomical to incineration
then the need for treated waste to be shredded disappears.
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Where pre- or integral shred is mandated by the EA, this introduces an
activity into the workplace at a treatment site that will inherently have
infection risks during equipment breakdown or maintenance, especially
if the malfunction is to the cleaning / disinfections process. Current
Health & Safety Executive policy through risk assessment is to
eliminate risks first, however through the practice of mandatory preintegral shred the EA does not allow the operator the opportunity to
eliminate the risk and so brings the operator in conflict with health &
safety legislation and regulatory practice.
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The timescale and dates given for introducing the requirement to ‘pre
or integral shed waste at alternative treatment sites needs to be revised.
The document does not appear to allow any alternatives to preshredding for instance segregation. The desire for pre-shred appears to
originate following discovery of medical devices that withstand the
treatment cycle in alternative technologies. As segregation of other
waste streams not considered suitable for alternative treatment is
considered satisfactory e.g. radioactive waste, anatomical waste
segregation of specific medical devices would also seem appropriate.
The segregation of these devices and other devices/containers could be
made more successful if they were ‘source tagged’ with either an
electromagnetic or RFID tag and a detector installed at the treatment
site. The use of this type of RFID technology is well established in the
retail industry and so is available, low cost and extremely reliable.
Practice at the treatment site would be that once the detector alarms
then waste would be segregated for alternative disposal e.g.
incineration.
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This technology solution could also be employed to source tag other
medical devices or containers e.g. cytotoxic sharps bins that should not
find their way into non-incineration sites.
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As the document includes references to procurement practices for waste
management contracts, procurement contracts for medical devices
should also include information on manufacturers ensuring there is an
appropriate disposal route for their waste/devices. Where the disposal
required a particular treatment e.g. incineration then source tagging or
identification for segregation should become part of the marking or
design of the device.
2. Anatomical Waste
The document suggests that all anatomical waste be regarded as infectious. Not
all anatomical waste is infectious e.g. waste arising from transplant surgery,
cosmetic surgery, nor should it automatically be regarded as so.
3. Storage Periods
The document suggests that the clinical waste should be stored for 7 days
unless refrigerated, we feel this is onerous and storage periods are not
required where waste is held in suitable, sealed containers.
4. Sector Guidance Documents
The guide states that sector guides would be produced. We welcome this
and see these documents providing the practical guidance to practioners
and health professionals missing from the parent document, however we
would state there would need to be clear timescales by when these are to be
published and these should be very soon after the publication of the parent
document.