SMDSA submission to Dft Re: Bulk carriage in bulk containers
Nigel
I apologise that this is delivered at the last minute, unfortunately, annual leave has meant a delay in
discussing this amongst our members.
I very much regret that we have no-one available to attend the meeting today to represent the clinical
waste industry.
However, I would be grateful if this note can be submitted to today's meeting for further discussion.
We will be pleased to meet with you before the meeting in Geneva to discuss this further should you
require.
We wish to comment upon the circulated draft INF paper, letter from DfT dated 14th July 2009 re
aligning BK1/BK2 and VW/VV provisions, and the DfT/VCA Guide re approval of bulk containers dated
July 2009.
The proposed change by the UK Representative (DfT) has raised concerns within the
Clinical/Healthcare Waste Industry which we wish to have taken into consideration.
Whilst we do not object to the principle of changing from VV11 to BK2, we have significant concern
about the implications for our members' vehicles and the inherent costs to industry, and in particular
the knock-on costs to small waste producers at a time when small business is severely affected by the
financial crisis.
Whilst the INF paper and proposed changes apply broadly across many industries and an extensive
range of dangerous goods, we believe the case for infectious clinical waste is unique and substantially
different and should therefore be excluded from this change.
Infectious clinical waste (UN 3291) is the only dangerous goods which are transported in bulk within
another packaging (i.e. plastic sacks). I.e. where the product is not in direct contact with the bulk
container under normal circumstances. It is inconceivable that clinical waste would be loaded into
bulk containers without first being placed into plastic sacks to aid with handling during loading and
unloading.
Whilst the general perspective of bulk transport entails the movement of at least several cubic metres
of product in a single container over a reasonable distance without being opened, this is not true for
infectious clinical wastes.
The clinical waste industry operates over 1000 small vans each day of up to 3.5te gross capacity
which have been fitted to enable carriage of infectious clinical waste in bulk in plastic sacks complying
with VV11 since 2002 following on from Certificate of Exemption Number 1 of that year. A range of
larger vehicles are also operated from 7.5te to 38te. All of these would then need to comply with the
requirements of BK2
We would point out that the smaller vehicles provide an essential support service to over 100,000
small producers of infectious clinical waste - Dentists, GP's, Care Homes, clinics, schools, vets,
undertakers, police stations, high street pharmacists, offices, and many thousands of private
households/dwellings etc etc. It is common practice for between 1 and 10 bags/sacks to be collected
from each premises on a milk round with up to 30 collections being made on a single vehicle each
day. Please bear in mind that these are not large bespoke vehicles that can be converted into or carry
a standardised bulk container costing £50,000+ ; these are typical tradesman's white vans (eg
Vauxhall Movano, Renault Master, Ford Transit) costing typically the same as the family saloon car
with adaption to comply with VV11.
We are extremely concerned that the requirement to submit drawings of and actual vehicles for
inspection by VCA/DfT on a three yearly basis increases costs which are vastly out of proportion to
both the danger and the existing cost basis, and where the significant cost increase will need to be
borne by the NHS and small businesses. We are also concerned about any additional implication
requiring these vans to be sealed (and tested) to greater extent to prevent leaks, recognising that the
average vehicle is opened every 20-30 minutes throughout its working life to add to the load. The
ability to maintain any watertight seal becomes impossible under these circumstances.
We have heard representation from VCA and others that these vehicles could instead carry their loads
as packages inside approved large packagings (= wheelie bins, for example) in order to avoid the
requirement for bulk transport completely. Whilst some infectious wastes are carried in this form, the
argument demonstrates a complete lack of knowledge or understanding of the scale, logistics and cost
basis. Wheelie bins are used extensively to carry infectious wastes from large producers (eg
hospitals) to point of destruction. Specially constructed vehicles have been designed and
introduced into the industry for this purpose. However, even after introducing double deck vehicles
with maximum chassis length, the tare weight of the wheelie bins often exceeds the 'pay load' of waste
being carried. Typically an 18te HGV will only carry 2.2te of waste in wheelie bins when full.
The existing small vans are chosen for their ability to access small premises (many in the high street)
and where larger vehicles would not be practical. The standard body shape of these vehicles is not
'square' and does not lend itself to carrying wheelie bins efficiently. A standard wheelie bin holds only
20-25 plastic sacks. It would be impossible for the vehicle to collect the same amount of waste in
packages as it does in bulk - this is essentially the reason why most operators continue to carry
clinical waste in bulk. We have already demonstrated that if forced to transport in wheelie bins on
small vehicles, the pay load for each vehicle will be decreased by 60-75% on average. This will mean
that the industry will need to increase its fleet size by threefold, and the consequent increase in cost to
the waste producer will also treble. This does not take account of the increased burden on the
environment through increased vehicle miles and the impact on vehicle congestion, driver recruitment
and training.
In addition, these vehicles are not equipped with tail lifts and do not have the means to load and
unload wheeled bins frequently, creating manual handling difficulties. The vans are designed as multiservice vehicles to avoid repeat visits to the same site with many different services. As a
consequence, the vehicle has to be constantly adaptable to its working load. Considerable time
and cost has been spent enabling these vehicles to comply with VV11 whilst still retaining versatility.
Our concern is that any change to the existing VV11 approval for small vehicles will involve not only
significant increased operator costs for each vehicle, but will also require a tripling of vehicle numbers
and a major increase in cost to the producer of clinical wastes. This may be sufficient to drive many
smaller operators out of business altogether, and again increasing potential for a market monopoly.
Whilst we recognise that there would be less impact on vehicles over 7.5 te, it is essential that a long
transitional period is agreed to allow old vehicles to be replaced naturally. As a final note, I would add
that the NHS are already concerned that the contingency provisions in the clinical waste industry are
fragile. The existing national contingency plan relies heavily on bulk transport of clinical waste. It is
unlikely that industry has the capital available to effect a substantive change in transport provisions for
a contingency; let alone a major increase.
Regards
Martin Foulser
Secretary
Sanitary Medical Disposal Services Association