Queen Mary University of London Occupational Health and Safety Directorate (OHSD) Management of College Hazardous Clinical Waste and Disposal Briefing Note to Safety Coordinators and Key Managers / Contacts – 4 April 2012 This briefing note is to update you on the management of hazardous clinical and clinical related wastes (also termed healthcare wastes) in the College. Most of this information will be issued shortly as part of a revised and updated College Standard for the Safe Management and Disposal of Hazardous Waste, which will update and incorporate the standards and requirements under the Hazardous Waste Regulations (England and Wales) 2005. Hazardous Clinical wastes (healthcare wastes) are typically discarded solid and/or trace liquid biologically hazardous materials such as human or animal tissue, cells, inactivated (e.g. autoclaved) human or animal pathogens, GM / SAPO waste and discarded plastic / paper / sharps consumables contaminated by these substances. Some hazardous clinical waste (materials / consumable / sharps) may contain chemical contaminants or cytotoxic / cytostatic compounds. Larger items may also be considered clinical waste when contaminated with infectious material (e.g. HEPA filters, cages). College Arrangements A renewed Service Agreement has just been signed with PHS Waste Management for the uplift and disposal of hazardous clinical waste from the College. (PHS and predecessor companies have disposed of most College hazardous clinical wastes over the last 10-15 years). PHS responsibilities: 1. PHS will uplift all correctly packaged and labelled hazardous clinical and clinicalrelated waste that is deposited in designated yellow clinical waste wheelie bins (Eurolock type) and transport waste for final disposal (high temperature incineration). (Attached table has full details of bin locations and key local contacts etc). 2. PHS will supply consumables (yellow clinical waste bags, cable ties and various sized sharp bins) to package hazardous clinical waste. (Attached tables have full details of consumable deliveries, required frequencies and drop off points etc). 3. PHS will prepare the Hazardous Waste Consignment notes. 4. PHS will send all College invoices and completed Hazardous Waste Consignment notes to the Director of OHSD (Dr Kevin Thurlow). OHSD Clinical Waste Management Briefing 4 April 2012 (MRA) Page 1 College staff responsibilities: 1. Hazardous clinical waste must be correctly segregated and packaged in the appropriate (PHS supplied) coded/labelled yellow clinical waste bag / sharp bin according to the type of waste and appropriate waste disposal route (see below for further information). 2. Where European Waste Codes (EWC) are not pre-printed on the bag / container, these must be correctly annotated (see below for further information). 3. Non-PHS supplied bags and sharp bins (which may be incorrectly coded / labelled) must NOT be used. 4. To reduce manual handling risks to the PHS pick-up driver, yellow clinical waste bags must NOT be filled with more than 5 kg (approx.) weight. 5. Correctly packaged hazardous waste bags (tied with the appropriate coloured cable tie) and sharp bins (tied with the appropriate coloured cable tie, if needed for identification) must be transported safely to the designated yellow clinical waste wheelie bin, awaiting uplift. 6. Where significant amounts of sharp bins are generated at a location (e.g. John Vane Science Centre, Blizard Institute), a dedicated yellow clinical waste wheelie bin must be designated for sharp bins. 7. Sharp bins must NOT be wrapped within yellow clinical waste bags or other bags. 8. Yellow clinical waste wheelie bins must be kept locked and annotated (e.g. attach a laminated sheet with information onto the bin) with the PHS servicing account number, Dept / School / Institute name, local contact and College telephone number. The wheelie bins should have the infectious transport label attached (if not, contact Mark Ariyanayagam for a label). 9. Any PHS invoices or Hazardous Waste Consignment notes received locally should be immediately forwarded to OHSD (FAO Mary Giguere). 10. Any deficiencies to the service or defects to facilities (e.g. to bins) should be immediately noted to OHSD (FAO Mark Ariyanayagam). OHSD responsibilities: 1. OHSD will manage the corporate contract with PHS, report deficiencies and defects in clinical waste facilities and arrangements to PHS and/or School / Institute / Dept, as appropriate. 2. OHSD will periodically inspect / survey clinical waste facilities and arrangements and make recommendations to PHS and/or School / Institute / Dept for improvements. 3. OHSD will pay all College hazardous clinical waste invoices received from PHS and retain all completed Hazardous Waste Consignment notes for 2 years. 4. OHSD will ensure that the annual Environment Agency Hazardous Waste Permits are renewed. Please contact Dr Mark Ariyanayagam (m.r.ariyanayagam@qmul.ac.uk, ext 8378 or 2079) on any arising queries on the management and disposal of hazardous clinical waste in the College. Where hazardous clinical wastes are also contaminated with radioactive or significantly dangerous chemicals, contact Dr Paul Cassell as well for advice (p.g.cassell@qmul.ac.uk, ext 8969 or 2079). OHSD Clinical Waste Management Briefing 4 April 2012 (MRA) Page 2 Dr Mark Ariyanayagam H&S Manager (Science, Eng & Medicine Safety Section) Occupational Health and Safety Directorate Queen Mary University of London OHSD Clinical Waste Management Briefing 4 April 2012 (MRA) Page 3 Hazardous Clinical Waste Disposal Routes (A) Yellow Clinical Waste Bag Disposal Route – for solid waste (trace liquids only), non-sharps Without pre-treatment: Negligible - low risk biological / clinical material waste and disposable consumables contaminated by these substances (materials equivalent to ACDP Hazard Group 1). (E.g. tissue / blood sample solid residues that are known to be of negligible/low infectious risk, cell lines with safe history of use, negligible/low infectious risk patient care waste, negligible/low infectious risk animal bedding waste, soil samples of negligible/low infectious risk that need incineration for final disposal, negligible / low risk animal by-products). After validated pre-treatment for inactivation (e.g. autoclaving, prior inactivation with disinfectant): GM Class 1 waste* Pathogen waste – ACDP HG 1 waste* Pathogen waste - ACDP HG 2 and 3; SAPO Class 2 and 3 GM Class 2 and 3 waste Medium – high risk biological / clinical material waste (e.g. unscreened / infectious tissue / blood sample solid residues, cell lines of unknown history / provenance, unscreened primary cell lines, infectious animal bedding waste, higher risk animal byproducts). Soil samples of unknown provenance which may contain infectious materials. Plant, soil samples that contains GM material. OHSD Clinical Waste Management Briefing 4 April 2012 (MRA) Page 4 Uplift and disposal of larger items such as fumigated HEPA filters, disinfected cages or equipment that need final disposal via incineration needs to be pre-arranged with PHS. *awaiting verification from PHS whether this waste can be disposed without pre-treatment Note: human tissue from deceased donors may be subject to additional requirements under the Human Tissue Act (HTA). Contact the College / Institute / School Responsible Person for HTA matters for additional disposal requirements under the HTA. (B) Sharp Bins Route, for solid waste (trace / small amounts of liquids only) 1. Yellow lidded sharp bins - for non-blood containing infectious material 2. Orange lidded sharp bins - for blood / phlebotomy related sharps 3. Purple lidded sharp bins -for significant cytostatic / cytotoxic contaminated sharps Sharps examples: tips, serological pipettes, scalpels, needle sticks and syringes, microscope slides, glass pasteur pipettes, small glass vials / ampoules (empty or trace liquid contamination). Without pre-treatment: Negligible to low risk infectious biological / clinical material contaminated sharps waste, equivalent to ACDP Hazard Group (HG) 1 (as noted above for yellow clinical bag route). After validated pre-treatment for inactivation (e.g. autoclaving, prior inactivation with disinfectant): Sharps contaminated with medium to high risk infectious biological / clinical materials (as noted above for yellow clinical bag route). Note: human tissue from deceased donors may be subject to additional requirements under the Human Tissue Act (HTA). Contact the College Responsible Person for HTA matters for disposal requirements under the HTA. OHSD Clinical Waste Management Briefing 4 April 2012 (MRA) Page 5 4. Full white sharp bins are to be used for amalgam waste (Institute of Dentistry) – contact Barts Health Trust for arrangements (not uplifted under College contract with PHS). (C) Where significant amounts of infectious liquids and/or dangerous chemicals need to be uplifted by PHS for high temperature incineration contact Mark Ariyanayagam / Paul Cassell for options. (D) Radioactive waste must NOT be disposed via PHS. Contact Paul Cassell for options. Note – other coloured waste bags and sharp bins options are available for the disposal of health care / clinical hazardous wastes under the Hazardous Waste Regulations 2005 but OHSD has determined after consultation that the above waste routes are currently sufficient. This will be kept under review. OHSD Clinical Waste Management Briefing 4 April 2012 (MRA) Page 6 European Waste Codes (EWC) for Hazardous Clinical (Healthcare) wastes Note – more than one EWC may be applicable to the waste. There are further EWC’s for other types of waste e.g. flammable chemicals. If you are unable to designate your waste to a EWC, contact Mark Ariyanayagam. “Absolute Entries” Hazardous waste regardless of any threshold concentrations: A “Mirror Entries” Hazardous waste only if dangerous substances are present above threshold concentrations: M and Animal Health Care and/or Restaurant wastes not arising from immediate health care) 18 01 wastes from natal care, diagnosis, treatment or prevention of disease in humans 18 01 01 18 01 02 18 01 03* 18 01 04 18 01 06* 18 01 07 18 01 08* 18 01 09 18 01 10* 18 02 Sharps (except 18 01 03) Body parts and organs including blood bags and blood preserves (except 18 01 03) Wastes whose collection and disposal is subject to special requirements in order to prevent infection A Wastes whose collection and disposal is not subject to special requirements in order to prevent infection (for example dressings, plaster casts, linen, disposable clothing, diapers) Chemicals consisting of or containing dangerous substances M Chemicals other than those mentioned in 18 01 06 Cytotoxic and cytostatic medicines A Medicines other than those mentioned in 18 01 08 Amalgam waste from dental care A wastes from research, diagnosis, treatment or prevention of disease involving animals 18 02 01 18 02 02* 18 02 03 18 02 05* 18 02 06 18 02 07* 18 02 08 sharps (except 18 02 02) wastes whose collection and disposal is subject to special requirements in order to prevent infection A wastes whose collection and disposal is not subject to special requirements in order to prevent infection chemicals consisting of or containing dangerous substances M chemicals other than those mentioned in 18 02 05 cytotoxic and cytostatic medicines A medicines other than those mentioned in 18 02 07 EWC’s generally applicable to College hazardous clinical waste: 18 01 03 for human infectious / blood waste that requires high temperature incineration and/or sharps that require high temperature incineration 18 01 03 and 18 01 06 for human infectious / blood waste that requires high temperature incineration and also contains dangerous chemicals (i.e. chemicals containing a Hazard Statement (previously a Risk Phrase). 18 01 08 for significant cytotoxic and cytostatic medicines / waste 18 01 03 and 18 01 08 for human infectious / blood waste that requires high temperature incineration and significant cytotoxic and cytostatic medicines / waste 18 01 01 for human infectious sharps that do not require high temperature incineration (e.g. low risk) OHSD Clinical Waste Management Briefing 4 April 2012 (MRA) Page 7 18 02 02 for animal infectious waste that requires high temperature incineration. 18 02 03 for low risk animal infectious waste that does not require high temperature incineration (e.g. low risk) OHSD Clinical Waste Management Briefing 4 April 2012 (MRA) Page 8