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Safe Management of Healthcare Waste

Safe Management of Healthcare Waste. Colin Ranshaw SMPU. Safe Management of Healthcare Waste. • The ‘old’ document – Safe Disposal of Clinical Waste has now been withdrawn. • The consultation closed February 2006. • Over 200 responses from organisations, professional bodies and individuals.

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Safe Management of Healthcare Waste

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  1. Safe Management of Healthcare Waste Colin Ranshaw SMPU

  2. Safe Management of Healthcare Waste • The ‘old’ document – Safe Disposal of Clinical Waste has now been withdrawn. • The consultation closed February 2006. • Over 200 responses from organisations, professional bodies and individuals. • The Steering Group met at the beginning of March to review the responses – over 2 days!

  3. Key parts of SMHCW •Infectious Waste To follow WM2 – waste segregated as clinical waste on the basis of infection risk posed (even potential risk) is now hazardous waste. •Medicinal Waste To follow WM2 - cyto-toxic and cyto-static medicines defined as those with the following hazardous properties: •H6 – toxic ; •H7 – carcinogenic; •H10 – toxic for reproduction; •H11 – mutagenic; are hazardous waste.

  4. Safe Management of Healthcare Waste Continued… •Offensive Waste Not a hazardous waste, not defined by regulation. Waste which requires specialist handling and disposal due to offensive nature. •Colour Coding Virtually unanimous agreement that this was the way forward – yet to agree the colours for medicinal wastes.

  5. Colour coding The following colours have been agreed: Purple & yellow for cyto toxic and cyto static Yellow for wastes which require (at minimum) disposal by incineration. Orange for waste which require (at minimum) treatment at suitably authorised facilities. ‘Tiger’ bags for offensive waste. Blue or green ??? Pharmacy waste

  6. Best Practice Colour Coding Colour Coding …

  7. DRAFT – NOT FINAL

  8. Next steps • Amendments will be made by the project steering group with additional support from other organisations. • There will be a peer review process – August 2006. • Final publication September / October 2006 (fingers crossed).

  9. Targets & Objectives • Overall target to reduce the amount of waste produced by 10% of the 2002/03 baseline by 2010 This is supported by 10 priority waste stream targets.

  10. Target 1: Hazardous Waste • All healthcare organisations should review, with immediate effect, the production of all hazardous waste produced on-site and should produced a hazardous waste inventory; and • NHS Trusts should reduce the amount of hazardous waste sent for disposal by 10% of the 2005/06 figure over the next five years. This can be achieved by a combination of: • better separation at source; • product substitution; and • increased recycling/recovery where appropriate.

  11. Target 2: Clinical Waste NHS Trusts should reduce the amount of clinical waste produced by 5% per annum. If this year-on-year target is achieved by 2010,clinical waste producers will have made a reduction in the amount of clinical waste produced equivalent to approximately 20% of the 2004/2005 arising figure.

  12. Target 3: Hygiene Waste • By 2007, healthcare organisations should undertake a waste audit and review the opportunities to segregate hygiene waste from the clinical waste stream; and • By 2008, every NHS Trust should have policies and waste segregation protocols in place to segregate hygiene waste from the clinical waste stream

  13. Target 4: Packaging Waste • By 2007, all healthcare organisations should undertake a waste audit and review the opportunities to segregate packaging waste; and • By 2010, every NHS Trust should segregate packaging wastes and recover/recycle a minimum of 30%, by weight, of all packaging wastes collected.

  14. Target 5: Biodegradable Waste • By 2007, all healthcare organisations should have reviewed the production of biodegradable waste on site, including: • plated meals; • kitchen and canteen waste; and • ground maintenance waste; and • By 2010, every NHS Trust should have in place arrangements to divert a minimum of 25%, by weight, of the total biodegradable waste from landfill to alternative waste management facilities .

  15. Target 6: Construction and DemolitionWaste • By 2007, all major capital projects resulting in the production of C&D waste should require contractors to produce site waste management plans, in accordance with the DTI Voluntary Code of Practice; • By 2010, all major capital projects, including new builds and site modifications, should require a minimum of 85% recovery of uncontaminated demolition materials by weight; and • By 2010, all major capital projects, including new builds and site modifications, should require that building materials contain a minimum of 15% (by value) of recycled/recovered material. .

  16. Target 7: Waste Electrical andElectronic Equipment (WEEE) • By 2006, all healthcare organisations should have reviewed the electrical and electronic waste they produce and investigate facilities to recover or recycle WEEE; and • By 2010, all NHS Trusts should recover/recycle 65% of all WEEE produced.

  17. Target 8: End of Life Vehicles (ELV) · From 2006, all healthcare organisations should have arrangements in place for all ELVs to be sent to authorised dismantlers to be de-polluted and for material recovery.

  18. Target 9: Battery Waste · By 2007, Health Supplies Organisations should establish a framework contract for disposal/recycling of waste batteries.

  19. Target 10: Waste Oils · By 2007, NHS Trusts should have reviewed the systems in place to manage waste oils.

  20. Hazardous Waste RegulationsJuly 2005 Define Pharmaceutical waste as hazardous using model from ‘NIOSH ALERT – Preventing Occupational Exposures to Antineoplastic and Other Hazardous Drugs in Health Care Settings’ • Carcinogenicity • Teratogenicity • Reproductive Toxicity • Organ Toxicity at low doses • Genotoxicity • Structure and Profiles of new drugs that mimic existing drugs determined hazardous as above

  21. Hazardous Waste New Hazardous Waste Regulations may render drugs with significant hazardous properties as non-hazardous Special Waste is NOT a category – This removed anomaly that all POM’s are Special Waste, eg Water for Injection; 100 Paracetamol Tablets Vs 3 x 32 Paracetamol Tablets Public Health Interest Vs Environmental View Pillferable Value Vs Environmental View WESTERN MAIL TEST!

  22. Proposed Definitions (A) Cytotoxic and Cytostatic Drugs must be incinerated EWC Codes - use 18 01 08, 18 02 07*, 20 01 1* (B) Medicines other than Cytotoxic and Cytostatic Drugs should be disposed of as follows EWC Codes - use 18 01 09, 18 02 08 and 20 01 32 (i) those with hazardous properties should be incinerated (ii) antimicrobial drugs should be incinerated (iii) genetherapy drugs should be incinerated (iv) denatured controlled Drugs should be incinerated

  23. Proposed Definitions cont’d……… (v) liquid drugs (other than (i), (ii) and (iii) ) may be disposed of in the foul sewer in accordance with appropriate consents or incinerated (see (v)) (vi) certain Intravenous fluids and benign liquid substances may be disposed of at any suitably authorised facility or discharged to foul sewer. (obviously needs a clearly defined list or criteria) (vii) articles - medicines in pressurised containers (e.g. ventolin) - these should be incinerated ? prefilled syringes - these should be incinerated ? medicated dressings - these should be incinerated where they have hazardous properties Other article types ???

  24. Proposed Definitions cont’d………. (viii) containers of mixed waste medicines should be incinerated where the individual pharmaceuticals present have not been identified and individually assessed against the above criteria. Clinical Trial Materials? (ix) non-liquid GSL or P Pharmaceuticals other than those listed above may be disposed of at a suitably authorised landfill or incinerated. For landfill these should be deep buried in a dedicated area at the working face and covered immediately by no less than 2 m of other refuse. A recommended limit of 1% of the total capacity of the cell, and an input of no more than 2% of the input waste per month (x) substances other than those identified should be incinerated

  25. Proposed Definitions cont’d……….. (C) Waste from pharmaceutical manufacture (i) For medicinal products, including those which are out of date, out of specification, or unfinished - use (A) and (B) above EWC codes - see (A) and (B) (ii) Pharmaceutically active substances associated with the manufacture of Cytotoxic and Cytostatic drugs, antimicrobial drugs, controlled drugs and gene therapy drugs should be incinerated. EWC codes - 17 05 13*, 07 05 14, 07 05 99 (iii) For process wastes other than (i) and (ii) disposal at any suitably authorised site

  26. No Liquid Waste on Landfill Sites January 2007 Positive list of drugs for disposal into foul sewer needed They must not be damaging to fauna or flora, for example antacids, bulk i/v fluids

  27. Segregation Article 2(4) of the Hazardous Waste Directive specifically requires the separation- where technically and economically feasible- of hazardous waste that has been mixed with non hazardous waste or with other categories of hazardous waste where it is necessary for the protection of the environment or to avoid harm to human health Requires extension of hospital ‘cytotoxic’ separation system Label medicine at point of issue category of disposal route

  28. Segregation cont’d………. Failure to separate appropriately will be a prosecutable offence. All yellow bags will be classed at Hazardous Waste from July 2007. If contents not segregated (eg flowers have been put in bags) an offence will have been committed Receiving Trust should be licensed for returns of waste/out dated stock from eg satellite hospitals Denaturing Controlled Drugs and De-blistering is Low Risk treatment and a Waste Treatment Licence is NOT required Sharps/needle containers do not comply with regulations as they leak liquids

  29. Additional Factors in the Community Household waste will be classified as domestic waste. Residential homes are not be able to dispose of medical/clinical waste Needle and Syringe exchange schemes through Community Pharmacies require the Pharmacy to have a licence. Therefore most schemes through Pharmacies are illegal. GP Surgeries do not require these licences

  30. Return of unwanted medicines Can accept Tablets/capsules Creams/ointments Liquid medicines Powders Inhalers Ampoules/vials Cannot accept Chemicals/pesticides Veterinary products Dialysis kits Paints/solvents Oil Batteries

  31. Why dispose of waste medicines? Helps prevent accidental poisonings Helps prevent inappropriate use of medicines e.g. diversion to other people Helps protect the environment

  32. Controlled waste regulations 1992 Clinical waste from: Domestic premises is “household waste” Residential homes is “household waste” Hospice (charity) is “household waste” Hospice (Care Home, Nursing) is “industrial waste” Care Home (Nursing) is “industrial waste” Prisons is “industrial waste” GP surgeries are not household premises, so can’t return waste to pharmacies

  33. Carriage of waste Not covered by conditional exemption Must register with the EA as a waste carrier Registration is valid for 3 years (£136 in June 2005; renewal costs £91) Applies to waste medicines collected from patient's home or a residential home Not part of Essential Service 3

  34. Waste Management Licence To store waste, pending collection, I need: Waste Management Licence; or Conditional Exemption registered with the EA (currently no charge). There is a qualifying limitation of less than 200Kg per annum Environment Agency Guidance on Low Risk Waste Activities – Version 13 Sept 2006 NOT REQUIRED

  35. Waste treatment De-blistering and emptying of bottles is regarded as waste treatment (a licensable activity) – LRW NOT IN PUBLIC INTEREST Non-CDs: remove blister packaging from inert cartons and leaflets MDS trays: remove inner disposable packaging and re-use plastic shell CDs: de-blister and denature

  36. Segregation (1) The NHS (Pharmaceutical Services) Regulations 2005 Aerosols Liquids Solids Depends on the requirements of the LHB and/or waste contractor who must supply adequate containers

  37. Segregation (2) The Hazardous Waste Regs 2005 prohibit the mixing of: different types of hazardous waste hazardous and non hazardous waste Pharmacies will require at least 2 containers for cytotoxic/cytostatic medicines for non hazardous medicines Duty of care to determine and code waste

  38. Segregation (3) Will you exceed 200kg of hazardous waste? If yes, notify EA Revise SOPs for handling waste Ensure appropriate containers are provided Identify segregation area in pharmacy Assess need for protective equipment e.g. gloves, overalls, spillage kits

  39. Disposal of obsolete dispensing stock Yes (for stock held to fill NHS scripts) Via LHB funded collection scheme No requirement to segregate stock from returned household waste But need to describe waste using the different EWC codes (18… or 20…) Ref: Essential Service Spec. 3.1.6

  40. Controlled Drugs (CDs) All CDs must be stored in a complying cabinet No exemption for “waste” CDs Therefore “waste” CDs must be denatured before mixing with other waste EA does not require a waste management licence to denature CDs Denaturing “resin mixture” kits should be used (purchased by pharmacy) Authorised witness?

  41. Sharps LAs have a duty to arrange collections on the request of a patient Needle exchange schemes – para 28 of WML permits waste to be returned to the pharmacy (Enhanced Service) EA allows other sharps waste to be returned to a pharmacy, without a licence, to avoid pollution or harm to health (but not part of essential service 3) Staff should be offered Hep B immunisation

  42. Consignment and transfer notes Hazardous waste: a consignment note must be completed and a copy retained in the pharmacy for 3 years: Waste must be listed and quantified (Kg) Waste must be coded e.g. 18 01 08 9 (cytotoxics) Non hazardous waste: a duty of care transfer note must be completed which can cover a series of transfers; retained for 2 years

  43. Care Homes (Nursing) Waste is classified as “industrial” waste Not covered by pharmacy exemption Pharmacists collecting this waste require: a waste management licence (high cost) to register as a carrier of waste Also applies to dual registered homes and hospices without charitable status providing nursing care

  44. Conflicting advice? Sometimes local EA advice can conflict with other guidance e.g. PSNC In these cases, the matter should be referred to the National Technical Officer (EA) and to the national EA/PSNC agreement

  45. Additional resources/reading PSNC: Pharmacy Contractor Briefing on Waste (www.psnc.org.uk) RPSGB: The Hazardous Waste Regulations (England and Wales) 2005: Interim guidance for community pharmacists Dec 2005, and for hospital pharmacists July 2005) (www.rpsgb.org.uk) NPA Information leaflet: Waste Disposal (www.npa.co.uk) Environment Agency: www.environment-agency.gov.uk

  46. Revision to Safe Disposal of Clinical Waste Wendy Rayner, Enviros Consulting Ltd.

  47. In summary…… Why re-write the guidance ? Steering Group – Changes in UK Regulation & Guidance Hazardous Waste Classification of Infectious Waste - Current & Forthcoming Classification of Medicinal Wastes - Current & Forthcoming Waste Audit, Packaging & Labelling Best Practice Colour Coding Guide to Waste Management Licences & Applicable Exemptions Consultation Process Content of new guidance subject to change following final Steering Group Approval

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