The document discusses guidelines for the safe management of healthcare waste. Key points include: - Healthcare waste should be segregated and categorized based on infection risk, hazardous properties, and required treatment/disposal. Colour coding is recommended. - Targets are set to reduce various waste streams, including hazardous, clinical, and packaging waste sent for disposal. - Recent regulations define more pharmaceutical waste as hazardous and prohibit mixing hazardous and non-hazardous waste. This requires improved waste segregation. - Additional guidance is provided for waste management in community settings and by pharmacies. Pharmacies may accept certain unwanted medications but have restrictions on handling, storing, transporting and disposing of healthcare waste.

1. Safe Management of Healthcare Waste

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has now been withdrawn.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 Description
Infectious Waste
Minimum treatment / disposal required is incineration in a suitably licensed or
permitted facility.
Infectious Waste
Minimum treatment / disposal required is to be ‘rendered safe’ in a suitably
licensed or permitted facility.
Cyto-toxic / Cyto-static Waste
Minimum treatment / disposal required is incineration in a suitably licensed or
permitted facility.
Offensive Waste*
Minimum treatment / disposal required is landfill in a suitably licensed or
permitted site. This waste should not be compacted in un-licensed/permitted
facilities.
Domestic Waste
Minimum treatment / disposal required is landfill in a suitably licensed or
permitted site.
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:
a) • plated meals;
b) • kitchen and canteen waste; and
c) • 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 Demolition
Waste
• 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 and
Electronic 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 Regulations
July 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

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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