NHS Facilities Management Network AN INTRODUCTION TO WASTE REGULATIONS TUESDAY 7th OCTOBER

1. NHS Facilities Management Network AN INTRODUCTION TO WASTE REGULATIONS TUESDAY 7th OCTOBER CLIVE AYLETT Head of Estates & Facilities (NPAG Waste benchmarking group chair) Queen Elizabeth Hospital

3. The Hazardous Waste (England) Regulations 2004 • Implementation 15 July 2005 • Improved Segregation • Compliance with E.U.Directive • Reduced Landfill • Reduced Waste Disposal Costs • Improved licensing and registration of producers premises • and waste disposal companies • Review of the existing legislation regarding Hazardous • Waste (Clinical Waste)

4. Previously known as the Safe Disposal of Clinical Waste 1999 (Purple Book) Issued November/December 2006 Aim: To provide a framework for good practice in waste management Revised colour coded best practice segregation and packaging system New methodology for the identification and classification of infectiousandmedicinal wastes The use of European waste catalogue (EWC) codes to remove the system using groups A to E Introduction of an offensive waste stream (human Hygiene and sanpro waste) Safe Management of Healthcare WasteHTM 07-01:

5. New Waste Segregation Chart

6. New National Colour Coding System

7. New colour scheme is recommended not mandatory Internal waste management group debate concluded, new guidance complicated and confusing Decision to streamline waste groups to avoid confusion Main categories of waste for disposal included : The Queen Elizabeth Approach • YELLOW:Waste for incineration only including anatomical or unautoclaved waste • ORANGE :Waste known or suspected to contain pathogens • YELLOW/PURPLE: Wastecontaminatedwithcytotoxic/cytostaticproducts

8. Yellow Waste Stream • Anatomical Waste • Unautoclaved pathological waste • Waste as directed by infection control

9. Orange Waste Stream • General ward produced waste, including waste from high risk • patients i.e. MRSA C/Diff • Autoclaved laboratory cultures • All waste known or suspected to be infectious

10. Purple/ Yellow Waste Stream • Waste from oncology • Waste from day care theatres ect (Treatment of Cancer Patients) • Waste from Cytotoxic/Cytotoxic Preparations (Pharmacy)

11. Sharps Containers • Sharps Waste Streams re classified or changed

12. New Colour Scheme Have Changed To Yellow lidded containers with yellow body should be used for ALL General sharps including sharps contaminated with medicinal products Exclude ALL Cytotoxc and Cytostatic Waste All Medicinal waste whether in original packaging or not must be returned to pharmacy All sharps containers MUST be tagged and placed in a secure area this waste must be consigned as 18.01.09 (Pharmaceutical) and 18.01.03* (Infectious)

13. New Colour Scheme Have Changed To • Cytotoxic/Cytostastic Sharps bins have changed from black lidded bins to Purple lidded bins • Sharps bins MUST be tagged or labelled for collection, then stored in a secure area, prior to collection • This waste stream should leave the hospital • consigned as 18.01.08* for incineration only

14. New Colour Scheme Have Changed To • All anatomical waste and placentas should be disposed of via • the yellow waste route in leak proof yellow containers • All containers MUST be tagged and labelled and placed in the • appropriate place for collection • This waste stream must be sent for incineration coded as • 18.01.02 (Anatomical) and 18.01.03* (infectious)

15. New Colour Scheme Amalgam Waste • Dental Amalgam waste produced in dental areas and theatres • must be disposed of via an authorised contractor, licensed in this • disposal. • All Amalgam must be packaged in U.N. approved White • Containers and disposed of by specialist and licensed waste contractors • This waste is consigned as 18.01.10*

16. Site Registration • All producers of hazardous waste must by law register the site on an annual basis. • This is a simple procedure via he Environment Agency website @ a cost of £18.00 per Annum • The Agency will then issue a registration report and site licence number i.e. AAC607 • This Must be included on the consignment note

17. Consignment Notes • A three part Consignment note must accompany all hazardous waste, • Showing as a minimum the following information: • Quantity of waste • EWC Codes, detailing the • Full description of waste • Final destination of waste • consignment • It is essential that the consignor then returns • part E back to the producer, verifying correct disposal

18. Duty of Care • Legislation determines that the producer is responsible for hazardous waste from cradle to grave. • This requires an annual duty of care audit to be carried out • Producers should arrange a covert operation to follow waste from point of production to final disposal • Checks related to licences (waste management licence & PPC Permit will also be required

20. WEEE - Waste Electrical and Electronic Equipment (WEEE) is an EU Directive which must be implemented into Member State law. The WEEE Directive aims to: Increase recovery and recycling rates of WEEE; Improve environmental performance of all operators involved in the life cycle of WEEE; Implement producer responsibility for WEEE. Legal requirement : recovery and recycling at end of life Marking of products and provision of information Implements ‘producer responsibility’ What are the WEEE Regulations?

21. The WEEE Regulations have placed new responsibilities on both producers and purchasers of EEE In many cases these new responsibilities have meant increased costs across the whole life of products particularly at the waste disposal stage. These responsibilities may be passed on by suppliers to customers and should be negotiated prior to purchase Waste management of WEEE has become extremely complex and expensive How will this affect Estates and Facilities Management?

22. All equipment dependent on electrical currents or electromagnetic fields. 10 indicative categories: Large household, Small household, IT and Telecoms Consumer equipment Lighting equipment, Electrical and electronic tools, Toys leisure & sports, Medical devices, Monitoring and control, Automatic dispensing machines. Specific exemptions exist. What is within the scope of the WEEE Regulations?

23. Equipment that operates over 1000v AC or 1500v DC. Implanted and infected medical equipment. Fixed installations – lots of discussion over the definition. Large scale stationary industrial tools. Equipment that is part of another type of equipment that is not within the scope of the Directive. Consumables and peripherals such as probes etc. General Exemptions for WEEE

24. All products placed on the market in the UK after 1 April 2007 must carry the following mark and a date of manufacture. The black bar denotes a date of post 13 August 2005 See BS50419 for more information User information as to the meaning of this symbol must also be included with the product? Communication of the meaning of this to staff is important Product marking and information

25. WEEE must not be disposed of in household waste. WEEE must be separately collected and be sent to Authorised Treatment Facilities for recovery and recycling. WEEE should be segregated for collection using the ‘5 skip principle’ Waste Management

26. ‘5 skip principle’ CRT-containing equipment Cooling Equipment White Goods Lamps General

27. It is important to remember that there are many costs associated with WEEE. Not just recovery and recycling costs. Hidden costs include: Staff training and awareness raising. Administration and asset management Collection and segregation costs. Storage costs Hidden costs of WEEE

28. An organisation, approved by the regulator, that takes on the legal and financial responsibility of its member Producers for the recovery and recycling of WEEE placed on the market by those member Producers. In many cases the physical activity of uplifting WEEE from an final user’s premises will be arranged by a Compliance Scheme on behalf of their member Producers. All Producers are required to register with the regulator as Producers through a Compliance Scheme Compliance Scheme

29. Are your waste management systems effective enough to deal with the level of segregation required, the storage of WEEE, and the potential for a number of compliance schemes to require access for uplifts? Training requirements for staff across the organisation as these may be extensive. If products are not recovered or recycled as required under the WEEE Regulations and other existing waste regulations this could result in prosecution. Requirement for the user to ensure compliance with other waste regulations that currently apply such as the Duty of Care regulations. General Risks

30. Alternatives • Producer can assume responsibility for disposal of WEEE • Reduces need for bulky disposal, and asset management (Purchasing records would need to be kept) • WEEE waste can be mixed, no need for the 5 skip principal, but must be sent to an Authorised Treatment Facility (ATM) • If this option is taken then a discount should be negotiated at the purchase stage

31. Penalties A person who commits an offence under [regulation 70 or 73] of the regulations shall be liable • On summary conviction, a fine not exceeding • the statutory maximum of £50,000.00 • On Conviction on indictment, unlimited fine • and/or up to five year imprisonment

32. QUESTIONS Clive Aylett Brook House Queen Elizabeth Hospital Tel : 0208 836 5777