Operations. This policy should be read in conjunction with the following statement:
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1 Policy Number SA22 Policy Title CORPORATE WASTE MANAGEMENT POLICY Accountable Director Executive Director of Resources (Deputy Chief Executive) Author Environmental Manager This Policy is a valid document however; due to organisational changes some references to organisational structures or roles have now been superseded. The table below provided a list of old terminology used within the policy cross referenced against the new terminology to be used when reading this document. Superseded Terminology Clinical Business Unit Clinical Business Unit Directors Specialist Management Services New Terminology Clinical Division Chief Operating Officer/ Director of Operations Corporate Division Safeguarding is Everybody s Business. This policy should be read in conjunction with the following statement: All Mersey Care NHS Trust employees have a statutory duty to safeguard and promote the welfare of children and vulnerable adults. This includes: Being alert to the possibility of child/vulnerable adult abuse and neglect through their observation of abuse, or by professional judgement made as a result of information gathered about the child/vulnerable adult. Knowing how to deal with a disclosure or allegation of child/adult abuse. Undertaking training as appropriate for their role and keep themselves updated. Being aware of and following the local policies and procedures they need to follow if they have a child/vulnerable adult concern. Ensuring appropriate advice and support is accessed either from managers, safeguarding ambassadors or the Trust Safeguarding team Participating in multi-agency working to safeguard the child or vulnerable adult (if appropriate to role). Ensure contemporaneous records are kept at all times and record keeping is in strict adherence to Mersey Care Trust policy and procedures and professional guidelines. Roles, responsibilities and accountabilities, will differ depending on the post you hold within the organisation Ensuring that all staff and their managers discuss and record any safeguarding issues that arise at each supervision session The date for review detailed on the front of all Mersey Care NHS Trust Policies does not mean that the document becomes invalid from this date. The review date is advisory and the organisation reserves the right to review a policy at any time due to organisation/ legal changes. Staff are advised to always check that they are using the correct version of any policies rather than referring to locally held copies.
2 The most up to date version of all Trust policies can be found at the following web address: es_and_procedures.aspx
3 CORPORATE WASTE MANAGEMENT POLICY POLICY STATEMENT POLICY NO RATIFYING COMMITTEE SA22 Corporate Document Review Group DATE RATIFIED April 2013 NEXT REVIEW DATE April 2016 Mersey Care NHS Trust is committed to ensuring compliance with current waste management legislation, maximising the recycling of its waste and minimising the environmental impact of the waste it generates. ACCOUNTABLE DIRECTOR: Executive Director of Resources POLICY AUTHOR: Environmental Manager POLICY STATEMENT / KEY OBJECTIVES The objectives of this policy are to describe the standards expected and the supporting processes for the management of the Trust s waste streams in accordance with current legislation and Corporate Environmental Policy commitments. In particular: Correct categorisation of waste and classification in accordance with European Waste Catalogue Codes Procedures for the appropriate and safe segregation, handling, storage, transportation and final disposal of waste Disposal of waste in an environmentally responsible and cost effective manner Minimisation of environmental risk and management of spillages Improved levels of recycling and reuse Increased staff awareness of the environmental impact of waste This policy and procedure can be made available in a range of languages and formats on request to the policy author Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
4 1. Contents Section Section Title Page Number 1 Contents 2 2 Version Control 3 3 Executive Summary 3 4 Introduction 4 5 Policy Standards 5 6 Duties: 5 Trust Board Accountable Director Director of Facilities Environmental Manager Purchasing Manager CBU Heads / Service Managers / SMS Leads Infection Control Team Ward Managers / Heads of Department Estates Officers / Capital Projects Officers / HIS Officers All Staff Classification of Waste 7 8 Supporting Procedures for Waste Management: Waste Segregation, Storage & Handling 8.2 Transfer Notes, Waste Documentation & Record Keeping 8.3 Spillages 8.4 Adverse Incident Reporting 8.5 Recycling 8.6 Waste Audits 8.7 Training 8.8 Healthcare Waste in the Community Development & Consultation Monitoring of Compliance & Effectiveness References Glossary of Terms Appendices: 22 Appendix 1 Waste Types & Disposal Routes Table Appendix 2 EWC Codes for Common Healthcare Wastes Appendix 3 Hazard Groups that Identify Waste as Hazardous Appendix 4 - Hazardous & Clinical Waste Comparison Table Appendix 5 Sample Hazardous Waste Consignment Note Appendix 6 Waste Audit Self Assessment Tool Appendix 7 Local Induction Training for Waste Management Appendix 8 Sample Decontamination Certificate Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
5 2. Version Control Version Date Author Approved by Ratified by Version July Head of Governance Committee Compliance & Version 2 Version 3 June 2011 April 2013 Sustainability Facilities Information Systems Manager Environmental Manager Integrated Governance Committee Corporate Document Review Group 3. Executive Summary Mersey Care NHS Trust is committed to minimising the environmental impact of all of its activities as set out in its Corporate Environmental Policy (SA34). The responsible management of waste streams is an integral part of the Trust s wider environmental commitments. This Policy has been developed to provide a systematic approach to maintaining legislative compliance. The Policy will ensure that the Trust works towards a concept of total waste management, with waste prevention and reduction at its heart, reducing pollution, the Trust s carbon footprint and making efficient cost savings that can be diverted to direct patient care. The Trust s aim in the formulation of this policy is to at least meet, if not exceed, the requirements of all current and forthcoming legislation governing the safe and correct handling, storage, treatment and disposal of all its wastes. This Policy updates the previous Corporate Waste Management Policy (ratified in July 2011) as a consequence of amendments to waste management legislation and improvements in best practice techniques for managing waste. This Policy is applicable to all staff throughout the Trust as it is recognised that all staff are involved in the generation of waste as a consequence of their day to day activities. The Policy is also applicable to contractors who work on behalf of the Trust whose activities give rise to the generation of waste on Trust premises. Other internal documents to be considered which have a direct relation to this policy are:- Corporate Environmental Policy (SA34) Mersey Care Environmental Management System local procedures Infection Prevention & Control Policy (IC01) Policy & Procedure for Handling of Medicines (SD12) Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
6 4. Introduction Rationale: This Policy encompasses the statutory responsibilities of the Trust as producers and consignors of waste and is intended to provide the framework for the establishment of procedures, based on current best practice, to ensure the safe handling, segregation, storage, transport and disposal of wastes from all Trust premises. Mersey Care NHS Trust has a duty under the Environmental Protection Act 1990 to ensure that all waste generated through its activities is responsibly managed from cradle to grave. As a producer of healthcare waste the Trust also has statutory duties under the following legislation: The Medical Devices Regulations 2002 The Hazardous Waste (England & Wales) Regulations 2005 The Lists of Wastes (England) Regulations 2005 The Hazardous Waste (England & Wales) (Amendment) Regulations 2009 The Health and Social Care Act 2008: Code of Practice on the prevention and control of infections and related guidance The Waste Electrical & Electronic Equipment Regulations 2006 (the WEEE Regulations ) The Waste (England & Wales) Regulations 2011 This Policy has also been written with reference to the updated Department of Health guidance Safe Management of Healthcare Waste HTM (March 2011). Scope: This Policy applies to all staff, contractors and agency workers who work on premises owned or controlled by the Trust and all waste produced as a result of the Trust s activities and services. Wastes arising from healthcare activities can include clinical waste (which may be hazardous or non-hazardous); offensive / hygiene waste; mixed municipal waste; infectious clinical waste; hazardous non-clinical waste (e.g. dental amalgam); recyclable waste (cans, paper etc), inert waste (e.g. construction / demolition waste), food and other organic waste. The procedures which support the implementation of this Policy are included in Section 8 and the Appendices 1-8 Principles: The purpose of this Policy is to establish and implement the key sustainable waste management principles and commitments of the Trust. These are as follows: To promote the minimisation of waste generated from Trust activities To increase the recycling and reuse of waste To minimise the adverse environmental impact from the generation of waste through its safe management and disposal Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
7 To reduce unnecessary costs associated with the disposal of waste by encouraging more sustainable resource use, better segregation of waste streams, utilising advances in technology and maximising favourable contracting arrangements As a minimum to ensure compliance with all relevant waste management legislation and maintain an effective risk management regime To comply with all other requirements and guidance of relevance to the health care sector To ensure that the risks of exposure by healthcare workers and service users, to potentially infectious materials within waste, are reduced to a minimum. This will be achieved through the correct disposal of infectious, hazardous and other waste To provide staff with adequate and regular training to meet the requirements of this Policy and its associated procedures 5. Policy Standards The policy has been developed with the intention of providing a clear definition of responsibilities in relation to waste management. Improved use of resources and the correct segregation, recycling and disposal of waste will ensure the Trust complies with environmental legislation and guidance whilst reducing its impact on the environment. The outcomes of the defined standards and requirements of this policy will be: Compliance with relevant legislation and other guidance relevant to the management of healthcare waste Continual improvement in the management of waste as indicated through the results of waste audits and increased recycling and recovery indicators Carbon reductions Pollution prevention control and effective management of risk Improved awareness and knowledge of staff in waste management best practice 6. Duties 6.1. Trust Board The Chief Executive has overall responsibility for ensuring compliance with all statutory regulations and guidance related to waste management. This responsibility can be devolved to Directors, Heads of Departments and Managers. The Trust Board has a duty to ensure a management regime is in place to effectively manage waste legislation requirements. Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
8 6.2. Accountable Director The Accountable Director (the Executive Director of Resources) is responsible for ensuring sufficient resources are made available for the Trust to achieve its waste management obligations and targets Director of Facilities The Director of Facilities has overall responsibility for the development of the Trust s wider Environmental Policy and Strategy. The Director chairs the Sustainability Development Management Group which monitors and reviews environmental performance for the Trust Environmental Manager The Environmental Manager is the Lead Manager with responsibility for the effective management of the Trust s waste in accordance with this Policy. Particular responsibilities include: Waste and recycling contract management (including ensuring that contractors meet current legislative requirements) Dissemination of information to staff with regard to best practice and legislative updates Reviewing the Waste Management Policy in line with changes in legislation and guidelines, in liaison with the Infection Control Team and other stakeholders Ensuring suitable procedures exist relating to waste handling and disposal Managing the conduct of waste audits Coordinating the maintenance and retention of all statutory documentation Waste performance reporting Facilitating Trust compliance with this Policy 6.5. Purchasing Manager The Purchasing Manager is responsible for the tendering process leading to the award of contracts for the disposal of waste; for adjusting contracts and services as wards and departments close and new ones open; and for identifying alternative means of disposal which represent best economical value CBU Directors / Service Managers / SMS Leads CBU Heads / Service Managers / SMS Leads are responsible for ensuring that staff under their management, who have responsibilities for handling waste, are adequately trained in order to fulfil the requirements of this Policy. They are responsible for making staff aware of this Policy and any subsequent updates to it and ensuring that staff understand its implications. They are responsible for informing the Head of Projects, the Estate and the Procurement Department of the closure of wards or departments or opening of new units that require waste collection services. Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
9 6.7. Infection Control Team It is the responsibility of the Infection Control Team to provide advice to Managers on matters relating to infection prevention and control with regard to the handling of waste Ward Managers / Heads of Department Ward Managers / Heads of Department are responsible for all operational waste management issues within their departments, in particular, for ensuring that all waste within their area of remit is segregated, stored and disposed of in accordance with this Policy and that all statutory documentation is completed and held in accordance with current legislation. Ward Managers / Matrons / Heads of Department are responsible for notifying the identified Lead/ Maintenance Contractor of any items of hazardous waste (including electrical items) for which separate disposal has to be arranged. It is vital that all sites use the Trust s approved contractors for the disposal of all wastes in order to ensure that the Trust is meeting its legal obligations. Information on approved contractors is available from Facilities Management Estates Officers / Capital Projects Officers / North Mersey Health Informatics Service Officers All Officers with responsibilities for the management of contractors are required to ensure that all contractors working on Trust premises are made aware of the Trust s Waste Management Policy and work within the terms of its requirements All Staff All staff are responsible for complying with the requirements of this Policy (and its associated procedures) and for ensuring that the Trust satisfies its legal obligations with respect to the management and disposal of waste, in so far as it relates to matters within their sphere of responsibility. All staff are responsible for reporting any adverse incident or near misses associated with the management of waste in accordance with the Trust s adverse incident reporting procedure. 7. Classification of Waste 7.1. The term hazardous waste is used in England, Wales and Northern Ireland to describe waste with hazardous characteristics in line with the List of Wastes Regulations 2005, which transpose the European Waste Catalogue (EWC) into domestic legislation and provide codes for the movement of all hazardous and non-hazardous wastes. Under the Hazardous Waste Regulations 2005 hazardous waste is waste that has hazardous properties that may make it harmful to human health or the environment. Such wastes are harmful to human health or to the environment either immediately or over an extended period of time. Since the Trust produces hazardous waste it has a duty of care to make sure it is disposed of properly. This includes keeping hazardous wastes separate from all other wastes and not mixing different types of hazardous waste. The movement and ultimate disposal Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
10 of hazardous wastes is controlled through the issue of hazardous waste consignment notes (section 8.2.3) Hazardous wastes produced by the Trust include: Asbestos Lead-acid batteries Electrical equipment containing hazardous components such as cathode ray tubes (e.g. televisions) Waste oils and oily residues Solvents Fluorescent light tubes Chemical wastes Infectious wastes Pesticides IT and telecommunications electrical and electronic equipment Medical devices A table of the different properties of waste that make it hazardous (the Hazard Groups) is set out in Appendix 3. In order to ascertain whether a particular chemical is hazardous waste staff should refer, in the first instance, to the COSHH sheet or Safety Data Sheet relating to it Infectious waste (H9 on the Hazardous waste table) is defined by the Hazardous Waste Regulations as: substances containing viable micro-organism or their toxins which are known or reliably believed to cause disease in man or other living organisms Clinical waste is defined under the Controlled Waste Regulations 1992 (issued under the Environmental Protection Act 1990) as:... any waste which consists wholly or partly of human or animal tissue, blood or other body fluids, excretions, drugs or other pharmaceutical products, swabs or dressings, syringes, needles or other sharp instruments, being waste which unless rendered safe may prove hazardous to any person coming into contact with it; and any other waste arising from medical, nursing, dental, veterinary, pharmaceutical or similar practice, investigation, treatment, care, teaching or research, or the collection of blood for transfusion, being waste which may cause infection to any person coming into contact with it. Clinical waste can be divided into three broad groups of materials: any healthcare waste which poses a risk of infection (and therefore by definition possesses the hazardous property H9 Infectious); certain healthcare wastes which pose a chemical hazard (for example one of H1 to H8, H10 to H15); medicines and medicinally-contaminated waste containing a pharmaceutically-active agent. Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
11 The relationship between the definition of clinical waste and hazardous waste definitions is summarised in the table in Appendix 4. The key principle is that clinical waste is equivalent to hazardous waste with only two possible exceptions: segregated non-cytotoxic and non-cytostatic medicines or separate fractions of out-patient-returned medicines clinical waste from municipal sources that are not in any way directly or indirectly associated with healthcare 7.4. Cytotoxic and Cytostatic Medicines: are medicinal products possessing one or more of the above stated hazardous properties. Only these medicines are classified as hazardous waste. However other (non cyto) medicinal waste may require specialist treatment/disposal. These medicines should be assessed for other hazardous properties, which they may possess (e.g. H3B Flammable) before being classified 7.5. Domestic Waste - (Black / Clear / Paper sacks): This waste is similar in nature and composition to waste generated in the home. Domestic waste must not contain any infectious materials, sharps or medicinal products. The Trust s domestic waste is collected by a contractor who undertakes the sorting and separation of the waste for recycling at a transfer station; the residue goes for disposal by landfill in a licensed site Confidential Waste confidential waste is any information or combination of information about an individual that identifies them and is defined by the Data Protection Act This can be in many forms such as patient records, contract information and budgetary information. All confidential waste paper must be shredded to British Code of Practice (BS 8470) either on site or passed to a secure and specialist contractor for shredding. This means that paper is cross-shredded to an agreed size of between 12mm and 4mm width Offensive / Hygiene Waste - Offensive/hygiene waste is healthcare waste or similar waste from municipal sources, which meets the following criteria: it is not clinical waste; it is not dangerous for carriage; the producer has identified, after segregation at source, that it is suitable for disposal at a non-hazardous landfill site without further treatment; it may cause offence to those coming into contact with it. Offensive/hygiene waste includes waste previously described as human hygiene waste and sanpro waste. Potentially offensive/hygiene waste may include: incontinence and other waste produced from human hygiene; sanitary waste; disposable medical items and equipment that does not pose a risk of infection, including PPE (items that are not clinical waste); Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
12 Waste items from healthcare activities must have been assessed for medicinal, chemical and infectious properties to confirm that they are not clinical waste before offensive properties can be considered Waste Electrical & Electronic Equipment (WEEE) the disposal of all waste electrical and electronic equipment (including fridges, fluorescent tubes, computer monitors, televisions) is governed by the WEEE Regulations These require the Trust to separately collect, appropriately store and recycle all electrical goods through a licensed contractor. Electrical goods are defined as items with a plug, battery or that can carry an electrical current. Many items of WEEE will be classed as hazardous if they have hazardous components (e.g. fridges, fluorescent tubes) Waste Medical Devices Infected / Used Medical Devices are medical devices that have been in contact with infectious bodily fluids and have been assessed to be infectious. They should be classified and disposed of as infectious waste. If the device contains hazardous substances or components (including nickel cadmium and mercury-containing batteries), the description of the waste on the consignment note must fully describe the waste and all its hazards. Disinfected / Unused Medical Devices - should be classified as non-infectious healthcare waste. A description of the waste is required even if the waste is not classed as hazardous waste. Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
13 8. Supporting Procedures for Waste Management 8.1. Waste Segregation, Storage & Handling Waste segregation at the point of production into suitable colour-coded containers is vital for good waste management and for complying with Health & Safety, Carriage and Waste Regulations. The prohibition in law of the mixing of certain categories of waste means that the colour coding of waste streams by the Trust as shown in Appendix 1 is required to meet legal requirements All containers must be labelled to identify the waste types within them to ensure appropriate onward management; in addition the label needs to identify the producer All bags and plastic containers used for the disposal of hazardous waste must have the appropriate UN 3291 clinical waste markings Packaging for clinical items is not classified as clinical waste and must not be disposed of into clinical or offensive waste bags or sharps boxes under any circumstances. Sharps bins are to be used for sharps only and must not contain clinical waste, gloves or any other non-sharp items The location of waste bins, sharps boxes and internal waste storage areas, as well as the extent of PPE required by staff, should be based on local risk assessment. Adequate supplies of appropriate waste bags, containers and PPE must be provided on each site and in each treatment area. Stock levels must be monitored by staff using the equipment Waste receptacles should be placed as close to the point of waste production as possible. Waste bags must be removed from bins and correctly sealed for collection when two thirds full or sooner if necessary. Waste bags that cannot be collected immediately must be stored in a designated waste storage area while awaiting collection. Storage areas should be secure and inaccessible to the public. Unsecured Hazardous waste (Clinical waste) must not be placed in corridors, passageways or areas to which the general public has access. Heavy duty bin lids should be kept closed and locked at all times. Bins should never be overfilled Prior to removal to the storage area clinical and offensive waste bags must be tied and labelled. The locally held Record Book must be completed each time a tag is used and tags must be used in sequential order. Sharps boxes must be permanently closed and tagged. Waste bags should be carried by the neck only, away from the body, and sharps boxes by the handle only. Clinical waste tags are available from [email protected] Appropriate PPE should be worn by staff handling waste (subject to local risk assessment) as a minimum this should be disposable gloves All staff who work in clinical areas are offered immunisation against Tetanus and Hepatitis by the Trust s Occupational Health Department in compliance with Department of Health Guidelines All waste awaiting collection must be stored in a suitable area that is locked and inaccessible to visitors and patients. The area must also be solely designated for waste, clean, well ventilated and free from insects and rodent Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
14 infestation. The storage area must be clearly labelled and identified as storing clinical waste. Clinical waste must be segregated from other wastes within the compound and stored inside lockable bins. All bins within the area / compound must be kept locked at all times. Sharps boxes must be kept in a separate bin or suitable approved container If waste is to be transported around the site it must remain secure and inaccessible to the public at all times. To prevent contamination trolleys / vehicles used for transportation should not be used for any other purpose. Such containers should be cleaned at regular intervals and be completely sealed and leakproof Waste should not be moved between sites by unauthorised persons. For the transport of waste by Community Healthcare professionals see section 8.8. If waste needs to be moved between sites advice should be sought from the SMS Estates and Facilities prior to the movement of waste to ensure legal guidelines are met Non-clinical hazardous wastes (e.g. fridges, fluorescent tubes, monitors, paints, solvents) should be securely stored under cover awaiting disposal. SMS Estates and Facilities should be contacted to arrange disposal of such items Transfer Notes, Waste Documentation & Record Keeping The Waste (England & Wales) Regulations 2011 replace the requirements set out in the Environmental Protection (Duty of Care) Regulations The new Regulations require that when controlled waste is transferred a written description of the waste (the transfer note ) must be completed and contain specified information. Additionally, from 1 st October 2011, whenever waste is passed on to someone else it will need a declaration on the waste transfer note (or consignment note for hazardous wastes) that the waste management hierarchy has been applied. This means that disposal options for the waste must have been considered in the priority order of waste prevention, preparation for reuse, recycling, other recovery (e.g. energy recovery) and finally disposal (e.g. by landfill) Controlled Waste Transfer Notes the Trust has an obligation to ensure that the Controlled Waste Transfer Note (required for all non-hazardous waste) contains the following information: Description of the waste (including the EWC code see Appendices 1&2) Quantity of waste Trust and site details Waste contractor details including waste carriers registration number Details of intended destination site for waste disposal The transferor and recipient must both sign and keep a copy of the note. An annual waste transfer note may be used to cover all movements of regular transfer of the same type of non-hazardous waste. For all waste documentation that is held locally it is a legal requirement that copies of waste transfer notes are retained by all parties for a minimum of two years. A hard copy or electronic copy is acceptable. Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
15 Hazardous Waste Transfer Notes the Trust has a legal obligation to ensure that hazardous waste consignment notes are completed and retained whenever hazardous waste is transported off site. The consignment note must contain the following information all sections must be completed before the note is signed: Part A Notification Details: Consignment note code/number Name and address of the site where the waste is being created Name and address of the waste producer if different from the site details Premises code (Hazardous Waste Registration Number if the site produces more than 500kg per annum) Part B Description of the Waste: Process giving rise to the waste SIC code for the process giving rise to the waste Description of the waste; European Waste Catalogue (EWC) code; Quantity; Chemical / Biological components of the waste; Physical form of waste; Hazard code; Container type, number and size. EWC Code; Packing group; UN identification number; Proper shipping name; UN classes; Special handling requirements. Part C Carrier s Certificate: Carrier (Driver) name Company Name and address details Carrier registration no. / reason for exemption. Vehicle registration number Carrier s signature and date. Part D Consignor s Certificate: Consignor (Staff member handing over waste) name Company name and address details Consignor s signature and date Part E Consignee s Certificate Part E will be completed at the disposal site by the company receiving the waste ( Consignee ). Once completed Part E must be returned to the Trust in the form of copy of original paperwork with Part E filled out or an electronic return from the Consignee. Most disposal companies issue hazardous waste producer returns quarterly. Upon receipt the Hazardous Waste Consignment Note (with Completed Part E) and/or the Hazardous Waste Producer Return must be filed and retained for a minimum of 3 years. A hard copy or electronic copy is acceptable. Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
16 A sample completed hazardous waste consignment note is set out in Appendix Hazardous Waste Premises Notification Under the Hazardous Waste Regulations 2005 sites which produce more than 500kg of hazardous waste in any period of 12 months must register with or notify the Environment Agency. Currently, it is only Ashworth Hospital, Mossley Hill Hospital and Stoddart House within the Trust to which this requirement applies. Note: Although premises producing under the 500kg threshold are exempt from the premises notification requirement, all other legislative requirements, including consignment notes for each collection continue to apply Spillages General Bagged Waste - the main risk is that arising from cross contamination/infection. In the event of a burst bag or spillage, appropriate PPE that is consistent with the risk must be worn. The waste items should be placed into a new bag of the appropriate colour [same as original bag or, if this is not available, a yellow bag]. Double bag if necessary Clinical Waste - All spillages of clinical wastes must be cleared without delay by the member of staff responsible for the spillage. PPE must be worn and the items collected and re-bagged into a new clinical waste sack, double bagging if necessary. Before clearing the waste, a visual inspection must be made to check for the presence of sharps. If found the guidance on sharps spillage must be followed before the other waste is collected Sharps Boxes - All spillages of sharps wastes must be cleared without delay and not left unattended. Suitable PPE must be worn and the items collected and placed into a new sharps box. Under no circumstances should sharps be picked up with bare hands. Spilled sharps items should be collected using an extension grab or pair of large tweezers, if deemed safe to do so. For large spillages or spillage within the external waste bins specialist removal should be arranged. Split or damaged sharps boxes with sharps still inside, must be placed into a larger sharps box or rigid clinical waste container before disposal Mercury If mercury equipment is still in use within the Trust: Mercury waste must not be discharged to the public sewer. Mercury Spillage kits should be made available to all areas that use mercury products or items of equipment that contain mercury. The spillage kit should be used to collect any significant quantity of free mercury for recycling. A written procedure for dealing with mercury spillages should be readily available to staff in the areas of use. Under no circumstances should a vacuum cleaner be used to clean up mercury, as this will vent mercury vapour into the atmosphere. The main risk is by skin absorption on contact with mercury, and by inhalation of mercury vapour, which may slowly vaporise into the air from exposed surfaces. This risk is increased in hot, confined areas. Mercury readily combines with other metals to form 'amalgams', which in turn emit mercury vapour, and from which mercury may be absorbed by skin Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
17 contact. Prevent contact with jewellery (eg.rings) and with any metal equipment, which is difficult to decontaminate Other Chemicals the essential steps are: Review information on the COSHH assessment or the manufacturer s material safety data sheet Only tackle the spillage if it is safe to do so and you have the necessary equipment to hand Contain the spillage to prevent further spread Prevent exposure of other persons in the vicinity Absorb and dispose of, using an appropriate spillage kit, as quickly as possible Decontaminate the area and return it to normal use Suitable contingency procedures (including the provision of spillage kits) to deal with foreseeable spillages of harmful chemicals should be devised by the users, and included with the COSHH assessment of health risks associated with that chemical or process Blood or Bodily Fluid Spillages refer to the Trust s Infection Prevention & Control Policy (IC01), section Adverse Incident Reporting All major spillages, accidents, incidents and near misses involving waste should be reported through the Trust s Adverse Incident Reporting Procedure & System, as set out in Corporate Procedure SA Recycling The Trust employs a commingled waste collection and recycling contractor across its sites. This will mean that recyclable waste (e.g. cans, plastics, glass, cardboard etc) is segregated from general waste for recycling at a sorting station following collection by the contractor. All such waste will not need to be placed into separate containers by staff, but placed within the general waste containers / black bags. Cardboard should be flattened and dry before being placed in the general waste containers. All other recyclable items should be rinsed out and dry before being placed into waste bins The following are items that cannot be recycled through the commingled waste collection but need to continue to be separately collected: Office paper in order to preserve the quality of the paper for recycling, this should be collected by way of dedicated office waste paper recycling bins containing plastic sacks. Once full sacks should be tied and placed in with the normal general waste container for the recycling contractor to separate out at the sorting station. Confidential waste this will continue to go through the specified route (Appendix 1) Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
18 All recyclable hazardous wastes (e.g. toner cartridges, fluorescent tubes, fridges) see Appendix 1 for more information 8.6. Waste Audits Under Duty of Care legislation the Trust, as a waste producer, has a cradle to grave responsibility for the control, management and ultimate disposal of its waste. In addition, requirements as part of the Trust s continuing accreditation under the International Standard for Environmental Management (ISO 14001), mean that periodic waste audits need to be undertaken to ensure that waste is being correctly segregated and disposed of Waste audits will be conducted by the SMS Estates and Facilities in conjunction with other departments / colleagues as appropriate. Departments / Service units will also be required to undertake self-assessment using a specific audit tool on a regular basis. An audit tool guidance sheet for this purpose is set out at Appendix 6. Completed sheets should be returned to the SMS Estates and Facilities when requested Clinical Waste Pre-Acceptance Audits The Environment Agency has imposed a legal requirement within the terms of Environmental Permits for clinical waste disposal sites to ensure that producers carry out audits of their waste before it can be accepted. These are known as 'pre-acceptance audits'. Any site producing over 5 tonnes of clinical (hazardous) waste is required to undertake an audit annually. If the individual sites produce less than 5 tonnes of clinical waste then they are audited every 5 years and the deadline for the first audit depends on the type of site Training Due to the extent and nature of waste produced by the Trust it is important that all staff receive appropriate training on the handling, segregation, transportation, storage and disposal of all waste produced Every member of staff involved in the production, handling and disposal of waste has a responsibility to ensure that they are aware of the contents of this procedure Initial training on the Hazardous Waste Regulations, segregation, handling and storage of waste will be provided to nominated staff as part of the Corporate Induction process and/or corporate mandatory training Following the initial training, specific training relating to the job function should also be provided by the line manager at local induction. Any training received should be formally recorded. Guidance for Managers on Local Induction Training for Waste Management can be found in Appendix 7. Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
19 8.8. Healthcare Waste in the Community Community healthcare can take many forms and occurs in various environments. It includes activities undertaken by all healthcare workers who provide services outside of the hospital to, for example, patients in their own homes and householders who are self-medicating Community healthcare workers, as producers of healthcare waste and specifically infectious waste, are required to comply with waste regulations including the Hazardous Waste Regulations 2005 and therefore need to ensure that waste is segregated, described, classified and disposed of appropriately Healthcare workers working in the community, and in the household environment, need to assess the waste they are producing for the hazardous properties it may contain, most notably, infectious. The assessment of infectious waste can be applied using a risk-assessment approach to reduce unnecessary disposal costs (both financial and environmental). This should be based on professional assessment, clinical signs and symptoms, and any prior knowledge of the patient Where the assessment has identified that the dressing is not infectious, the following should be considered: Contaminated dressings from a wound assessed by the healthcare worker as non-infectious can be treated as non-hazardous and should be contained and disposed of in the offensive/hygiene stream. Mixed domestic waste does contain small numbers of plasters, small dressings and incontinence products. Where the healthcare worker produces the same or similar items, these subject to the following considerations can be placed in the domestic waste stream (with the householder s permission). The following considerations apply: o the type of waste if the waste looks like a healthcare waste, and is not obviously a normal constituent of domestic waste, it should not go in the black bag; o the quantity produced where a number of small dressings are produced regularly over a period of time, it may be appropriate to dispose of these as offensive/hygiene waste. If, however, the amount produced is relatively small and consistent with that likely to be found in the household waste stream (for example that bought from a local pharmacy or supermarket by the householder), it may be discarded in the domestic waste; o packaging where such waste is placed in domestic refuse, the waste should be wrapped in a plastic bag. The wrapping should not be yellow or orange, as the waste is not deemed to be infectious thin opaque plastic bags (e.g. bin liners) are appropriate Healthcare workers will produce the following waste types and require the following colour coded containers for segregation: yellow- or purple-lidded sharps container; orange bags for infectious waste; black/clear bags for domestic waste; Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
20 yellow/black bags for offensive waste; Waste Generated by Healthcare Worker Where waste is generated by a healthcare worker for people in their own homes, the healthcare worker is responsible for ensuring that the waste is managed correctly; this forms part of their duty-of-care obligations under the legislation It is not always practical for healthcare workers to carry many different types of packaging with them. Therefore, healthcare workers should be supplied with the most appropriate packages to meet their needs. Where possible, this should be determined prior to in-situ treatment based on the pre-visit assessment and patients records Managers need to ensure that arrangements are in place to ensure that the waste is packaged and labelled correctly and transported for appropriate treatment and disposal. In general there are two options: Option 1 collection from the premises/householder: Provided the householder consents, the healthcare worker producing the waste can leave it in the home for later collection by an appropriate organisation, (for example the local authority). If the householder declines to give consent, the healthcare worker cannot legally leave the waste. The Trust and their employees have responsibility for the waste while it is being stored awaiting collection and for arranging that collection. While awaiting collection from the householder s home, the waste should be stored in a suitable place to which children, pets, pests etc do not have access. It is not appropriate to leave the waste unsupervised on the pavement awaiting collection. Waste should be packaged and labelled appropriately, and adequate instruction should be given in relation to safe pre-collection storage. The householder should be provided with the correct containers/packaging to ensure correct disposal. The party collecting the waste should be provided with the information required under duty-of-care requirements. A consignment note is not required for the movement of hazardous waste from a domestic premises Option 2 healthcare worker transports waste Provided they have a suitable vehicle, and have received relevant training, the healthcare worker producing the waste can transport the infectious or offensive waste from the home back to their base where waste collection and disposal arrangements are in place. Where healthcare workers are transporting waste in their own vehicles, this should be transported in suitable UN approved rigid packaging, for example containers or drums. Reusable transport containers must be cleaned with detergents wipes upon emptying. Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
21 Clinical waste sacks must not be transported in a vehicle, unless placed within a rigid UN approved container (Bio-bins are disposable UN approved rigid containers). Sharps bins are UN approved rigid containers for the transportation of waste and therefore do not require any further packaging when fully closed. Sharps containers which are closed temporarily should be placed into an additional approved outer package. For the purpose of transportation sharps boxes should be; o Placed in the boot of the vehicle. o Kept upright and secured using a vehicle hook. o Moved with the aperture in full closure mode, OR o Moved within an additional UN approved box if closure is temporary. o Kept out of site and locked when the vehicle is left unattended. Normally, the carriage of any quantity of clinical waste requires the carrier (e.g. healthcare worker) to fit a 2 kg fire extinguisher irrespective of the quantity of waste. The Department for Transport has issued an authorisation to exempt community nurses from this requirement Note: If infectious or hazardous waste is produced within a community environment that cannot be removed by the healthcare worker in a safe manner, contact the Infection Control Department for advice. Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
22 9. Development & Consultation This Policy was written by the SMS Estates and Facilities in consultation with the Infection Control Team and distributed widely for consultation with a selection of key individuals within the Trust. 10. Monitoring of Compliance & Effectiveness The monitoring of compliance with, and the effectiveness of, the Trust s Waste Management Policy will be achieved through the programming of regular, systematic and documented internal waste audits in accordance with both Duty of Care requirements and the requirements set out in the Trust s Environmental Management System which is implemented, and externally accredited, in accordance with International Standard ISO Documentation relating to the scheduling, conducting and recording of these audits is maintained within the Trust s documented Environmental Management System which is held within the SMS Estates and Facilities. 11. References External documents: Department of Health Health Technical Memorandum 07-01: Safe Management of Healthcare Waste (updated March 2011) BS EN15713:2009 Secure Destruction of Confidential Material Code of Practice Environment Agency Hazardous Waste Technical Guidance Note WM2, April 2011 Version 2.3 DEFRA Guidance for Dentists on Waste Dental Amalgam, 2005 Internal documents: Mersey Care NHS Trust Environmental Management System (EMS) documentation held locally within the SMS Estates and Facilities. Mersey Care NHS Trust Infection Prevention & Control Policy (IC01) The contact for accessing Environmental Management System documents is: Louise Leyshon, Environmental Manager, SMS Estates and Facilities, V7 Building, Kings Business Park, Prescot, L34 1PJ. Tel: [email protected] Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
23 12. Glossary of terms No glossary of terms. Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
24 13. Appendices APPENDIX 1 WASTE DISPOSAL STREAM TABLE In order to comply with current legislation and avoid prosecution waste needs to be segregated according to the colour coding and the definitions below and labelled with the relevant EWC code: Note: Codes with an * indicate hazardous wastes Yellow Lid Sharps Bin Medicinal Sharps Waste Sharps contaminated with non-cytotoxic and noncytostatic medicines Syringes containing medicines or medicinal residue Medicinally contaminated Single Use Sharp metal Instruments e.g. scalpel blades, needles, razors, stitch cutters, ampoules Incineration EWC code: * Note - Where appropriate needles and syringes should be discarded as one unit, unsheathed and immediately after use Purple Lid Sharps Bin Cytotoxic or Cytostatic Sharps Waste Sharps waste contaminated with cytotoxic / cytostatic (hazardous) medicinal products Cytotoxic or Cytostatic contaminated sharps Used medical instruments contaminated with hazardous medicines Note: The Pharmacy Department supply containers with any issue of cytotoxic injectables Incineration. Will require labelling as hazardous waste EWC code: * Yellow Lid Bin Pharmaceutical Waste Flammable and Harmful & Corrosive All unused pharmaceutical products that are flammable, harmful or corrosive All pharmaceuticals except cytotoxic and cytostatic waste Note - Liquid pharmaceuticals must be discarded into a leak proof container Note Flammable must be segregated from Harmful & Corrosive waste into separate bins. Bins must be stickered to identify contents Incineration. Flammable waste disposed of by alternative means EWC code: * / Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
25 Purple Lid Bin Pharmaceutical Waste - Cytotoxic and Cytostatic (not flammable, harmful or corrosive) All unused pharmaceutical products that are NOT flammable, harmful or corrosive (including cytotoxic and cytostatic) Blister packs of tablets Bottles containing liquid medicines Disposable liquid dispensing cups with medicinal residue Note - Liquid pharmaceuticals must be discarded into a leakproof container Incineration. Will require labelling as hazardous waste EWC code: * Yellow Bag or Yellow Bin (Leakproof) Orange bag Hazardous (Chemical or Highly Infectious) Waste The Trust produces no highly infectious waste contaminated with Category A pathogens ( ) and only small amounts of hazardous chemical waste ( ). Contact SMS Estates and Facilities for special collection arrangements. Used body fluid spillage kits Hazardous Infectious or Clinically Assessed as Potentially Infectious Waste Any waste which consists wholly or partly of human tissues, blood or other bodily fluids or excretions that are infectious or have been clinically assessed as potentially infectious, or waste contaminated with the same E.g. Dressings from infected wounds Swabs used for cleaning infected wounds Contaminated used protective clothing Infectious waste ( Category Group B waste), contaminated with Hep B, HIV etc Infected Single Use Plastic Instruments (not sharps) Paper towels used to clean up spillages of infectious bodily fluids Note: Where significant volumes of fluids are present these must be soaked up by absorbent dressing material placed within the bag. Only during outbreaks of infection should all bodily fluid contaminated waste be assumed to be infectious Incineration requires special arrangement EWC code: / * Incineration - but can also be treated to render safe in a licensed / permitted treatment facility EWC code: * Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
26 Yellow & Black Stripped Bag (Tiger Bags) Offensive / Non-Infectious Waste Waste assessed by a Healthcare professional to be noninfectious. This is not hazardous waste and does not require specialist treatment or disposal, but may cause offence to those coming in contact with it. This is the majority of healthcare waste produced by the Trust. E.g: Sanitary products. Incontinence products. Disposable medical equipment. Catheter / Stoma bags. Dressings and wipes. Other items contaminated with bodily fluids not assessed to be infectious Deep landfill or energy from waste plant EWC code: Black bags White Container Domestic Waste Waste similar in nature and composition to that produced by households. Paper, clean packaging. Food. Paper hand towels, couch roll * Gloves * Plastics * NOT contaminated with bodily fluids Amalgam Waste Amalgam waste to be placed in dedicated white rigid containers which have a mercury suppressant Recycled / Reused / Landfill EWC code: Specialist Recovery EWC Code: * Leak-proof Yellow Bin with Biohazard Marking Radioactive Waste Waste contaminated with low levels of radioisotopes from x-ray departments must be disposed of in rigid, leak-proof containers showing the bio-hazard marking. Disposal must be in accordance with the Radioactive Substances Act 1993 by incineration at a licensed facility Incineration EWC code: * (infectious) Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
27 Other Wastes By Type: Mattresses Non-Contaminated and Contaminated Mattresses Non-Contaminated Mattresses Mattresses not contaminated internally with bodily fluids should be cleaned with high level disinfectant and placed into a clear mattress bag. Clear bags can be requested from the Transport Department. Contaminated Mattresses Mattresses which are contaminated internally with bodily fluids need to be placed in a clinical waste mattress bag and secured with a tag and disposed of as hazardous / infectious waste. Large yellow clinical waste mattress sacks can be requested from the Infection Control Department via [email protected] or contacting them on Removal of Mattresses Request removal by completing a Transport Request Form and sending to the Transport Department if based in Local Services: [email protected] or fax number If based in Ashworth Hospital contact the Portering Department: [email protected] or telephone number Note: All mattresses need to display the completed Declaration of Contamination Status sample attached as Appendix 8. Autoclaving EWC Code: * Recycled EWC Code: X-Ray Waste Fixer & Developer Leak-proof Rigid Container May be classified as hazardous waste depending on the type of materials used refer to manufacturer s safety data sheet If appropriate, send to licensed facility for material recovery through a specialist contractor. If recovery is not appropriate, fixer and developer should be incinerated at a licensed facility Incineration or Specialist Recovery EWC code: XX* Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
28 Contaminated Medical Devices Secure Packaging appropriate to device Contact Infection Control for advice regarding decontaminating medical devices e.g. sphygmomanometers, suction machines. After decontamination contact SMS Estates and Facilities to arrange for specialist disposal. Declaration of Contamination Status certificate must be completed and attached Landfill or Incineration depending on hazardous properties EWC Code: Depends on nature of device Furniture Redundant furniture from direct patient care areas must be decontaminated in accordance with the Trust s Infection Control Policy (IC01) and have a Declaration of Contamination Status certificate attached. For disposal of all furniture contact: Ashworth Hospital contact Phil Kavanagh ([email protected] or ) to arrange collection. Other Trust sites complete a works request form and to [email protected] NOTE: Furniture disposed of through Trust contracts goes to landfill so consider any reuse options available before using this route. For example, circulate an around the Trust advertising the items for reuse. Landfill or Reuse EWC Code: Electrical & Electronic Equipment All Electrical and Electronic Equipment including: Any item with a plug, battery or that can carry an electrical current, e.g. Fridges; Fluorescent Tubes; Ovens; Heaters All items must be disposed of in accordance with the Waste Electrical & Electronic Equipment Regulations 2007 Fluorescent tubes are exchanged and disposed of by MITIE - contact to arrange Bulky electrical items (e.g. fridges / ovens) follow the procedure as for furniture (above) to arrange for collection and disposal Recycling / Recovery Fridges * Fluorescent Tubes * Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
29 Batteries Cardboard Office Paper Confidential Paper Best Practice to Segregate - includes all types of Batteries both household and industrial AA/AAA Batteries Gel Batteries from wheelchairs Camera batteries etc Batteries are separately collected by way of a battery compliance scheme at the shop on the Ashworth Hospital (HSS) site. Other sites can arrange for battery containers to be sited through a similar compliance scheme (such as Battery back) or contact SMS Estates and Facilities for details of licensed contractors All cardboard packing should be flattened, kept dry and placed within the general waste containers on site as part of the commingled waste collection and removal from site for recycling Non-confidential paper waste should be placed within dedicated office waste paper recycling bins in plastic sacks. When full the sacks should be tied and placed in the general waste containers for collection and recycling by the commingled waste contractor All confidential waste paper must be shredded to British Code of Practice (BS EN 15713:2009) either on site or bagged for collection (brown sacks) by the Trust s specialist shredding and console contractor Ashworth Hospital contact Phil Kavanagh ([email protected] or ) to arrange collection or for sack supplies Other Trust sites with consoles contact Louise Leyshon, Environmental Manager on or [email protected] or Alex Cremona at Shred-it [email protected] or or Other Trust sites without consoles [email protected] with budget code, number of sacks and location Recycling / Recovery EWC Code: * Recycling EWC code: Recycling EWC code: Recycling EWC code: IT Equipment IT equipment is classified as hazardous waste under the Waste Electrical & Electronic Equipment (WEEE) Regulations. Contact the Desktop Service Team Engineers through the IT Service Desk (x. 2619) to arrange collection. Recycling EWC code: * Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
30 Mobile Phones Toner Cartridges Cooking Oil Waste Engine Oil Paints Solvents / Thinners Aerosols Asbestos Mobile phones are classed as hazardous wastes and need to be disposed of through the correct routes. Contact the Voice & Data Team on to arrange disposal. The Trust operates a Trust wide toner cartridge recycling scheme whereby the cartridges are returned to either Office Depot or HP when new supplies are delivered. Collection boxes are available to order from either the Office Depot, HP websites or NHS Supply Chain. Cooking Oil is collected for recycling using a specialist contractor. Waste engine oil is hazardous waste and must be stored in bunded containers (away from drains) prior to collection for reprocessing by a specialist contractor. Contact the SMS Estates and Facilities to arrange a collection. Paints and empty paint cans containing paint residues are hazardous wastes and need to be stored in secure, leak-proof containers, away from drains, prior to collection by a licensed contractor. Contact the SMS Estates and Facilities to arrange a collection. Solvents and containers which previously contained solvents are hazardous wastes and need to be stored in enclosed containers, prior to collection by a licensed contractor. Contact the SMS Estates and Facilities to arrange a collection. Fully discharged aerosols that previously contained hazardous or dangerous components (e.g. paints, pesticides, solvents) will still contain hazardous residues and will therefore need to be disposed of as hazardous wastes Any waste which is suspected to contain asbestos needs to be removed and disposed of in accordance with the Trust s Asbestos Management Policy. Contact the SMS Estates and Facilities for further information. Recycling EWC code: * Recycling EWC code: * Recycling EWC code: * Recycling EWC code: * to * Recovery / Hazardous waste landfill EWC code: * Recovery / Hazardous waste landfill EWC code: * * Hazardous waste landfill EWC code: * Hazardous waste landfill EWC code: * Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
31 Construction Waste Other Chemicals The Trust maximises the recycling of any construction waste produced as a result of renovation projects in conjunction with its contractors and within the requirements of the Site Waste Management Plans Regulations Refer to the product s Safety Data Sheet for information on correct disposal and an indication of its hazardous status. Contact SMS Estates and Facilities to arrange for appropriate disposal of hazardous chemicals through the Trust s main waste contractor Recycling EWC code: * Depends on nature of the chemical For general waste management queries please contact: SMS Estates and Facilities V7 Building Kings Business Park Prescot L34 1PJ Tel: Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
32 APPENDIX 2 European Waste Catalogue (EWC) Codes for Common Healthcare Waste Types to be shown on waste transfer notes (* indicates hazardous wastes) EWC code Description of code 09 Wastes from the photographic industry Wastes from the photographic industry * Water-based developer and activator solutions * Water-based offset plate developer solutions * Solvent-based developer solutions * Fixer solutions * Bleach solutions and bleach fixer solutions * Wastes containing silver from on-site treatment of photographic waste Photographic film and paper containing silver or silver compounds Photographic film and paper free of silver or silver compounds 18 Wastes from human and animal health care and/or related research (except kitchen and restaurant wastes not arising from immediate health care) Waste from natal care, diagnosis, treatment or prevention of disease in humans Sharps except * Body parts and organs including blood bags and blood preserves * Waste whose collection and disposal is subject to special requirements in order to prevent infection Waste whose collection and disposal is not subject to special requirements in order to prevent infection, e.g. dressings, plaster casts, linen, disposable clothing * Chemicals consisting of or containing dangerous substances Chemicals other than those listed in * * Cytotoxic and cytostatic medicines Medicines other than those mentioned in * * Amalgam waste from dental care 20 Municipal wastes (household waste and similar commercial, industrial and institutional wastes) including separately collected fractions Separately collected fractions (except 15 01) * Cytotoxic and cytostatic medicines Medicines other than those mentioned in * Other fractions not otherwise specified (used for offensive waste) Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
33 APPENDIX 3 Hazard Groups Which Identify Waste as Hazardous The 14 hazard groups that make waste hazardous are: Hazard Group Hazard Symbol Description H1 H2 H3A Explosive. Substances and preparations which may explode under the effect of flame or which are more sensitive to shocks or friction than dinitrobenzene Oxidising. Substances and preparations which exhibit highly exothermic reactions when in contact with other substances, particularly flammable substances Highly flammable. H3B H4 H5 H6 H7 H8 H9 H10 H11 H12 H13 H14 Flammable. Liquid substances and preparations having a flashpoint equal to or greater than 21 C and less than or equal to 55 C Irritant. Non-corrosive substances and preparations which, through immediate, prolonged or repeated contact with the skin or mucous membrane, can cause inflammation Harmful. Substances and preparations which, if they are inhaled or ingested or if they penetrate the skin or mucous membrane, can cause inflammation Toxic. Substances and preparations (including very toxic substances and preparations) which, if they are inhaled or ingested or if they penetrate the skin, may involve serious, acute or chronic health risks and even death Carcinogenic. Substances and preparations which, if they are inhaled or ingested or if they penetrate the skin, may induce cancer or increase its incidence Corrosive. Substances and preparations which may destroy living tissue on contact Infectious. Substances containing viable micro-organisms or their toxins which are known or reliably believed to cause disease in man or other living organisms Toxic for reproduction. Substances and preparations which, if they are inhaled or ingested or if they penetrate the skin, may produce or increase the incidence of non-heritable adverse effects in the progeny and / or of male or female reproduction functions or capacity Mutagenic. Substances and preparations which, if they are inhaled or ingested or if they penetrate the skin, may induce hereditary genetic defects or increase their incidence. Substances and preparations which release toxic or very toxic gases in contact with water, air or an acid. Substances and preparations capable by any means, after disposal, of yielding another substance e.g. leachate, which possesses any of the characteristics listed above. Ecotoxic. Substances and preparations which present or may present immediate or delayed risks for one or more sectors of the environment Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
34 APPENDIX 4 - Table Showing Relation Between Hazardous & Clinical Waste Definitions NON-HAZARDOUS WASTE Clinical waste HAZARDOUS Clinical waste Medicines other than those that are cytotoxic and cytostatic , , Non-infectious anatomical waste, chemicals present and and Cytotoxic and cytostatic medicines , , Non-clinical waste Non-infectious anatomical waste, no chemicals present , Clinical waste: infectious waste for carriage (Category A UN 2814/UN 2900; Category B UN 3291) Infectious anatomical waste no chemicals present , Cytotoxic and cytostatic sharps and and Sharps not contaminated with body fluids or medicines , Infectious anatomical waste, chemicals present and and Other medicinally contaminated sharps and and Non-infectious gypsum (plaster) wastes Other clinical infectious waste containing chemicals and and Non-medicinally-contaminated sharps , Offensive/hygiene waste , Infectious gypsum (plaster) * Other clinical infectious waste arising from healthcare activities , Mixed municipal waste Infectious waste containing dental amalgam * and Recyclables (various) Non-clinical waste Healthcare chemicals with hazardous properties , Healthcare chemicals without hazardous properties , Dental amalgam X-ray fixer and developer , , , , Note: Colours shown in the tables relate to the colour of the container used for disposal, in accordance with classification in Appendix 1. From Department of Health guidance Safe Management of Healthcare Waste HTM (updated March 2011) Mersey Care NHS Trust Corporate Waste Management Policy Version 3 Review Date: April
35 APPENDIX 5 SAMPLE HAZARDOUS WASTE CONSIGNMENT NOTE Example for general practice PART A Notification Details 1. Consignment note code: ABC123/AB The waste described below is to be removed from (name, address, postcode, telephone, e mail & fax): The General Practice, High Street, New Town, The Shire, XX12 3YY Tel , [email protected] 3. Premises code: ABC The waste will be taken to (address and postcode): The Transfer Station, Low Street, Old Town, The Shire YY12 4XX 5. The waste producer was (if different from 1) (name, address, postcode, telephone, e mail & fax) PART B Description of waste 1. The process giving rise to the waste(s) was: Dental healthcare. 2. SIC for the process giving rise to the waste: WASTE DETAILS (where more than one waste type is collected all of the information given below must be completed for each EWC identified). Description of waste EWC code Qty (kg) Physical form Hazard code(s) Cytotoxic and Cytostatic clinical waste: Mixed sharps and pharmaceutical waste for incineration only Clinical waste: Mixed sharps and pharmaceutical waste for incineration only Clinical waste: nonmedicinally contaminated sharps for incineration only Clinical waste: infectious, suitable for alternative treatment Clinical waste: infectious, containing chemicals and pharmaceuticals Clinical waste: anatomical for incineration only * * The chemical/biological components of the waste, their concentrations Sharps, syringe barrels, medicine vials and ampoules (cytotoxic and cytostatic); see attached list 10 kg Sharps, syringe barrels, medicine vials and ampoules (not cytotoxic and cytostatic) * 10 kg Sharps contaminated with body fluids, podiatry instruments * 20 kg Dressings, PPE and swabs, not contaminated with chemicals or medicines. Contains ZnO dressings * * 20 kg Medicated dressings, Formaldehyde preserved specimens mixed H3, H6, H7, H9, H10, H11 mixed H3, H4, H5, H9, H14 Container type, number & size 2 14 litre purple lidded sharps box 7 14 litre yellow lidded sharps box mixed H litre orange lidded sharps box mixed H9, H14 27 orange bags mixed H9, H7 1 yellow bag * Placenta mixed H litre green lidded bin ADR information for each EWC identified above: EWC Description for Carriage Special handling requirements code * UN 3291 Clinical waste, unspecified, n.o.s, 6.2, II No persons in handling chain to have direct contact. Waste to be disposed of at authorised site etc etc etc Page 33 of 59
36 PART C Carriers certificate (If more than one carrier is used, please attach a schedule for subsequent carriers. If a schedule of carriers is attached tick here) I certify that I today collected the consignment and that the details in A2, A4 and B3 are correct and have been advised of any specific handling requirements: 1. Carrier driver name (please PRINT) Tony Driver 2.Onbehalf of (name, address, postcode, telephone, & fax) The Transfer Station, Low Street, Old Town, The Shire, YY12 4XX Tel: ; [email protected] 3. Carrier s registration no/exemption reason: ABC/ Vehicle registration no: AB07 FIL Signature Time: Date: 29/02/2010 PART D Consignors/holders certificate I certify that the information in A, B and C above is correct, that the carrier is registered or exempt and was advised of the appropriate precautionary measures. All of the waste is packaged and labelled correctly and the carrier has been advised of any special handling requirements. 1. Consignor/Holder name (please PRINT) Mr Sydney Note on behalf of (name, address, postcode, telephone, and fax) The General Practice, High Street, New Town, The Shire, XX12 3YY Tel , [email protected] Signature Time: Date: 29/02/2010 PART E Consignees Certificate (where more than one waste type is collected, all of the information given below must be completed for each EWC) Individual EWC code(s) received Quantity of each EWC code received (kg) EWC code accepted/ rejected Waste Management operation (R or D code) I received this waste at the address given in A4 on Vehicle registration no (or mode of transport if not by road): Where waste is rejected please provide details: I certify that the waste management licence/permit/authorised exemption no(s). Name: (please PRINT) On behalf of (name, address, postcode, tel, & fax): Signature: Date: Time: authorises the management of the waste described in B at the address given at A4 Page 34 of 59
37 APPENDIX 6 WASTE AUDIT SELF-ASSESSMENT TOOL WASTE MANAGEMENT AUDIT STANDARD QUESTIONS Yes No If No state reasons Q1 Q2 Q3 Q4 Q5 Are staff aware of the Waste Management Policy and Procedures? Are staff made aware of waste policy and procedures as part of their induction training? Do the Ward/Department/Health Centre or Clinic have Waste Management notices displayed? Do all of the waste bins have notices displayed above them or on them identifying what waste can be disposed in them? Are the main containers for the waste bags and sharps bins in a locked and secure area? Q6 Q7 Q8 Is the main storage area clean and tidy? Are the main containers for clinical and sharps waste locked? Is clinical waste segregated from other waste? Q9 Q10 Q11 Are clinical waste sacks labelled and secured before disposal? Is the Record Book for clinical waste tags complete and up to date? Have tags been sequentially issued? Have Duty of Care Transfer notes (or hazardous waste consignment notes) been completed correctly and kept on file (if held locally)? Please return completed audit sheets to: Louise Leyshon, SMS Estates and Facilities, V7 Building, Kings Business Park, Prescot, L34 1PJ. Tel: [email protected] Page 35 of 59
38 APPENDIX 7 GUIDANCE FOR MANAGERS ON LOCAL INDUCTION TRAINING FOR WASTE MANAGEMENT The attached pro-forma must be completed with any induction documentation and placed on the staff member s personal file. At local induction every new member of staff must be given information and guidance on the Trust s Waste Management policy and procedures. This is in addition to the training they will receive when attending induction training. The overall aim of waste management training is to provide staff with the knowledge to dispose of waste in a safe and cost reducing manner. The bullet points listed below should be used as a basis for informing staff members of their responsibilities when dealing with waste disposal. As a minimum staff should receive information on each of the following areas to ensure they have a holistic view of waste management. Information within these procedures will provide further guidance on each point. Why the Trust operates a waste management system How waste should be segregated The difference between hazardous, clinical and domestic type waste How to dispose of waste safely Waste documentation and filing (where this is held locally) What to do in the event of a spillage or sharps injury Where to obtain PPE equipment Where to obtain waste bags and sharps bins Who to contact to receive further information regarding storage and collection of waste for the staff member s designated base How to report an incident Who to contact to arrange waste collections from the Community Community Clinical staff only Page 36 of 59
39 APPENDIX 8 SAMPLE DECONTAMINATION CERTIFICATE DECLARATION OF CONTAMINATION STATUS Prior to Inspection, Servicing, Repair, Condemning or Return of Medical Devices and Other Equipment Make and Description of Equipment: Model/Serial/Batch No: Tick box A if applicable. Otherwise complete all parts of B, providing further information as requested or appropriate A. This equipment/item has not been used or been in contact with blood, other body fluids, respired gases, or pathological samples. It has been cleaned in preparation for inspection, servicing, repair, condemning or transportation. B. 1. Has this equipment/item been exposed internally or externally to hazardous materials as indicated below? Provide further details here YES/NO Blood, body fluids, respired gases, infected wounds, pathogens or pathological samples: YES/NO Other biohazards: YES/NO Chemical or substances hazardous to health: YES/NO Other hazards: 2. Has this equipment/item been cleaned and decontaminated as per Infection Control Prevention and Control of Infection Policy guidelines? YES NO Indicate the methods and materials used: If the equipment/item could not be decontaminated please indicate why: Equipment that has not been decontaminated must not be returned/transported without the prior agreement of the MCT Infection Control Team, and must not be collected/transported unless written instruction is received from the MCT Infection Control Team. 3. Describe how the equipment/item has been packaged to ensure safe handling/transportation. I declare that I have decontaminated the above stated equipment/item, in accordance with the Infection Control Prevention and Control of Infection Policy Decontamination of Equipment Section Authorised signature Unit Name (printed) Dept Position Tel No Date The Infection Control Team can be contacted on Page 37 of 59
40 IMPLEMENTATION PLAN for the CORPORATE WASTE MANAGEMENT POLICY DOCUMENT NUMBER RATIFYING COMMITTEE Policy Group DATE RATIFIED 21 July 2011 NEXT REVIEW DATE July 2012 ACCOUNTABLE DIRECTOR: Director of Facilities DOCUMENT AUTHOR: Manager Facilities Information Systems An implementation plan should be completed for all procedural documents. This will ensure that a systematic approach is taken to the introduction of procedural documents in order to secure effective working practices. NB The implementation plan should include actions to address issues identified through the equality and diversity impact assessment process as well as those specific to the policy itself. The following template provides a checklist to be used as a starting point for thinking about implementation in a systematic manner. It is evidence-based and draws on the work of the Promoting Action on Clinical Effectiveness (PACE) programme (Dunning et al, 1999). Dunning et al (1999) Experience Evidence and Everyday Practice, Kings Fund Page 38 of 59
41 1. Co-ordination of implementation How will the implementation plan be coordinated and by whom? Clear co-ordination is essential to monitor and sustain progress against the implementation plan and resolve any further issues that may arise. 2. Engaging staff Who is affected directly or indirectly by the policy? Are the most influential staff involved in the implementation? Engaging staff and developing strong working relationships will provide a solid foundation for changes to be made. 3. Involving service users and carers Is there a need to provide information to service users and carers regarding this policy? Are there service users, carers, representatives or local organisations who could contribute to the implementation? Involving service users and carers will ensure that any actions taken are in the best interest of services users and carers and that they are better informed about their care. Issues identified / Action to be taken The Director of Facilities will coordinate the activities of the implementation plan through direct delegation to the Facilities Information Systems Manager and the Facilities Compliance Manager All Trust Staff Visitors to Trust Sites (Trust Staff and General Public) Executive Directors and other Senior Managers Communications Department vital in disseminating information and raising awareness of staff An Environmental Management Group which includes Senior Managers from all key departments has been formed to manage the implementation of the Policy requirements There is no specific need to provide service users and carers with a copy of the policy unless Managers / Heads of Service initiate a local policy of involvement. However, copies can be provided on request and a copy will be available via the Trust website Service Users and Carers will not be involved in implementing the policy Time-Scale July 2011 September 2011 N/A Page 39 of 59
42 4. Communicating What are the key messages to communicate to the different stakeholders? How will these messages be communicated? Effective communication will ensure that all those affected by the policy are kept informed thus smoothing the way for any changes. Promoting achievements can also provide encouragement to those involved. Issues identified / Action to be taken The key messages are: The need to ensure the legal, safe and appropriate management and disposal of all elements of the Trust s waste stream The need to maximise the segregation of waste and optimise recycling opportunities The message will be communicated through: Publishing Policy on the Trust s Website: Engaging the Environmental Champions Communication broadcasts, s etc. Trust publications Mersey Cares for Staff / Mersey Cares Time-Scale September 2011 Page 40 of 59
43 5. Resources Have the financial impacts of any changes been established? Is it possible to set up processes to reinvest any savings? Are other resources required to enable the implementation of the policy e.g. increased staffing, new documentation? Identification of resource impacts is essential at the start of the process to ensure action can be taken to address issues which may arise at a later stage. 6. Securing and sustaining change Have the likely barriers to change and realistic ways to overcome them been identified? Who needs to change and how do you plan to approach them? Have arrangements been made with service managers to enable staff to attend briefing and training sessions? Are arrangements in place to ensure the induction of new staff reflects the policy? Initial barriers to implementation need to be addressed as well as those that may affect the on-going success of the policy Issues identified / Action to be taken The policy has been developed in order to increase process efficiencies and potentially generate savings from these. Indirect reinvestment opportunities maybe considered but these cannot be identified at this stage Staffing resources need to be addressed the Trust is currently under-resourced in this vital area and a dedicated post needs to be sourced. This will be addressed following the organisational review of SMS Estates and Facilities Indirect & direct costs associated with staff training including staff waste segregation and management training. Any specialist training will be need to be funded from within existing Department budgets No significant barriers to change have been identified. The Trust currently has good internal processes for the management of its waste. This Policy is an updated version which has been revised in line with changes to waste management legislation and technological developments which have revised best practices governing the management of different waste streams Waste management awareness training sessions shall be arranged and communicated to service managers as required to meet the plan Waste management and segregation awareness training sessions shall be included into the staff induction programme and local induction training Time-Scale October 2011 October 2011 Page 41 of 59
44 7. Evaluating What are the main changes in practice that should be seen from the policy? How might these changes be evaluated? How will lessons learnt from the implementation of this policy be fed back into the organisation? Evaluating and demonstrating the benefits of new policy is essential to promote the achievements of those involved and justifying changes that have been made. Issues identified / Action to be taken 8. Other considerations None identified Increased awareness of the need for waste segregation, waste minimisation, improved waste recycling and many other indicatives. Improved management of risk regarding hazardous waste issues Improved waste minimisation and recycling performance Changes evaluated through Financial analysis, annual evaluation through ERIC reporting; introduction of local environmental KPI s as part of the SMS Estates and Facilities Dashboard; benchmarking with other Mental Health Trusts, Staff Surveys and other means. Time-Scale April 2012 Page 42 of 59
45 Page 43 of 59
46 Stage 1 Single Equality and Human Rights Screen Name of Document Corporate Waste Management Policy Who does it relate to Staff x Service Users x Carers & others x Area of Trust it covers Corporate Names of people completing screen (Minimum of 3) Alan Pennington Andrew Pople Ruth Miller (external consultant) Barb Rafferty / George Sullivan What is the purpose of policy / service change /strategy. what is your this document trying to achieve To provide guidance on the safe segregation, handling, storage, transportation and disposal of waste in an environmental responsible and cost effective manner. The screening of any document is completed to ensure that it does not have either a Direct or Indirect impact on any members from particular protected Equality Groups. Page 44 of 59
47 If there is an actual or possible discrimination please tick Y and give a reason Equality Strand Age Y N Reasoning X Disability inc Learning Disability Gender X X Race Inc Gypsies and travellers and Asylum Seekers Religion and Belief X X Sexual Orientation X Transgender X X Page 45 of 59
48 Cross cutting Total Accessibility Is it clear that this document is available in other formats: Yes No Comment Other comments noted from the assessment. Any areas highlighted by the EIA assessors must be put into an action plan. This must record all areas noted even when it can be rectified immediately. The document with the assessment, which includes the action plan, must be available for scrutiny and be able to show:- What has been highlighted What has been done to rectify immediately What time frame has been agreed to rectify in the future Page 46 of 59
49 HUMAN RIGHTS IMPACT ASSESSMENT Right of freedom from inhuman and degrading treatment (Article 3) Does this policy ensure N/A people are treated with dignity and respect Could this policy lead to degrading or inhuman treatment (eg lack of dignity in care, excessive force in restraint) How could this right be protected? Right to life (Article 2) Does this policy help protect Health and Safety issues to protect life a persons right to life? Does this policy have the potential to result in a persons loss of life? How could this right be protected? Right to a fair trial (Article 6) Does this policy support the N/A right to a fair trial? Does this policy threaten the right to a fair trial? (eg no appeals process) How could this right be protected? Right to liberty (Article 5) Does this policy support the N/A right to liberty? Does this policy restrict the right to liberty? Page 47 of 59
50 Is the restriction prescribed by law? Page 48 of 59
51 Right to private and family life (Article 8) Does this policy support a N/A persons right to private and family life Does this policy have the potential to restrict the right to private and family life How could this right be protected? Is it prescribed by law? Is it necessary? Is it proportionate? Right to freedom of expression Note: this does not include insulting language such as racism (Article 10) Does this policy support a N/A persons ability to express opinions and share information Does this policy interfere with a person s ability to express opinions and share information? Is it in pursuit of legitimate aim? Is it prescribed by law? Is it necessary? Is it proportionate? Right of freedom of religion or belief (Article 9) Does this policy support a N/A person s right to freedom of religion or belief? Does this policy interfere Page 49 of 59
52 with a person s right to freedom of religion or beliefs? (e.g. prevention of a person practising their religion Is it in pursuit of legitimate aim? Is it prescribed by law? Is it necessary? Is it proportionate? Right freedom from discrimination (Article 14) If you have identified an impact, will this discriminate against anyone group in particular? Disability and Race Is the Document:- Compliant Non compliant - With actions immediately taken Action Plan completed y/n Y y/n y/n Full Impact Assessment Required Lead Assessor XXXX Date XXXXX y/n Page 50 of 59
53 ACTION PLAN Age Impact Noted Action Required Action Taken Date to be completed. Disability Gender Race Religion and Belief Page 51 of 59
54 Sexual Orientation Transgender Cross cutting Human Rights Page 52 of 59
55 Stage 2 FULL EQUALITY AND HUMAN RIGHTS IMPACT ASSESSMENT Title of function, policy or procedure Corporate Environmental Policy Manager responsible for this function, policy or procedure. Andrew Pople Assessors Andrew Pople Alan Pennington Ruth Miller (external consultant) Barb Rafferty / George Sullivan Department and remit of service delivery ( indicate commissioning boundaries) SMS Estates and Facilities Do you know the Demographic/equality breakdown of area document covers ( if not this must be included as an action within the action plan) Policy will apply Trust Wide Page 53 of 59
56 Aims and Purpose Describe the aims and purpose of this function, policy or procedure To provide guidance on the safe segregation, handling, storage, transportation and disposal of waste in an environmental responsible and cost effective manner. Describe the desired outcomes of this function, policy or procedure Compliance to relevant legislation and other guidance to which the trust subscribes. Improve waste segregation and recycling opportunities Pollution prevention control Clear accountability arrangements Target Group State who the function / policy / procedure/strategy is aimed at. No equality target group Is Monitoring a part of this document? ( if no please detail why not And/or add monitoring requirement to action plan) Duty of Care Audits to be conducted regularly Page 54 of 59
57 Management and Monitoring Auditable evidence must be kept. In this section describe the management arrangements for this function / policy / procedure/strategy. Name and role of How is this to be managed? lead. Andrew Pople Facilities Information Systems Manager Legislative compliance updates. Duty of Care Audits Waste Management update training Consider inclusion in Induction Training In this section describe the monitoring arrangements for this function / policy / procedure/strategy Name and role of How is this to be monitored? lead. Andrew Pople Facilities Information Systems Manager Will be enabler of policy, procedures and projects with regards to Waste management Use this space below to analyse results from the auditable evidence. e.g. Consultation or monitoring. Page 55 of 59
58 Page 56 of 59
59 Consultation Is consultation/further evidence required. *Please state reasons for not undertaking consultation, if that is decided. It is important that consultation occurs with key stakeholders those who are either directly affected by the function/policy/procedure/strategy those external bodies with an interest in the impact of Mersey Care NHS Trust policies. In terms of this, list who you consider to be your key stakeholders. The Waste Management policy must conform to all applicable waste legislation. Use this section to describe the methods of consultation used, including dates and times. Use this section to analyse the main issues arising out of the consultation exercises. Conclusion Page 57 of 59
60 Having thought about the potential negative impact on different equality groups, examined all the sources of information for evidence of previous discrimination. Consulted relevant stakeholders if appropriate to assess whether the function, policy or practice is meeting the needs of different equality groups. Is the function / policy / procedure/strategy fit for purpose? State the rationale behind this. Yes this policy is fit for purpose as it does not impact negatively on an equality target group adversely. Any actions identified can be overcome quickly. The function / policy / procedure/strategy is not fit for purpose. Complete the equality action plan to enable the implementation Who will be responsible for the Equality Impact Action Plan? Andrew Pople Information Systems Manager Mersey Care NHS Trust Page 58 of 59
61 Record of Review State how often this function, policy, strategy or procedure will be reviewed. Annually State who will be responsible for the review. Andrew Pople Signed Equality Action Plan Co-ordinator:- Signed (person responsible for function / policy / strategy/procedure: Print name: Date: Print name: Date: Page 59 of 59
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