Waste Management Policy

Transcription

1 Waste Management Policy Date Approved by Trust Board Version Issue Date 29/1/13 Four January 2013 Review Date January 2015 Executive Lead Lead Executive Director for Estates & Facilities Procedure/Policy RM0041.V4 Number Procedure/Policy Risk Management Policy type Date Equality impact assessment completed: December 2012 Information Asset Owner Head of Facilities Author Brian Gaff Health & Safety Advisor Page 1 of 62

2 DOCUMENT INFORMATION AND AMENDMENT RECORD Document Number: RM0041.V4 Document Title: Executive Lead: Waste Management Policy Executive Director for Estates & Facilities Amendments page Amendment number 1 Amendment / description Person making amendment (Role) Date of amendment Page 2 of 62

3 Index Section Title Page Number 1 Introduction 4 2 Purpose and Aim of the Policy 4 3 Responsibilities 4 4 Legislation and Statutory Requirements 7 5 Environmental Protection Act Definition of Waste 8 7 Waste Management Waste Hierarchy 9 8 Segregation and Containment of Waste 9 9 Waste generated in the Community BIOTRACK Collection of Waste from other Organisations Waste Transfer and Waste Consignment Notes Selection of Waste Contractors Site Registration Discharge to Drain Recycling and Waste Minimisation Waste Management Site Plans Risk Assessment Personal Protective Equipment Staff Training Requirements Chemical Storage Accidents and Incidents Waste Management Group Waste Audit Arrangements Review References Equality Impact Assessment 22 Appendix 1 Mercury Spillage Procedure 23 Appendix 2 Infectious Substances included in Category A 25 Appendix 3 Collection of Household Infectious Waste Forms 27 Appendix 4 Waste Container Colour Coding Guide 34 Appendix 5 Biotrack Tagging Guide 35 Appendix 6 Waste Disposal Procedures 36 Appendix 7 Waste Flow Chart 43 Appendix 8 Waste Audit Proforma 44 Appendix 9 Example List of Cytotoxic and Cytostatic Medicines 62 Page 3 of 62

4 1. INTRODUCTION WASTE MANAGEMENT POLICY 1.1 Effective management of waste is essential to any organisation if they are to avoid prosecution, avoid cross-contamination of waste streams and prevent unnecessary financial burden upon the organisation. This policy gives detailed guidance on the measures to take in order to manage waste successfully and specifies everyone s responsibilities for the safe disposal of waste. Waste disposal is a burden on the earth s natural resources. When discarded all the materials, time, energy and money put into producing it in the first place are lost. 1.2 Disposing of waste requires energy and material resources as well as generating emissions. Consequently, as with any other activity, society and industry both need to behave in a sustainable manner so as to safeguard the availability of resources for future generations. In this context waste needs to be considered as a potential resource wherever possible and organisations have an important role to play in making this happen, and ensuring that where waste cannot be reduced, reused or recycled it is disposed of in the most sustainable manner. 2. PURPOSE AND AIM OF THE POLICY The purpose of this policy is to describe in detail the arrangements for the correct segregation, storage, collection and disposal of all types of waste in order to assist managers to establish and maintain safe and effective waste management systems and procedures based on Safe Management of Healthcare Waste best practice. To inform and assist staff to apply correct and safe procedures at all times and comply with the law. 3. RESPONSIBILITIES 3.1. Chief Executive - Is ultimately responsible for the implementation of this policy within the Trust however Heads of Service/Departmental Managers have been delegated the responsibility for implementing the policy within their area(s) of control. 3.2 Lead Executive Director for Estates & Facilities - Is the Board Level Executive Director responsible for waste management and is responsible to the Chief Executive for establishing systems to ensure that waste is effectively managed within the Trust. 3.3 Head of Facilities - Will ensure that processes are in place to monitor compliance with this policy and that any non-conformance is acted upon and will also chair the Trust Waste Management Group. Page 4 of 62

5 3.4 Clinical Business Managers/Heads of Service - Have been delegated the responsibility for implementing this policy within their areas of control by ensuring that: Processes are in place to minimize risks from waste. That all staff have been trained in how to correctly and safely dispose of waste. Risk assessments are carried out for waste management within their areas of control, as appropriate. Setting clear objectives for Ward/Department managers concerning waste management. Ensuring that Ward/Department managers receive appropriate training in the safe management of waste in the workplace. 3.5 Managers - Will be responsible for the operational implementation of safe management of healthcare waste and all supporting legislation within their area(s) of responsibility and in particular will ensure that The waste hierarchy is applied to all materials before they are considered as waste. (see Section 7) Ensure Risk Assessments are carried out for the safe disposal of waste. Waste is correctly segregated into the appropriate containers and that staff are made aware of the correct containers to use. Will respond to any concern raised by staff through liaison with the Waste Officer/Manager. Will act upon the findings of waste audits and take any necessary corrective action. Ensure staff receive adequate training to allow them to safely dispose of all healthcare waste. 3.6 Employees Dispose of waste safely and only in the correct container. The waste hierarchy is applied to all materials before they are considered as waste. (see Section 7) Attend waste management training. Keep all waste streams separate and correctly segregated. Ensure as a minimum that all waste containers detail the hospital or clinic, ward or department and date of disposal. Report all incidents involving waste to their line manager or supervisor. Ensure that sharps boxes are correctly assembled, signed and dated including the ward or department information. Page 5 of 62

6 3.7 Waste Porters/Caretakers - In addition to the duties of employees the Waste Porters/Caretakers will ensure that: Waste is kept segregated throughout transport and disposal. Waste is correctly consigned for disposal and that the waste is only given to a waste contractor approved by the Trust to carry that type of waste. Complete and sign any necessary waste transfer notes or waste consignment notes and return any customer copy to the correct location for retention. 3.8 Waste Manager (SoTW owned premises) Is responsible for providing advice, support, instruction and training for the safe management of healthcare waste through the Service Level Agreement (SLA) with the Trust for community sites and staff based in the community. Is a member of the Trust Waste Management Group. Carrys out waste audits within all community premises and report on the findings to the Trust. Responsible for registering community healthcare sites with the Environment Agency. Complete a pre-acceptance audit, at the required frequencies, for any waste carrier which requires us to produce one using the ward/department waste audits as a basis. As a minimum for clinical waste this is 10% + 1 of all wards/departments plus A & E, Pharmacy, Laboratories and Theatres. 3.9 Health & Safety Advisor Is responsible for updating and reviewing the Trust Waste Management Policy, interpreting and advising the Trust on changes in legislation and providing high level advice and guidance to both the Head of Facilities and Trust Waste Officer. Is a member of the Trust Waste Management Group Trust Waste Officer (Trust owned sites) Is responsible for providing advice, support, instruction and training for the safe management of healthcare waste with support from the Health & Safety Advisor. Carrying out waste audits within all Trust owned sites and report on the findings. This includes any other Trusts whose waste we collect. Complete a pre-acceptance audit, at the required frequencies, for any waste carrier which requires us to produce one using the ward/department waste audits as a basis. As a minimum for clinical waste this is 10% + 1 of all wards/departments plus A & E, Pharmacy, Laboratories and Theatres. Is a member of the Trust Waste Management Group. Page 6 of 62

7 3.11 Infection, Prevention and Control Team Provide advice and guidance on the Infection Prevention and Control issues concerned with the safe management of healthcare waste within the Trust. Is a member of the Trust Waste Management Group 3.12 Contractors Employed by Trust The person introducing the contractor on site will ensure that before a contractor is employed on site they are aware that they must not use any of our facilities to disposal of their waste. All waste is to be removed from site by the contractor which must be overseen by the relevant Estates Department. 4. LEGISLATION AND STATUTORY RESPONSIBILITIES 4.1. Criminal Liability - The management and disposal of waste is governed by both health & safety and environmental legislation. Both sets of legislation assign strict duties to employers and to individuals who create or handle waste. A breach of the legislation is increasingly likely to result in a criminal prosecution of both the employer and of any identifiable individual who committed the offence Health and Safety Legislation - the employer, through individual managers, is responsible for providing The necessary resources for correct and effective waste management. Written assessments of any significant risk to health or safety associated with waste generation, management and disposal. Safe systems of work for staff generating, handling, storing or transporting waste. Appropriate information and training for all relevant staff. Regular monitoring and periodic review of the system so that deficiencies are corrected within a reasonable timescale and the system continuously refined and improved in the light of experience Individual employees - are required to: Take reasonable care of themselves and others who may be affected by their acts or omissions. Co-operate in matters of health and safety. Correctly use any personal protective equipment and any other work equipment designated for the task. Correctly apply the information and training, previously received. Page 7 of 62

8 Report any perceived hazards in their working environment, or deficiencies in the safe system of work, to their manager. 5. ENVIRONMENTAL PROTECTION ACT 1990 Everyone concerned with waste has a 'Duty of Care' to: Only receive waste if properly authorised to do so, and only from an authorised person. Keep waste securely contained, and prevent its escape or unauthorised removal. Ensure it is adequately contained and packed for safe transport. Label the waste clearly to identify its contents and point of origin. Transfer the waste only to a licensed contractor authorised to transport that type of waste. Describe the waste (on the appropriate forms) in sufficient detail that subsequent carriers and disposers can deal with it safely. Take reasonable steps to check that those providing or removing waste are acting properly and within the law. The employer must also comply with a range of waste management regulations and guidance which govern the correct method of disposal of waste and the keeping of adequate written records regarding the disposal of the waste. 6. DEFINITION OF WASTE Any substance or object the holder discards, intends to discard or is required to discard" is WASTE under the Waste Framework Directive (European Directive (WFD) 2006/12/EC), Classes of Waste 6.1. Controlled Waste General waste comes under the category of Controlled waste in the Controlled Waste Regulations 1992 SI 588 (Controlled Waste regs). Waste from this Trust would be classed as commercial waste under the regulations. This waste stream consists of nonhazardous wastes including paper, some packaging materials, some metals and some food waste. Typically it goes to landfill and in many companies the waste is compacted to reduce the volume and increase the amount that can be contained in a skip. The waste is carried by a licensed waste carrier who will take it to either a transfer station or directly to a land-fill site Hazardous Waste Waste is classed as hazardous if it dangerous to people, the environment or animals. Waste is also classified as hazardous if it is covered under the Hazardous Waste Regulations 2005 SI 894 (Hazardous Waste Regs) and will be listed in the European Waste Catalogue (EWC). Typical examples of hazardous waste include things such as lead acid batteries, fluorescent tubes or clinical waste which has been designated as infectious waste. Non-infectious clinical waste can be disposed of as controlled waste. The hazardous nature of the waste will determine where its Page 8 of 62

9 final destination will be. Some hazardous waste can go to land-fill following treatment. Others may have to be incinerated with the level of incineration being determined by the hazardous properties of the waste Radioactive Waste is covered under the Radioactive Substances Act 1993 and excluded form this policy. 7. WASTE MANAGEMENT Waste is segregated into the classes as specified above. Each category will then be disposed of via identified separate waste streams. The Waste (England and Wales) Regulations 2011 place a specific requirement on all organisations to utilise the waste hierarchy when dealing with waste. The following steps should always be considered in descending order: 7.1. Reduce the amount of waste produced by using less material in design and manufacture. Keeping products for longer or using less hazardous materials Re-use waste items as and when appropriate, by checking, cleaning, repairing, refurbishing, whole items or spare parts. THIS DOES NOT APPLY TO SINGLE USE OR SINGLE PATIENT USE PRODUCTS Recycle, turning waste into a new substance or product. Includes composting if it meets quality protocols Recovery which includes anaerobic digestion, incineration with energy recovery, gasification and pyrolysis which produce energy (fuels, heat and power) and materials from waste Disposal includes landfill and incineration without energy recovery. 8. SEGREGATION AND CONTAINMENT OF WASTE Each waste stream requires a different method of disposal. Therefore it is of paramount importance that each waste stream is segregated from the others at source, and remains separate throughout the process of containment, collection and disposal. Mixing wastes, even in small quantities is not acceptable as this will mean the waste transfer or consignment note will have the wrong information on it and will result in a range of non-compliances with legislation. This section describes each type, and each sub-category of waste and the means by which it is contained and kept separate from the rest Controlled Waste or municipal waste is defined in 6.1. This type of waste is disposed of in black bags and typically goes to landfill. The parts of this waste that cannot be recycled at present are segregated from the dry mixed recycling. Typically this waste is food, dead flowers and anything else which is biodegradable. Page 9 of 62

10 8.2. Dry Mixed Recycling is fractions of municipal waste which can be recycled. This includes paper, cardboard, plastics and metal cans. This waste is all collected in one clear bag which is taken away by the waste contractor and recycled on our behalf. A compactor can be used to compact the waste and maximise the space available in the skip. A paragraph 27 exemption from the Environment Agency needs to be in place to allow a compactor to be used Offensive waste, this describes healthcare and similar municipal waste, apart from clinical and hazardous waste, which may cause offence to people. Examples include nappies, feminine hygiene products, used but uncontaminated PPE (has not been in contact with an infected patient), resin casts and incontinence waste. This type of waste can be put through a compactor which has low level compaction and is disposed of to a licensed land-fill site for deep land-fill. Offensive waste goes into a yellow bag which has black stripes on it (tiger stripe bags). Waste which has been autoclaved is now classed as offensive waste. Blood bags are now classed as offensive waste once any remaining blood has been discharged to drain. There is no need to wash out blood bags. Please note on sites that do not have the offensive waste stream nappies will have to be disposed of in the municipal waste which is a black bag Offensive or Infectious? - When disposing of nappies, feminine hygiene products, used but uncontaminated PPE and incontinence waste a decision has to be made by health care workers whether this waste is offensive or infectious. If it is known that the waste comes from a person who has a known infection which would affect the waste then the waste is clearly infectious. Infectious waste is classed as clinical waste and would be disposed of in an orange bag. Conversely the absence of known infections should ensure that the waste is disposed of as offensive waste and disposed of in a tiger stripe bag. This decision should be considered every time this type of waste is disposed of in case the results of tests indicate that the patient s condition has changed Clinical Waste is defined 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, or 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. Page 10 of 62

11 8.6. Clinical waste is a major component of wastes from many NHS Trusts. Clinical waste bags are coloured orange which denotes that they are to be sent for treatment via alternative technology. Rather than burn the waste it is pasteurised using hot oil and then when the biological hazard has been reduced is sent for land fill Yellow clinical waste bags are for incineration only and will not be used at a hospital or clinic unless specified by Infection Control or the Consultant Microbiologist. Supplies of yellow clinical waste bags are available through the Caretakers (SoTW premises) or Waste Porters (STDH) Clinical waste carts and wheelie bins are all coloured yellow, and clearly labelled and marked with a bio-hazard sign. Standard 'soft' waste is placed in orange clinical waste plastic bags, whilst rigid yellow plastic boxes are used for sharps and for large pieces of human tissue Any substantial pieces of metal which are contaminated with blood or body fluid are also classed as clinical waste. These must be labelled 'for incineration only due to the risk of damage to the shredder at the waste disposal plant where most of the clinical waste is heat-treated prior to landfill. Contaminated metal objects are placed in a suitable rigid plastic clinical waste box, such as the Daniels long bin. If not a regular occurrence or an unusual size or shape, contact the Infection Control Team for advice on suitable containers Human Tissue in any form must only be sent for incineration in red lidded containers (with appropriately labelled body of the box) or incineration only bags. For further information and guidance regarding the management of Human tissue please refer to the appropriate Trust policies and procedures on the Trust intranet Pacemakers pacemaker generators removed from patients are decontaminated in Theatres. The Cardiac Physiologist then completes relevant paperwork and arranges return of the device to the company for disposal Sharps - sharps boxes used within the Trust will have the following colour coded lids:- Orange coloured lids (with appropriately labelled body of the box) are for sharps which do not contain prescription only medicines (POM). This will include sharps that are used for blood or other bodily fluid sampling. Yellow coloured lids (with appropriately labelled body of the box) are for sharps and other equipment used in conjunction with prescription only medicines. Purple coloured lids (with appropriately labelled body of the box) are for cytotoxic or cytostatic drugs and equipment contaminated with Page 11 of 62

12 these drugs. (A list of these drugs is available on the Pharmacy intranet site) Pharmaceutical Waste - within wards and departments is divided into two separate waste streams. Those medicine containers which contain more than a dose should be returned to Pharmacy in the box provided for returns. Medicine containers which contain less than a dose (residue) should be disposed of at ward level into a blue lidded pharmacy box which has a blue labelled body of the box. Fluid bags and giving sets which have contained POMs must also be disposed of in the blue lidded box. Syringes which have not been fully discharged and contain POMs should be put straight into a yellow lidded sharps box without discharging the contents of the syringe. Any establishment which carries out sorting or denaturing of controlled drugs will need to register the site with the Environment Agency for a T28 exemption. The only exception to this is where a Pharmacy is operating within a building which already has an exemption such as a hospital site Controlled Drugs the disposal of these drugs are covered under the Overarching Medicines Policy, under section 10 which can be found on the Trust s Intranet site Amalgam Waste is produced as a result of dentistry and contains heavy metals which require specialist disposal. This waste is taken away by a licensed contractor to recover the heavy metals Chemical Waste is waste which is not infectious and contains chemicals or chemical residue. Examples within a clinical environment include alcohol gel containers and aerosols. Elsewhere chemical waste includes reagent containers, alcohols, xylene, formaldehyde, formalin and waste chemicals. If there are any chemical containers for disposal, establish does the product go down the toilet, sluice or drain. If it does then wash out the container with soap and water and put the container into the municipal waste (black bag). If it does not then it will need to be dealt with differently so contact the appropriate Waste Officer/Manager for advice. The soft alcohol gel bags which are fitted into the wall mounted dispensers should also be cut open and washed out prior to disposal as above. Another type of container which will probably have at least one hazard symbol is an aerosol. A fully discharged aerosol can be placed in municipal waste but do not put accumulations of these containers in the same bag. Page 12 of 62

13 Any aerosols which have contained prescription only medicines should be placed in a blue lidded pharmaceutical box Sealing Waste Containers - All waste bags and boxes must be sealed before disposal. When sealing bags staff should be mindful of the weight of the contents of the bag and to ensure that enough space is left to gather the edges of the bag to seal it. Bags should never be filled more than ¾ full and should be tied with a cable tie. All bags and containers when full and sealed must display the name of the hospital or clinic, ward/department and the date. Boxes must be signed by the person sealing them It is essential that waste carts sited externally to departments are kept locked at all times to prevent the unauthorised removal or accidental loss of any waste bags or boxes Plaster of Paris (gypsum) has to be collected separately and cannot go to landfill. This is because it degrades in landfill sites to produce hydrogen sulphide gas which goes up into the atmosphere and mixes with water and comes back down as acid rain (sulphuric acid). This includes gypsum used for plaster casts medicinally and for the disposal of plaster and plaster board from the Estates Department Glass is classed as controlled waste but for health and safety reasons has to be collected separately from the rest of the controlled waste. On some sites glass is collected for recycling and consigned separately in either cardboard boxes or orange buckets, whichever is available. Where recycling is not available the glass is put into orange buckets and then disposed of with controlled waste at the point of disposal. Glass which has contained pharmaceutical products cannot be recycled and must be disposed of as pharmaceutical waste Batteries are collected at various points around the sites and sent to a suitable recycling facility. There are plastic bins for collecting batteries for recycling Waste Electrical and Electronic Equipment (WEEE) is collected and then sent away for recycling Other Waste any waste that is disposed of must not leave site without the appropriate waste documentation being completed. In addition the waste must only be handed to a registered waste contractor that has been approved by the Trust (Trust owned sites) or SoTW Facilities Department through the SLA for community premises Confidential Waste This is waste containing staff or patient details or potentially sensitive information about the Trust e.g. patient records/information, financial records, non-paper items such as x-rays. Confidential waste is shredded on site by a contractor who is also responsible for the removal of this waste from site to send it for recycling. Page 13 of 62

14 9. WASTE GENERATED IN THE COMMUNITY Waste generated in Community premises is disposed of through an SLA with SoTW who are responsible for the waste removal contract arrangements, registering community sites with the Environment Agency, correct waste handling and consignment by Facilities staff employed by the SoTW. Despite this agreement the waste produced by STFT staff remains our responsibility in terms of correct segregation and handling Healthcare carried out in the community by Trust staff will produce waste and it is essential that this waste is disposed of correctly to ensure that we meet our duty of care. Firstly an assessment should be made to establish whether the waste is offensive or infectious If it is infectious waste produced in patient s home:- Place the waste in an orange bag at the household for collection by a contractor. Note: waste is still the responsibility of the healthcare worker. The Healthcare worker will arrange collection through the Trust s referral system. At present there are separate systems for Gateshead, South Tyneside and Sunderland and each requires a different form for each council. See Appendix 3 for the respective referral system. Ensure suitable storage away from vermin or contact by the public. Ensure the waste company which is collecting the waste is provided with enough information to allow safe handling and disposal, by completing the relevant sections on the waste collection request form. SHARPS USED BY CLINICAL STAFF MUST NEVER BE LEFT IN A PATIENT S HOME Non-infectious waste (Offensive waste) should be disposed of in the domestic waste stream. Do not use orange or yellow NHS colour coded bags as this could cause alarm at landfill sites should staff think it is infectious waste. Use a carrier bag or black bag for disposing of this type of waste in the domestic waste stream Sharps must not be placed in household waste stream. Selfmedicating patients should dispose of sharps through their GP Home Births Placenta must be placed in a red lidded placenta bucket which has appropriately labelled body. Other infectious waste must be placed into an orange bag. The waste is left at patient s home until collected by a licensed waste contractor. Midwives should request a collection using the referral system in Appendix 3. Page 14 of 62

15 10. BIOTRACK This is the tagging system which is utilised by our waste contractor and ensures that the yellow waste carts are dealt with in the most appropriate manner for the class of hazardous waste they contain. The colour coded tags are attached to the yellow waste carts before they are sent from site to ensure that the waste goes to the correct place and receives the correct treatment. See Appendix 7 for further details. 11. COLLECTION OF WASTE FROM OTHER ORGANISATIONS Waste that is collected from other organisations that utilise areas and buildings on Trust owned sites is mixed in with our waste streams and disposed of from our waste disposal facility. In order that this situation does not compromise the Trust s legal position it is essential that the organisations comply with the STFT s waste policy and compliance will be audited by the Trust Waste Officer/Manager. Such organisations are responsible for ensuring their staff are trained and comply with the STFT Waste Policy. 12. WASTE TRANSFER AND WASTE CONSIGNMENT NOTES Waste Transfer Note (Controlled Waste) before any Controlled waste leaves the Trust a waste transfer note must be produced ensuring all the required information is put onto the form. The form must be signed by an authorised Trust signatory and be given to the waste carrier when they come to collect the waste. For regular collections an annual waste transfer note can be set up in advance of the first collection. Waste transfer notes must be retained for two years following the disposal of the waste. No waste must leave the Trust without a waste transfer note or waste consignment note Waste Consignment Note (Hazardous Waste) before any hazardous waste is removed from the Trust a waste consignment note must be completed ensuring all relevant information is put onto the form. This form cannot be completed annually but must be completed for each load. Waste consignment notes must be retained for three years following the disposal of the waste. No waste must leave the Trust without a waste consignment note or waste transfer note Producer Returns is information that waste contractors send to the Trust advising how much waste has been taken from site over a given period (normally quarterly). It is important to maintain a database of these returns for three years from the time the information is received so that waste production levels can be monitored and there is an audit trail of where the waste has been disposed of. Page 15 of 62

16 12.4. Waste Transfer transferring waste between sites within the Trust is not permitted as the Trust does not have a waste transfer license. Waste should only be consigned to a licensed waste contractor from the site it was produced on. The Trust is not registered as a waste transfer station and cannot accept waste brought onto any of the sites. This prohibition includes vans bringing back waste or unused pharmaceuticals from other sites, accepting sharps boxes or pharmaceuticals from the public or staff bringing in waste from home. 13. SELECTION OF WASTE CONTRACTORS All persons who remove waste from any Trust site must comply with the following minimum requirements:- Registered with the Environment Agency as a waste carrier. Use the correct waste transfer or waste consignment notes for the type of waste. Give the Trust producer returns at agreed intervals to enable monitoring of how much waste is being produced and how much is being taken away for disposal. In addition to the minimum requirements above there will be other contractual obligations to be met which are arranged via the Supplies Department or SoTW Facilities Department for Community premises. 14. SITE REGISTRATION The Hazardous Waste Regulations 2005 require that most sites which produce hazardous waste are registered with the Environment Agency on an annual basis by the respective Facilities Department. The exceptions are those sites which produce less than 500kg per year. Each site is given a unique registration number which must be quoted on every waste consignment note. 15. DISCHARGE TO DRAIN Although not always thought of as waste the things that are put down the drains, through toilets, sluices, sinks, etc, are as much waste as what goes into a bin. Some things that are not allowed to be put down the drain are chemicals such alcohols, xylene, etc. The company which takes away the sewage from our Trust also dictates what is allowed to be put into the sewer system. This information is contained within a document referred to as the Consent to Discharge to Drain. If there is any doubt about what can or cannot be put down a toilet, sluice or drain please ask the departmental manager or the Waste Officer/Manager. Page 16 of 62

17 16. RECYCLING AND WASTE MINIMISATION It is essential that the Trust seeks to minimise waste production as a means of reducing costs. Every piece of waste costs the Trust to buy it in its original form and if benefit is not derived from it then financial losses occur. Even when benefit has occurred there are still opportunities for an organisation to gain further income by separating out waste streams and sending waste for recycling rather than final disposal. The Trust already carries out recycling of many waste streams and further improvements are on-going as part of the remit of the Waste Management Group. 17. WASTE MANAGEMENT SITE PLANS The Site Waste Management Plans Regulations 2008 requires the Trust to produce a Site Waste Management Plan (SWMP) before the construction phase begins on any construction project valued at over The purpose of the regulations is to promote the economic use of construction materials and methods so that waste is minimised and any waste that is produced can be reused, recycled or recovered. Additionally the regulations seek to reduce fly tipping by restricting the opportunities available for the illegal disposal of waste. This is the responsibility of the Trust Estates Department (Trust owned sites) and the SoTW Estates Department for schemes that are delivered in Community premises. 18. RISK ASSESSMENT - THE STATUTORY REQUIREMENTS The Management of Health and Safety at Work Regulations 1999 require that all 'significant' risks are assessed and the risks, together with details of the persons at risk, and the control measures required to manage those risks, are recorded in writing, and amended as necessary in response to changes or new information The Control of Substances Hazardous to Health Regulations 2002 requires the same, in relation to chemical risks and infection risks and this includes the risks posed by waste materials. Both also require the training of staff and provision of information in relation to those risks The Use of Generic Risk Assessments should be adopted where ever required but the generic assessments should be reviewed to ensure that any ward/department specific risks are covered by the Risk Assessment. 19. PERSONAL PROTECTIVE EQUIPMENT Clinical staff will follow normal control of infection guidelines during the generation and disposal of clinical waste on the ward or department, which will include protective clothing suitable for the infection risk involved and hand washing. Page 17 of 62

18 20. STAFF TRAINING REQUIREMENTS Ward/Departmental Inductions for New Staff - it is essential that waste disposal procedures are included as early as possible, in the ward or department based induction process for new staff and new staff are given access to this policy Clinical Staff - training sessions in the safe and correct disposal of waste and an introduction to environmental issues are included in the annual Trust training programme. Where more convenient for staff, specific sessions can be arranged for individual wards or departments on request to the respective Waste Officer/Manager Portering/Caretaking Staff these staff have a very important role to play in collecting, transporting, storage and disposal of waste. They will require specific training to enable them to ensure correct segregation of waste during collection, storage at the point of disposal along with ensuring the paperwork is correct when the waste is handed over to the waste contractor. A course specifically designed for waste porters will be delivered for them and refresher training available when required. 21. CHEMICAL STORAGE All chemicals, regardless of the hazards they pose need to be stored and handled in a manner which minimises the risk of spillage. Chemicals should not be stored with other chemicals which they will react with e.g. acids should not be stored with alkalis and oxidising agents should not be stored with flammable chemicals Information on the hazards associated with chemicals can be found on the material safety data sheet which is available free from the manufacturer or supplier. All stored liquids should be stored inside a bund (an outer wall or container designed to retain the contents of an inner tank in the event of leakage or spillage) which is capable of holding 110% of the liquid stored. Spillage procedures should be established for stored chemicals/substances and this should form part of the COSHH assessment. As part of the assessment sufficient absorbing and clean up materials should be available to cope with any spillages. 22. ACCIDENTS AND INCIDENTS General - whilst every effort should be made to avoid loss or spillage of any kind, it is important that a clear procedure and a ready supply of the necessary equipment is in place and is used whenever such an event occurs. Information and training for staff must be provided prior to such an eventuality. Page 18 of 62

19 22.2. Spillage Procedures - The aim of any spillage procedure is to: Contain the spillage to limit the escape. Protect staff, patients and visitors. Protect the environment. Restore the area to normal as quickly as possible. Minimise the effect of the spillage on normal service provision Clinical Waste - The main risk is that of cross infection, and the procedure consists of donning protective clothing consistent with the risk, in most cases disposable gloves and apron if appropriate, and placing the waste items into the appropriate orange bag, or into a sharps box, in the case of needles, blades or other sharp items, taking special care not to receive a sharps injury. Sharps must not be retrieved by hand. Please see Decontamination policy on the Trust Intranet site Spilt blood or body fluids - Please see Decontamination policy on the Trust Intranet site Mercury - a summary of the procedure is included at Appendix 1, and the full procedure, together with a spillage kit, is issued on request by the Pharmacy Other Chemicals - Similar principles apply to any other chemical spillage. The essential steps are: Find out how to deal with the individual chemical first; this information should be on the COSHH assessment or the manufacturers 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 as quickly as possible. Decontaminate the area and return it to normal use Before disposing of spillages or absorbent materials the COSHH assessment should be consulted for the correct method of collection and disposal Suitable contingency procedures 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 If in doubt, contact the Waste Officer/Manager or the respective Facilities Departments. Page 19 of 62

20 Any injury which arises out of waste production, handling or disposal must be reported to the relevant manager or supervisor in the normal way. If there has been a sharps injury from an item contaminated with blood or body fluid the Inoculation Injury Policy which is available on the Intranet site should be followed, in full Any other untoward incident, whether it causes injury or not, should be reported so that its implications can be considered and if appropriate, further preventive measures taken Any injury or untoward incident which arises out of waste production, handling or disposal must be recorded on the Trust accident/incident form in the normal way and submitted via that person's manager or supervisor. If the incident results in death or major injury of any person, or results in more than five consecutive day s absence from work immediately after the incident to a member of staff, it will also require reporting to the Health and Safety Executive. Guidance on RIDDOR is available on the Trust s intranet site The waste porters on the main hospital site also complete Trust accident/incident forms for incidents which they are involved with and these will be discussed at the Waste Management Group along with any others reported throughout the other premises. 23. WASTE MANAGEMENT GROUP This group meets every three months and is made up of Trust staff from; Infection Control and Estates & Facilities, representatives from Northumberland Tyne & Wear Mental Health NHS Foundation Trust and SoTW Facilities Department. The group has its own Terms of Reference and its purpose is to ensure compliance with the Trust Waste Management Policy, oversee changes to the way the Trust manages waste and to look at recycling and other environmental issues The Waste Management Group reports into the Infection Control Committee via the Head of Facilities. 24. WASTE AUDIT ARRANGEMENTS An audit tool (see Appendix 8) based on Safe Management of Healthcare Waste best practice has been established for waste audits to enable a true picture to be established as to how each ward and department is managing waste. These audits will be carried out by the Trust Waste Officer/Manager (for Trust owned sites) and by the Waste Officer/Manager from SoTW Facilities (community premises) inline with the frequencies recommended in the Safe Management of Healthcare Waste and staff will be invited to participate. Page 20 of 62

21 24.1. The waste audits are carried out randomly and without prior notification to establish a true picture of how well waste is being managed Each ward and department will be audited at least once annually but follow up visits could be planned depending on the findings of the original waste audit. Included in the schedule will be waste collection services and record keeping Following the audit visit a report will be compiled outlining the areas of non-compliance and the remedial action required. The report will be sent to the ward/department manager along with the Clinical Business Manager for that area for information and action. Key themes from the audits will be collated by the Waste Manager/Officer for Acute and Community premises respectively for consideration at the Waste Management Group Periodically the carriers of our waste will request an audit of waste to be carried out on site so that we can satisfy them that what we are stipulating on our waste documentation is in fact what we put into our waste bags. This will require liaison with other Trusts who share our sites, and whose waste we collect, to ensure that they can give us assurance about the contents of their waste containers The Environment Agency views health care waste as a high risk because if it is poorly managed it could have serious consequences for the health of people or for the environment. The Environment Agency carries out waste audits within NHS Trusts and can recommend that changes be made to the manner in which waste is managed and if necessary take enforcement action. 25. REVIEW This policy will be reviewed every 2 years unless changes occur within waste management which dictate that it must be reviewed earlier. 26. REFERENCES The following documents where used as sources of information when compiling this policy:- Environmental Protection Act 1990 Controlled Waste Regulations 1992 Hazardous waste Regulation 2005 Waste (England & Wales) Regulation 2011 Consolidate European Waste Catalogue Safe Management of Healthcare Waste V.2 Biotrack Guide by SRCL Page 21 of 62

22 27. EQUALITY & DIVERSITY In accordance with our equality duties an Equality impact Assessment has been carried out on this policy. There is no evidence to suggest that the policy would have an adverse impact in relation to race, disability, gender, age, sexual orientation, religion and belief or infringe individual s human rights. Page 22 of 62

23 Appendix 1 Mercury Spillage Procedure The Waste Officer/Manager in both the SoTW and Acute sectors both have a Mercury spillage kit for dealing with spillages. Contact numbers are as follows:- Ian Thurgood and Gordon Smith ext 2493 If large quantities of mercury are spilled or the area is hot or in a confined space this could increase the amount of airborne mercury and a respirator may be required. Consult the Health & Safety Team for further advice. This, however, would be a very rare and exceptional circumstance. Mercury spillage on a hard surface vinyl, tiles, etc In the event of spillage, try to confine the affected area to a minimum. Put on protective GLOVES and MASK to reduce dust inhalation. Increase ventilation by opening a window. Try to reduce the spread of the spill as much as possible. NEVER USE A VACUUM CLEANER OR ASPIRATOR TO PICK UP MERCURY AND NEVER DISPOSE OF MERCURY IN A SHARPS BIN. Using the SCOOP, move the globules of mercury together to form one large pool. Pick up as much of this as possible using the SYRINGE and place in the WASTE CONTAINER. Return the syringe to the spillage kit. Make a paste of equal amounts of SULPHUR and CALCIUM HYDROXIDE with a little water and spread onto the spillage area. Keep mixing the paste on the spillage area using the BRUSH and SCOOP for two or three minutes it can be used wet and does not need to dry out. Then BRUSH the paste into the SCOOP and transfer it to the WASTE CONTAINER, wiping and residual paste from the BRUSH and SCOOP on the lip of the WASTE CONTAINER, which is then capped tightly. Replace in the spillage kit and store this in a well ventilated place away from sources of heat. Mercury spillage on a fabric surface e.g. carpet or bedding (can also be used on hard surfaces to avoid using paste) Skin contact with mercury should be avoided if bedding is affected, move the patient away if possible. Put on protective GLOVES and increase ventilation. Recover as much of the loose mercury as possible with the syringe and place in the WASTE CONTAINER. Return the syringe to the spillage kit. Break off a piece of ALLOY WOOL to form a sphere of 1 25mm diameter. Holding the ALLOY WOOL between finger and thumb, press it firmly against a hard surface e.g. work surface, to flatten one side. Place this flattened area GENTLY on top of loose mercury and leave it for 20 seconds or so. The mercury will adhere to the ALLOY WOOL and will be picked up. Then move the ALLOY WOOL pad to the next area of mercury droplets. Place the contaminated ALLOY WOOL in the WASTE CONTAINER. Repeat this until all visible mercury droplets have been removed, using more buds of ALLOY WOOL if necessary. Page 23 of 62

24 Decontamination procedure (hard floors only) To a third of a bucket of warm water add a drop of washing up liquid and two heaped teaspoons full each of SULPHUR and CALCIUM HYDROXIDE stirring to make a suspension. Use a mop to apply this to hard floors doing this perhaps every month or two months. After most of the suspension has been mopped off, clean the floor with a proprietary cleaner. WHEN THE WASTE CONTAINER IS FULL DISPOSE OF IT VIA THE WASTE PORTERS AS TOXIC WASTE. Page 24 of 62

25 Appendix 2 Indicative Examples of Infectious Substances Included in Category 'A' in any Form Unless Otherwise Indicated Category A Infectious Substances UN Number & Proper Shipping Name UN 2814 Infectious substances affecting humans Micro-organism Bacillus anthracis (cultures only) Brucella abortus (cultures only) Brucella melitensis (cultures only) Brucella suis (cultures only) Burkholderia mallei - Pseudomonas mallei Glanders (cultures only) Burkholderia pseudomallei Pseudomonas pseudomallei (cultures only) Chlamydia psittaci - avian strains (cultures only) Clostridium botulinum (cultures only) Coccidioides immitis (cultures only) Coxiella burnetii (cultures only) Crimean-Congo hemorrhagic fever virus Dengue virus (cultures only) Eastern equine encephalitis virus (cultures only) Escherichia coli, verotoxigenic (cultures only) Ebola virus Flexal virus Francisella tularensis (cultures only) Guanarito virus Hantaan virus Hantaviruses causing hemorrhagic fever with renal syndrome Hendra virus Hepatitis B virus (cultures only) Herpes B virus (cultures only) Human immunodeficiency virus (cultures only) Highly pathogenic avian influenza virus (cultures only) Japanese Encephalitis virus (cultures only) Junin virus Kyasanur Forest disease virus Lassa virus Machupo virus Marburg virus Monkeypox virus Mycobacterium tuberculosis (cultures only) Nipah virus Omsk hemorrhagic fever virus Page 25 of 62

26 Poliovirus (cultures only) Rabies virus (cultures only) Rickettsia prowazekii (cultures only) Rickettsia rickettsii (cultures only) Rift Valley fever virus (cultures only) Russian spring-summer encephalitis virus (cultures only) Sabia virus Shigella dysenteriae type 1 (cultures only) Tick-borne encephalitis virus (cultures only) Variola virus Venezuelan equine encephalitis virus West Nile virus (cultures only) Yellow fever virus (cultures only) Yersinia pestis (cultures only) UN 2900 Infectious substances affecting animals only African swine fever virus (cultures only) Avian paramyxovirus Type 1 - Velogenic Newcastle disease virus (cultures only) Classical swine fever virus (cultures only) Foot and mouth disease virus (cultures only) Lumpy skin disease virus (cultures only) Mycoplasma mycoides - Contagious bovine pleuropneumonia (cultures only) Peste des petits ruminants virus (culture only) Rinderpest virus (cultures only) Sheep-pox virus (cultures only) Goatpox virus (cultures only) Swine vesicular disease virus (cultures only) Vesicular stomatitis virus (cultures only) Page 26 of 62

27 Appendix 3 Procedure for assessment and disposal of healthcare waste generated in patients homes by community healthcare staff. (Gateshead Area). INFORMATION Community healthcare workers responsibilities Producers of healthcare waste and specifically infectious waste are required to comply with waste regulations including the Hazardous Waste Regulations and therefore need to ensure that waste is segregated, described, classified and disposed of appropriately. Waste risk assessment - Infectious waste Waste is classified as infectious waste where: it arises from a patient known or suspected to have an infection, whether or not the causal agent is known, and where the waste may contain the pathogen; or where an infection is not known or suspected, but a potential risk of infection is considered to exist. Table: Risk assessment approach to waste segregation based on likelihood of infection being present Contaminant Proposed general Urine, faeces, vomit sputum and Blood, pus and wound exudates classification Offensive (where risk assessment had indicated that no infection is present, and no other risk of infection exist) Infectious unless assessment indicates no infection present. If no infection, and no other risk of infection, offensive then Examples Urine bags, incontinence pads, single-use bowls, nappies, PPE Dressings from wounds, Wound drains, delivery packs Exception to this rule Gastrointestinal and other infections that are readily transmissible in the community setting (e.g. verocytotoxinproducing Escherichia coli (VTEC), campylobacter, salmonella, chickenpox/shingles)¹ Hepatitis B and C, HIV only if blood is present¹ Blood transfusion items Dressings contaminated with blood/wound exudates assessed not to be infectious. Maternity sanitary waste where screening or knowledge has confirmed that no infection is present and no other risk of infection exists Page 27 of 62

28 Notes: All Infectious waste A and B species, and therefore downstream waste items, will be deemed infectious/hazardous under waste regulations irrespective of the contaminant matrix. 1. Potential hazards from the use of cytotoxic and cytostatic medicines may also be relevant in some instances and with some drugs. This would also prevent the waste being considered offensive 2. Pleurex and Rocket drains need to be classed as infected clinical waste for disposal. Wound assessment The following criteria are based on the Delphi process of identifying wound infection in six different wound types (European Wound Management Association, 2005). Signs and symptoms of infection Is there presence of erythema/cellulitis? Is there presence of pus/abscess? Is the wound not healing as it should, or has healing been delayed? Is the wound inflamed and has it changed appearance? Is the wound producing a pungent smell? Is the wound producing an increased purulent exudate? Has the wound increased in pain? Has there been an increase in skin temperature? Is the patient on antibiotics for an infection present in the wound? Is the wound to be swabbed for infection? Probability of wound being infected High High Medium Medium High Medium High Medium/Low High Medium Note: It should be recognised that this is not an exhaustive list of signs and symptoms of wound infection and that different types of wound will present differently. This tool is to assist in the basic assessment of all wounds in order to correctly categorise whether the waste produced contains an infectious fraction and therefore infectious waste. Further information and advice regarding assessment of wound infections should be sought from the local tissue viability specialist nurse. PROCEDURE 1. The health worker needs to use their professional judgement and knowledge of the patient, in conjunction with the above tables of information (from the Department of Health Waste Manual) to assess whether contaminated healthcare waste is infectious or offensive. 2. If the waste is deemed to be Infectious, the waste should be bagged into an Orange Clinical waste bag, the bag should be sealed. 3. A suitable storage area needs to be confirmed with the householder. Page 28 of 62

29 4. Please contact Gateshead Council on to request a new clinical waste collection. Details of the waste to be collected, patient s name, address and contact telephone number, frequency of collection and the health workers contact details should be provided to the call centre. 5. The Councils clinical waste contractor will be contacted to arrange a collection and the patient notified of the collection arrangements 6. For any queries or to discuss individual cases, please contact John Fenwick on , or via johnafenwick@gateshead.gov.uk. 7. If the waste is deemed to be offensive, it needs to be wrapped or bagged and placed into the householder s domestic waste bin. Do not use tiger stripe or orange clinical waste bags in the domestic waste. Page 29 of 62

30 Procedure for assessment and disposal of healthcare waste generated in patients homes by community healthcare staff (South Tyneside and Sunderland Areas) INFORMATION Community healthcare workers responsibilities Producers of healthcare waste and specifically infectious waste are required to comply with waste regulations including the Hazardous Waste Regulations and therefore need to ensure that waste is segregated, described, classified and disposed of appropriately. Waste risk assessment - Infectious waste Waste is classified as infectious waste where: it arises from a patient known or suspected to have an infection, whether or not the causal agent is known, and where the waste may contain the pathogen; or where an infection is not known or suspected, but a potential risk of infection is considered to exist. Table: Risk assessment approach to waste segregation based on likelihood of infection being present Contaminant Proposed general Urine, faeces, vomit and sputum Blood, pus and wound exudates classification Offensive (where risk assessment had indicated that no infection is present, and no other risk of infection exist) Infectious unless assessment indicates no infection present. If no infection, and no other risk of infection, then offensive Examples Urine bags, incontinence pads, single-use bowls, nappies, PPE Dressings from wounds, Wound drains, delivery packs Exception to this rule Gastrointestinal and other infections that are readily transmissible in the community setting (e.g. verocytotoxinproducing Escherichia coli (VTEC), campylobacter, salmonella, chickenpox/shingles)¹ Hepatitis B and C, HIV only if blood is present¹ Blood transfusion items Dressings contaminated with blood/wound exudates assessed not to be infectious. Maternity sanitary waste where screening or knowledge has confirmed that no infection is present and no other risk of infection exists Page 30 of 62

31 Notes: All Infectious waste A and B species, and therefore downstream waste items, will be deemed infectious/hazardous under waste regulations irrespective of the contaminant matrix. 1. Potential hazards from the use of cytotoxic and cytostatic medicines may also be relevant in some instances and with some drugs. This would also prevent the waste being considered offensive 2. Pleurex and Rocket drains need to be classed as infected clinical waste for disposal. Wound assessment The following criteria are based on the Delphi process of identifying wound infection in six different wound types (European Wound Management Association, 2005). Signs and symptoms of infection Is there presence of erythema/cellulitis? Is there presence of pus/abscess? Is the wound not healing as it should, or has healing been delayed? Is the wound inflamed and has it changed appearance? Is the wound producing a pungent smell? Is the wound producing an increased purulent exudate? Has the wound increased in pain? Has there been an increase in skin temperature? Is the patient on antibiotics for an infection present in the wound? Is the wound to be swabbed for infection? Probability of wound being infected High High Medium Medium High Medium High Medium/Low High Medium Note: It should be recognised that this is not an exhaustive list of signs and symptoms of wound infection and that different types of wound will present differently. This tool is to assist in the basic assessment of all wounds in order to correctly categorise whether the waste produced contains an infectious fraction and therefore infectious waste. Further information and advice regarding assessment of wound infections should be sought from the local tissue viability specialist nurse. PROCEDURE The health worker needs to use their professional judgement and knowledge of the patient, in conjunction with the above tables of information (from the Department of Health Waste Manual) to assess whether contaminated healthcare waste is infectious or offensive. 1 If the waste is deemed to be Infectious, the waste should be bagged into an Orange Clinical waste bag, the bag should be sealed. 2 A suitable storage area needs to be confirmed with the householder. Page 31 of 62

32 3 A referral form needs to be sent to SRCL (clinical waste contractor) by fax, with relevant details of the waste to be collected. A start/end date and frequency of collection should be included. A copy to be kept for the purpose of keeping records. TO RECEIVE THE APPROPRIATE FAX NUMBER, CONTACT SRCL VIA TELEPHONE: Number The patient should be notified of the collection arrangements. 5 If the waste is deemed to be offensive, it needs to be wrapped or bagged and placed into the householder s domestic waste bin. Do not use tiger stripe or orange clinical waste bags in the domestic waste. Page 32 of 62

33 Community Health Services SRCL Household Clinical Waste Collection Request Form For collection of Infectious Clinical Waste from patients homes by SRCL please ring the following number and SRCL will issue you with the correct fax number: Patient/Collection Details Name: Address: Telephone Number: Post Code: Can SRCL contact the patient on this number to confirm collection detail Yes No Healthcare Professionals Contact Details Name Contact Tel Description of Clinical Waste (i.e. Bagged Dressings from MRSA infected wound) Frequency of Collection Required (please where appropriate) Weekly Fortnightly One Off (end of treatment) Duration of Collection (please where appropriate, collections in excess of 4 weeks need to be re-referred for a further collection). One Week Two Weeks Three Weeks Maximum Four Weeks Comment / Additional Information (please use this space to add any further information you feel may be useful) Page 33 of 62

34 Colour coding key to segregation system Appendix 4 Colour Yellow Orange Purple Yellow/black Description Waste which requires disposal by incineration Indicative treatment/disposal required is incineration in a suitably permitted or licensed facility. Waste which may be treated Indicative treatment/disposal required is to be rendered safe in a suitably permitted or licensed facility, usually alternative treatment plants (ATPs). However this waste may also be disposed of by incineration. Cytotoxic and cytostatic waste Indicative treatment/disposal required is incineration in a suitably permitted or licensed facility. Offensive/hygiene waste* Indicative treatment/disposal required is landfill or municipal incineration/energy from waste at a suitably permitted or licensed facility. Anatomical waste for incineration 1 Indicative treatment/disposal required is incineration in a suitably permitted facility. Red Black Domestic (municipal) waste Minimum treatment/disposal required is landfill, municipal incineration/energy from waste or other municipal waste treatment process at a suitably permitted or licensed facility. Recyclable components should be removed through segregation. Clear/opaque receptacles may also be used for domestic waste. Medicinal waste for incineration 1 Indicative treatment/disposal required is incineration in a suitably permitted facility. Blue Amalgam waste For recovery White *The use of yellow/black for offensive/hygiene waste was chosen as these colours have historically been universally used for the sanitary/offensive/hygiene waste stream. 1 The colours red and blue are new to the colour-coding system in this edition. Care should be taken when ordering red containers to ensure that they can be clearly differentiated from orange. The colour-coding could be agreed as part of a contract specification. Page 34 of 62

35 Appendix 5 BIOTRACK TAGGING GUIDE Tag each waste bin with the correct tag before the next waste collection HT Infectious Clinical Waste Bags HA Infectious Anatomical Waste HN Infectious HS Infectious Sharps HN Infectious Blood Contaminated Sharps HY Cytotoxic Medicines for Incineration HP Non- Hazardous Medicines HI Highly Infectious Clinical Waste for Incineration HL Non Infectious Clinical Waste Page 35 of 62