WASTE MANAGEMENT POLICY

WASTE MANAGEMENT POLICY Trust ref number: A15/2002 Approved By: Trust Board Date of Approval: 25 July 2002 Date of next review: May 2006 (as confirmed in December 2005) NB: this was consequently amended to Autumn 2006 in light of awaited national guidance extension to review approved by & Guideline Committee on 8 May 2006 1

Trust Health and Safety Policies Introduction This policy has been devised following collabotation with University Hospitals of Leicester NHS Trust (UHL) and Leicestershire & Rutland Healthcare NHS Trust and is intended to be adopted as a Leicestershire-wide Waste Management. The Trust is responsible for the safe handling, transportation and disposal of all clinical and non-clinical waste generated on site in accordance with current legislation. This policy covers all staff employed by the Trust in the course of their duties and will include agency and contractual staff working within or on behalf of the Trust. Where members of staff treat patients at home the quantity of clinical waste produced is generally quite small. However, staff still have a duty to ensure that where clinical waste is generated, it is disposed of safely and in the correct manner. It is important to realise that all waste must be segregated from the point of collection and disposed of by the correct process. Segregation must be monitored through storage and handling to each of the many final disposal routes. Waste must be held in secure locations to prevent unauthorised access, ensure public safety and to prevent access by animals, rodents or insects. All clinical and domestic/household waste must be identifiable and traceable to its source. Therefore all waste must be tied using a swan-neck method and labelled with the appropriate coloured or numbered tie, to enable an audit trail to be followed. Statement The University Hospitals of Leicester NHS Trust is committed to ensuring the health, safety and welfare of all its staff, patients, visitors and others who may be affected by the waste materials which result from our work. It is the policy of the Trust that management will do all that is possible in the field of waste management to ensure the disposal of all waste products regularly, safely and in accordance with statutory requirements, and in particular the Environment Protection Act 1990 and associated legislation. 2

Where appropriate, training in the correct procedures for handling and disposal of waste will be provided, together with the necessary equipment, information and protective clothing in line with the Controls Assurance Standard. The waste disposal arrangements will be reviewed regularly and where appropriate re-cycling initiatives will be undertaken in order to help protect the environment and make better use of resources. Organisational Responsibilities UHL will appoint a Waste Control Officer, appointed by the Chief Executive, for ensuring that the handling and disposal of waste is in accordance with current best practice. The Waste Control Officer will assume the following responsibilities: To keep under review and to propose improvements to the waste handling and disposal procedures of the Trust. To investigate or review incidents reported during the handling of waste. To monitor methods of handling, transporting on and off site and disposing of waste. To require, where appropriate, improvements to observed practices to bring them into line with approved requirements. To identify training requirements by staff grade and discipline, e.g., Infection Control Clinical Waste Issues Pharmacy Drug/Medication Issues Facilities Collection/Transportation and Disposal off site To liaise with the Training Officer/Manager and participate in staff induction and post employment training in the handling and disposal of waste. To liaise with Supplies Manager to ensure that an appropriate and acceptable range of clinical and other waste containers, protective clothing and collection disposal vehicles are available as appropriate. To liaise with the Facilities Manager in ensuring that 3

storage and disposal facilities for clinical and other waste are appropriate and maintained in a satisfactory condition. To liaise with the Chief Pharmacist in the appropriate disposal of used pharmaceutical products and to undertake periodic DUMP (Disposal of Unwanted Medicines and Poisons) programmes with the Local Authority. To liaise with the Radiation Protection Adviser (RPA), as clinical waste may also present specific radioactive waste risks when it occurs in a clinical area. To represent Board Managers in liaison with the Waste Regulation Authority, the local authority and other bodies having responsibilities under Environmental and Waste Regulations. To liaise with the Occupational Health Services when conducting surveys to determine, from an occupational health point of view, any shortcomings in the handling of clinical waste. To ensure that the waste disposal contract is firmly controlled and carefully monitored he/she is to implement an audit trail from source to final disposal to ensure the Trust s legal obligations are met. The waste disposal audit should be performed at least twice in the financial year, with a documented report forwarded to the Chairman of the Health and Safety Committee within 3 weeks of the audit. To liaise with the Director of Nursing and the heads of clinical directorates and departments to ensure compliance with approved procedures for the handling and disposal of waste. To liaise with the Infection Control Team and to be coopted onto the Infection Control Committee as required to discuss clinical waste issues. To ensure that responsibilities are appropriately ascribed and job descriptions are reviewed/altered as appropriate. 4

Clinical Directors/Non-Clinical Directors Shall : Be responsible for the implementation of the policy within their directorate. Identify and seek provision of resources to enable the directorate to comply with the policy and existing legislation. Ensure that all their Departmental Managers/Ward Managers are aware of their waste management responsibilities. Liaise and co-operate with the Waste Control Officer and act on any recommendations. Ensure that appropriate arrangements are made to coordinate procedures, training and information across the directorate. Ensure that all contractors engaged by their department(s) comply with this policy. Directorate General Managers Shall: Be responsible for the implementation and monitoring of the policy within the specific area of responsibility. Ensure that risk assessments in relation to waste are carried out, recorded and reviewed regularly. Ensure that waste management procedures and safe working practices resulting from them are produced, documented and implemented for their area. Ensure that arrangements with regard to waste are included in induction and regular refresher training for all staff. Monitor the investigation and reporting of all incidents and dangerous occurrences in relation to waste in their area. 5

Ensure that all staff are properly trained and are competent to undertake their duties. Ensure that safe working practices are followed and that all safety precautions are taken within the department. Maintain and update departmental procedures and records. Undertake regular monitoring and record their findings. Infection Control Team (ICT) With regard to clinical waste the ICT will support the Waste Control Officer(s) on issues associated with clinical waste; provide education for effective clinical waste management and assist in the investigation of any associated adverse incidents. They will assist and participate in the monitoring of the Controls Assurance Standard. Employees General Responsibilities Although primary responsibility for the management and safe disposal of waste rests with management, each employee or agent of the Trust has an individual responsibility to: Segregate and dispose of waste products in the receptacles specifically provided for that purpose, taking note of any segregation, and/or security requirements. Take reasonable care for their own health and safety and others who may be affected by their acts or omissions. Co-operate with the Trust management in the implementation of this policy. Ensure their compliance where a requirement for the wearing of Personal Protective Equipment has been established for the handling of waste. Report any problems that arise regarding waste disposal to their supervisor/manager. To undergo regular training as identified through the Risk Assessment process and by their Line Managers. 6

Contractors Other employers or individuals providing goods and/or services to the Trust shall be required to comply with Trust policies and procedures with regard to the management and disposal of waste. Specific requirements for Contractors will be detailed in the University Hospitals of Leicester NHS Trust s Safety for Contractors SECURING WASTE All waste bags are to be tied using the swan-neck method using an appropriately coloured plastic tie. Ties must be marked so as to identify the origin of the waste bag. WASTE CATEGORIES Definition of Clinical Waste This definition of clinical waste is taken from the Controlled Waste Regulations 1992. 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 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. Categorisation of Clinical Waste 7

Group A Includes the following items: identifiable human tissue, * blood, animal carcasses and tissue from veterinary centres, hospitals and laboratories. Soiled surgical dressings, swabs and other similar soiled waste. Other waste materials, for example from infectious disease cases, excluding any in Groups B-E. Group B Discarded syringe needles, cartridges, broken glass and any other contaminated disposable sharp instruments or items. Group C Microbiological cultures and potentially infected waste from pathology departments and other clinical or research laboratories. Group D Drugs or other pharmaceutical products. Group E Items used to dispose of urine, faeces and other bodily secretions or excretions which do not fall within Group A. This includes used disposable bed pans or bed pan liners, nappies, incontinence pads, stoma bags and urine containers. # In community settings this can also include non infectious body waste. Definition of Domestic Waste For the purposes of this policy domestic waste is that waste that is uncontaminated and usually includes: general ward waste other than that categorised above as clinical waste, e.g., newspapers, magazines, dead flowers, boxes, paper towels, handkerchiefs, packaging, etc. waste from office areas, public toilets and corridors * All identifiable human tissue, whether infected or not, may only be disposed of by incineration. # Where the risk assessment shows there is no infection risk, Group E wastes are not clinical waste as defined. 8

kitchen waste from the main or ward kitchens non combustibles, e.g., crockery, empty/broken glass, tins, cans and aerosols large non-combustibles, e.g., beds, lockers, chairs, tables etc. Uncontaminated items such as crockery, glass, tins and aerosols should be placed into brown multi-ply bags, which incorporate a polythene type lining to contain wet waste and prevent leakage. It is important that staff empty and rinse all bottles and other containers of any fluid prior to disposal. When the bag is approximately ½ full, expel any trapped air and secure the neck of the bag against leakage and label to indicate origin. Aerosol cans must not under any circumstances be placed in clinical waste bags for incineration. In addition aerosols should not be punctured prior to disposal. Disposal of large non-combustible items must be carried out in accordance with local procedures, as those items on asset registers can only be condemned by authorised personnel. Cardboard boxes must be flat packed whenever possible, but staff must refrain from jumping on boxes as ankle/foot injuries may occur. Similarly open bladed knives (Stanley Knives) should not be used due to the potential for lacerations or deep cuts. Household /domestic waste must not be allowed to accumulate in non-designated areas, i.e., corridors, stairwells, due to the fire risk and potential for arson. Printer cartridges should preferably be recycled under local site arrangements. Departments provided with black bags should ensure that they do not become overfull. Once the bag becomes ¾ full or requires changing, it should be sealed against leakage and labelled to indicate origin. Kitchen/Food wastes that include food residues empty containers and out of date stock are not only a potential hazard in themselves but often encourage insects and vermin. Food waste should be returned to the Catering Department for disposal into sink waste disposal units. These should be cleaned regularly by flushing with hot water and a mild detergent to prevent offensive odours, or as instructed by the 9

manufacturer. Other catering waste such as tin cans, cooking oil should be finally disposed of in accordance with local procedures. Definition of Special Waste Special waste is that waste which has been designated by the Special Waste Regulations 1996 and in practical terms will primarily consist of the following: Cytotoxic Waste Pharmaceutical Waste Asbestos Mercury Compounds Laboratory Chemicals Radioactive Waste with measurable quantities of radiopharmaceuticals associated with it Prior to the arranged collection a 5 part Consignment Note must be prepared by the nominated person in the producer department. Local arrangements will decide on how waste is collected/delivered, but the waste must be accompanied by the duly signed consignment note. In due course, a copy of the consignment note will be returned to the producer department by the waste contractor as proof of disposal at the incineration point. All special waste must be kept separate from all other waste. See local procedures for the handling, collection, storage, transport and final disposal arrangements. However, the following generic precautions must be complied with. Radioactive Waste Radioactive waste may also present clinical waste risks where it occurs in a clinical area. Due to the special hazards associated with radioactive waste, this material must only be disposed of in a controlled manner via a carrier to an authorised incinerator. No handling, storage or disposal of Radioactive waste should be carried out without authorisation of the Trust s Radiation Protection Adviser or nominated representative. Radioactive waste intended for incineration must either be placed in proprietary labelled radioactive waste bags or sharps containers, labelled with the date, origin and clearly marked with tape or adhesive stickers denoting the 10

Radioactive Trefoil sign. All items must be uniquely identifiable. Patients who have undergone diagnostic tests involving radiation should have this indicated by attaching instructions to their patient records. Waste arising from this therapy is dealt with by Medical Physics. If a spillage occurs or a bag is split, the site of the spillage should be safeguarded, e.g., by sealing the area off. The Trust s Radiation Protection Adviser should be contacted. Patient clinical waste should be treated according to local Ionising Radiation Rules. Cytotoxic Waste All Cytotoxic waste, other than sharp s should be placed in yellow clinical waste bags and labelled with Cytotoxic Waste stickers/labels; sealed against leakage and labelled to indicate origin. All sharp s Cytotoxic waste must be placed in specifically designated sharp s containers labelled as Cytotoxic waste and kept separate from other waste. Arrangements for collection/delivery of Cytotoxic waste will be dictated by local procedures. Pharmaceutical Waste All pharmaceutical waste not required or surplus at ward/clinical level must be returned to the appropriate Pharmacy Department, who will make the necessary arrangements for disposal as Special Waste. N.B. The following waste is not categorised as pharmaceutical waste, and is to be disposed of via the general waste system, either in yellow bags or sharps containers as appropriate: Infusion sets Empty containers (tablet/medicine bottles etc.) Part used IV bags and bottles Any blood/body fluid contaminated item. Mercury Waste Because of the potential for damage to health, the spillage of mercury is regarded as a serious matter. 11

Should any spillage occur, e.g., broken sphygmomanometers, the area should be immediately segregated to prevent dispersal of the droplets and the local site Spillage followed. Segregation and Packaging of Waste Proper segregation of different types of waste is critical to safe management and helps control disposal costs. Waste needs to be sorted at the point of origin so it can follow appropriate routes for treatment and/or disposal. It is essential that the procedures used for segregating waste are monitored and evaluated on a regular basis, and that staff receive feedback on how the arrangements are working. Requirements for packaging vary depending on the category of waste and the method of final disposal. Most infectious waste (other than Sharp s) is disposed of in yellow clinical waste bags that meet the NHS Performance Specification. The following list indicates the requirements to follow for segregation and disposal routes. Clinical Waste General (Group A) Clinical Waste - Human Tissue/Organs/Limbs (Group A) Clinical Waste - Placentas (Group A) Clinical Waste - Sharp s (Group B) Clinical Waste Microbiology /Pathology Waste for autoclaving (Group C) Clinical Waste (Group E) Yellow Plastic Bags Medium duty Double Yellow Plastic Bags (Inner bag Medium Duty, Outer bag Heavy Duty) Placenta Bins / Large rigid containers e.g. Griff bins Sharps Containers (to BS 7320/UN 3291) Autoclaved Blue and Transparent Bags then Yellow Plastic Bag Contents via sewer/sluice Containers/Similar items via Yellow Plastic Bags Special Waste: Pharmaceutical Waste 12

(Group D) - Glass bottles etc., containing any quantity of surplus drugs/pharmaceuticals (too large for Sharps Container) Radioactive Waste CytotoxicWaste ) ) Return to Pharmacy under ) local site arrangements ) ) ) Local Site Arrangements ) Contaminated Broken Glass, Small Vials, Small Ampoules containing or having contained any drugs or pharmaceuticals Glass bottles contaminated with body fluids (i.e., patient s own samples) Uncontaminated Glass and Aerosols Domestic Waste Cardboard Boxes Confidential Waste Mercury and Waste Chemicals Kitchen Waste Compactable Waste Non-Compactable Waste Sharps Containers Brown 2 ply Sack then Yellow Plastic Bag Brown 2 ply Sack Black Plastic Bags Flat-packed Local Site Arrangements Local Site Arrangements Local Site Arrangements Local Site Arrangements Local Site Arrangements Inert Waste, i.e., Local Site Arrangements Builders Rubble Scrap Metal Local Site Arrangements Batteries (Heavy Duty) Oils/Paints/Lubricants Fluorescent Tubes Local Site Arrangements Local Site Arrangements Local Site Arrangements 13

Tissue/Organ/Limb Waste Particular care must be exercised in the disposal of this waste, due to its sensitive nature, and it should be segregated from other clinical waste. All tissue waste should be double bagged (medium inner, heavy duty outer) in yellow clinical waste bags, which should be sealed against leakage and labelled to indicate origin prior to final disposal. Alternatively Large rigid containers e.g. Griff bins can be used. Used Blood Bags Used blood bags must be stored on the ward/department for the designated time of 72 hours. The bag must be placed into a yellow clinical bag with the date and patient s name legible on the outside of the bag. The bag can be loosely knotted and stored in the appropriate place in the sluice room until final disposal. Used blood bags must be placed into yellow clinical waste bags, sealed against leakage and labelled to indicate origin. After 72 hours has elapsed bags still containing blood should be placed in heavy duty yellow clinical bags to avoid spillage. Leech/Maggot Waste Dispose of as clinical waste, double bagged and swan-necked and tagged with the appropriate colour tie. Placentae Due to the nature and consistency of placentaes they are more easily disposed of in special to type containers, with final disposal via the normal clinical waste stream and in accordance with local procedures. It is important that containers are not overfilled due to manual handling issues. Where patients are treated at home, the Trust still has a duty to ensure that any clinical waste generated is disposed of safely. Staff such as Community Midwives must ensure that they have available the appropriate containers for the disposal of clinical waste, e.g., placenta containers/sharps Containers. 14

For those occasions where mothers elect to keep their placentaes for social/religious reasons, the placenta should not be packaged /transported home in clinical waste bags. This is to prevent the clinical waste bag entering the Local Authority waste stream and finish up at a landfill site. Mothers and their partners must be informed that human tissue (e.g., placentas) must not be discarded to landfill sites. An approval form must be completed prior to removal from site. Sharps The safe disposal of sharps is imperative to reduce the risk of inadvertent injury to staff, patients and others. Sharps containers, which must comply to UN 3291 and BS 7320 are to be used for syringes, needles, scalpel blades, stitch cutters, glass vials, ampoules and contaminated broken glass, pipettes and other similar waste. The disposal of a sharp is the personal responsibility of the user, and must not be handed to, or left for someone else to dispose of. Used needles must not be resheathed by hand, bent or broken prior to disposal. Once sharps have been placed in the container, no attempt should be made to retrieve them. Sharps containers must be correctly assembled according to the manufacturer's instructions and the appropriate signature block annotated, denoting the originating department and assembler. Containers must not be overfilled, and once ¾ full, should be stored in a secure area to await final disposal. Containers must not be stored next to any heat source, in direct sunlight or where the public has direct access. Sharps containers should be stored out of reach of patients, especially children. Sharps containers must not be placed into yellow clinical waste bags, but must be placed directly into the yellow wheeled bins. Storage and Security Clinical and other wastes may need to be stored before incineration or transport for disposal. Waste should not be allowed to accumulate under any circumstances, in corridors, wards or other places accessible to members of the public. 15

Within wards and departments, clinical and special waste waiting for final disposal must be kept in a separate area of adequate size, and which provides an impervious floor capable of being washed. These areas should only be accessible to those members of staff required to handle, transport and dispose of the waste, and should be secure from other persons, especially the general public. Extra special care must be taken to prevent public access to Sharps containers (full or partially full) and the possible theft of used hypodermic syringes and needles. The storage of non-clinical waste (cardboard, broken furniture, etc.) should not constitute a hazard within the department prior to final disposal, e.g., blocking fire exits or stored on corridors. - continued - Handling Precautions All staff, including contractors, who are required to handle bagged clinical waste etc., must be trained to: Exchange bags when approximately 2 / 3 full. Check that clinical waste bags are sealed against leakage and labelled with the appropriate coloured or numbered tie/label. Handle bags by the neck only, and as far as possible ensure that bags are kept away from the body and legs when carrying. Be familiar with the spillage procedures. Transport Dedicated trucks, trolleys or wheeled containers are needed to transport waste containers to storage areas. In order to prevent contamination they should not be used for any other purpose. They need to be designed and constructed so that they: are easy to clean and drain; 16

contain any leakage from damaged receptacles or containers; are easy to load and unload; do not offer harborage for insects or vermin; and do not allow particles of waste to become trapped on edges or crevices. Containers for on-site transport need to be cleaned and disinfected following leakages or spills, and at regular intervals. If containers are heavily used, cleaning is likely to be required at least weekly. The clinical waste procedures need to specify the method and frequency of cleaning and disinfection. Transport off-site to authorised incineration plants is currently undertaken by a properly registered contractor. - continued - Spillages All spillages of waste, clinical or otherwise should be reported to the appropriate line manager and dealt with immediately. If a clinical waste bag is damaged in the ward/department area, it will be that ward/department s responsibility to re-bag the contents in a new clinical waste bag, and clean up any resultant fluid spillage as identified below. If a clinical waste spillage occurs during transportation, then it should be the responsibility of the person transporting the waste to re-bag the contents and clean up any resultant fluid spillage as below. Minor spillages of blood should be wiped up using a paper towel soaked with sodium hypochlorite 1% (10,000ppm) solution. Disposable gloves and aprons must be worn, and discard the gloves and towels into a yellow plastic bag for incineration. Since hypochlorite solutions can be corrosive, the treated surface(s) should be rinsed with clean water and dried. At the present time, the risk of blood borne virus transmission through other body fluids is low. Following spillages of urine, faeces, vomit or sputum, all traces should be removed with a paper towel. 17

The area should then be cleaned with detergent and water, then wiped with a sodium hypochlorite 0.1% (1,000ppm) solution, then rinsed and dried. Full details of the procedure to be followed following a spillage of blood, other body fluids and known contaminated material can be obtained from Chapter 3 of the Control of Infection Guide. Complete an incident report form. - continued - Protective Clothing All members of staff involved in the removal of clinical and other waste from ward and departments should wear the appropriate protective clothing. In the main this should consist of: Protective Gloves Overalls Safety Shoes In special circumstances such as spillage, additional clothing may be required and advice should be sought either from Infection Control, Health and Safety or the Occupational Health Department(s). Immunisation All staff handling clinical waste should be offered appropriate immunisation, including Hepatitis B and Tetanus. Any queries or advice can be obtained through the Occupational Health Departments. Accidents and Incident Reporting The Trust s policy on accident and incident reporting should be followed in relation to any incident involving waste. All waste related incidents, will be referred by the Health and Safety Adviser to the Waste Control Officer, who will ensure that the incident is investigated and corrective actions taken to prevent recurrence of similar incidents. 18

- continued - Risk Assessment Training and Information All wards/departments/clinics whose staff are involved in the handling of waste are to ensure that the appropriate Risk Assessments are carried out, documented and formally reviewed. The Risk Assessment should take into consideration the following issues and where appropriate, line managers should ensure that staff receive information/training on the following: The risks to their health and safety Any precautions necessary The results of any monitoring The collective results of any relevant health surveillance. Training needs will obviously vary greatly depending on the task and on the individual, but staff must receive the appropriate training, information and instruction on: The segregation, handling, storage and collection risks associated with clinical and other wastes Personal hygiene Any local procedures which apply to their task/workplace Procedures for spillages and accidents Emergency procedures The appropriate use of protective clothing. For those members of staff who collect, transfer, transport or handle clinical and other waste, the training must cover the following issues: Checking that storage containers are locked effectively before handling Ensuring that the origin of the waste is identified Handling bags correctly (for example, not clasped to the body, thrown, dropped or supported by hand from below) Using handles to move rigid containers Checking that the seal on any used waste storage container is unbroken when movement is complete Sharps awareness Procedures in case of accidental spillage and how to report an incident Safe and appropriate cleaning and disinfection procedures. 19

- continued - Clinical and other waste is produced in most wards, clinics and departments across the district. Therefore staff must ensure that they familiarise themselves and comply with local policies and guidelines. Audit: Wards and departments to audit all waste, sharps bins, blood bags and waste disposal areas weekly. Heath & Safety, Facilities and Infection Control to audit quarterly (to be co-ordinated by the premises managers). 20

Bibliography Health and Safety at Work etc. Act 1974 Environmental Protection Act 1990 Management of Health and Safety at Work Regulations 1999 Control of Substances Hazardous to Health Regulations 1999 Personal Protective Equipment Regulations 1992 Special Waste Regulations 1996 HSE/HSAC Safe Disposal of Clinical Waste Controlled Waste Regulations 1992 Carriage of Dangerous Goods (Classification, Packaging & Labelling) Regulations 1996 Environmental Protection (Duty of Care) Regulations 1991 HSC Categorisation of Biological Agents according to Hazard and Categories of Containment Medicines Act 1968 Specification for Sharps Containers BS7320: 1990 Carriage of Dangerous Goods by Road Regulations 1996 Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 Controls Assurance Standard Department of Health 2001 21