Clinical Waste Audits
Since the introduction of the Environment Agency (EA) guidance for waste management companies in 2007, there has been a change in the way that healthcare waste is regulated in England and Wales. All healthcare waste producers, including GP practices, must provide audits of their waste to their waste management contractors if they are to continue to have their waste accepted at a clinical waste alternative treatment facility. The treatment facilities are required by their permits to obtain additional detailed information on the composition of a waste before they receive it, which forms part of their ‘pre-acceptance’ checks. This audit is an Environmental Agency legal requirement and failure to provide an audit report could result in the EA prohibiting waste collecting companies from collecting the waste from GP practices.
The Environmental Civil Sanctions (England) Order 2010 came into force on 6 April 2010 and gives the EA the power to invoke civil sanctions, such as monetary penalties, if companies do not comply with the environmental laws.
Further information can be found in:
- Section A6 2.1.1 of Appendix 6: Sector Guidance Note IPPC S5.06 – Supplementary PPC for clinical waste
- The BMA’s ‘Focus on Clinical Waste Audits’
- Pre-acceptance Healthcare Waste Self-Audit Tool
Sharps Bins / Boxes
Sharps bins either have:
- Yellow lids
- For sharps that may have medicinal contamination but not cytotoxic or cytostatic properties
- Orange lids
- For any sharps waste that do not essentially have any medicinal contamination (i.e. just phlebotomy).
- Purple lids;
- For sharps that may have medicinal contamination that is classified as cytotoxic or cytostatic.
It is this last classification that we felt worth highlighting. The definition of cytotoxic for the purposes of clinical waste disposal is wider than that we would normally consider. Here is the text from the clinical waste audit appendix:
The definition of cytotoxic and cytostatic medicines is wide, and is based on chemical properties rather than usage. Any medicine that is carcinogenic, mutagenic, toxic for reproduction, or toxic is classified as a ‘cytotoxic and cytostatic’ medicine. As a result this classification will include many hormonal preparations, oncology drugs, immunosuppressants, a vaccine, and a number of antivirals/antibiotics. Examples in community care might include; chloramphenicol, BCG vaccine, Methotrexate, and Methoxyprogesterone (Depo provera), Oxytocin (Syntometrine, Syntocinon).
This has implications for most practices, as it will include hormonal preparations and contraceptions such as Zoladex, mirena coils, implanon insertion devices. This should not have cost implications for practices as it should be the primary care organisation who meets the cost.
The guidance comes from HTM 07-01 (healthcare waste) which says the following about waste in community settings:
‘Sharps receptacles should be collected when filled to the fill line and should never exceed the permissible marked mass. If the sharps receptacle is seldom used, it should be collected after a maximum of three months, regardless of the filled capacity.’
However, the NICE best practice guidelines (2012) Healthcare-associated infections: prevention and control in primary and community care also says that:
Sharps containers ‘should be disposed of every 3 months even if not full, by the licensed route in accordance with local policy.’
It makes no differentiation between primary and community care.
With thanks for Mathew Richardson ICB Lead for Infection Prevention & Control Specialist at NHS West Hampshire ICB.