Healthcare Waste is waste produced during human or animal healthcare, or related research activity, and covers both Clinical Waste and Offensive Waste as defined in the Controlled Waste (England and Wales) Regulations 2012 [1] and requires specific management measures. Healthcare Waste containing radioactive materials requirements compliance with specific guidance[2].

Picture of Healthcare Waste packaging from Herefordshire CGC report
Picture of Healthcare Waste packaging from Herefordshire CGC report


Clinical Waste

Clinical Waste is Healthcare Waste that:

  • contains viable micro-organisms or their toxins which are known or reliably believed to cause disease in humans or other living organisms
  • contains or is contaminated with a medicine that contains a biologically active pharmaceutical agent
    • Medicine is a drug or other preparation for the treatment or prevention of disease
    • Cytotoxic and cytostatic medicine is medicine that possesses hazardous properties which are toxic, carcinogenic, mutagenic or toxic for reproduction.
  • is a sharp, or a body fluid, or other biological material (including human and animal tissue), containing or contaminated with a hazardous substance
    • A sharp is an item that could cause cuts or puncture wounds. This includes needles, hypodermic needles, scalpels and other blades, knives, infusion sets, saws, broken glass, and nails.
  • is waste of a similar nature from a non-healthcare activity

Offensive Waste

Offensive Waste is non-infectious waste which is unpleasant and may cause offence to those coming into contact with it. It includes[3]:

  • outer dressings and protective clothing e.g. masks, gowns and gloves that are not contaminated with body fluids
  • hygiene waste and sanitary protection e.g. nappies and incontinence pads
  • autoclaved laboratory waste.
  • falls within EWC waste codes 18 01 04, 18 02 03 or 20 01 99.

Offensive waste does not include [3]:

  • sharps
  • anatomical waste e.g.body parts, organs or blood
  • chemicals, medicines
  • dental amalgam
  • any waste that is infectious (i.e. a clinical waste)

Management of Healthcare Waste

The management of Healthcare Wastes is set out in Healthcare Technical Memorandum 07-01 - Safe Management of Healthcare Waste[4] which replaced the Safe Management of Healthcare Waste in 2013 [5]. Management of Healthcare Waste for regulated facilities with an environmental permit is the subject of guidance issued in July 2020 [6] by the EA which sets out appropriate measures in the following sections:

  • When appropriate measures apply
  • Definition of Healthcare Waste (as set out in the table below)
  • Managing healthcare wastes
  • General management appropriate measures
  • Waste pre-acceptance, acceptance and tracking appropriate measures
  • Waste storage, segregation and handling appropriate measures
  • Waste treatment appropriate measures (including assessment and validation requirements)
  • Emissions control appropriate measures
  • Emissions monitoring and limits appropriate measures
  • Process efficiency appropriate measures

Healthcare Waste - Packaging Colour and Appropriate Waste Management

The types of Healthcare Waste are grouped and designated by packaging colour set out in the table below (can be bag colour or lid colour)[7] [4]:

Colour of Packaging: Orange
Appropriate healthcare waste management activities Storage, alternative treatment or Incineration
Waste types and List of Waste (LoW) code(s) Infectious waste, not contaminated with chemicals or medicines
human healthcare (may contain sharps) - 18 01 03*
animal healthcare (may contain sharps) - 18 02 02*
municipal, separately collected fractions, not from healthcare or research-related sources (may contain sharps) - 20 01 99
commercial, separately collected fractions of absorbents, wiping cloths and protective clothing contaminated by infectious substances - 15 02 02
Colour of Packaging: Yellow
Appropriate healthcare waste management activities Storage and Incineration
Waste types and List of Waste (LoW) code(s) Infectious waste, contaminated with chemicals:
human healthcare - 18 01 03* and 18 01 06* or 18 01 07
animal healthcare - 18 02 02* and 18 02 05* or 18 02 06
Infectious waste, medicinally contaminated (not cytotoxic or cytostatic):
human healthcare (may contain sharps) - 18 01 03* and 18 01 09
animal healthcare (may contain sharps) - 18 02 02* and 18 02 08
Colour of Packaging: Red
Appropriate healthcare waste management activities Storage and Incineration
Waste types and List of Waste (LoW) code(s) Infectious anatomical waste, chemically preserved:
Human healthcare – 18 01 03* and 18 01 06* or 18 01 07
Animal healthcare – 18 02 02* and 18 02 05* or 18 02 06
Infectious anatomical waste, not chemically preserved:
Human healthcare – 18 01 03*
Animal healthcare – 18 02 02*
Non-infectious anatomical waste, chemically preserved:
Human healthcare - 18 01 02 and 18 01 06* or 18 01 07
Animal healthcare - 18 02 03 and 18 02 05* or 18 02 06
Non-infectious anatomical waste, not chemically preserved:
Human healthcare - 18 01 02
Animal healthcare - 18 02 03
Colour of Packaging: Purple
Appropriate healthcare waste management activities Storage and Incineration
Waste types and List of Waste (LoW) code(s) Cytotoxic and cytostatic medicines:
Human healthcare – 18 01 08*
Animal healthcare – 18 02 07*
Infectious waste, contaminated with cytotoxic and cytostatic medicines:
Human healthcare (may contain sharps) - 18 01 03* and 18 01 08* or 20 01 31*
Animal healthcare (may contain sharps) - 18 02 02* and 18 02 07* or 20 01 31*
Colour of Packaging: Blue
Appropriate healthcare waste management activities Storage and Incineration
Waste types and List of Waste (LoW) code(s) Other waste medicines, excluding cytotoxic and cytostatic medicines 18 01 09, 18 02 08 or 20 01 32
Colour of Packaging: Black and Yellow ('tiger bags')
Appropriate healthcare waste management activities Storage, Incineration or Landfill. Compaction, where specifically permitted.
Waste types and List of Waste (LoW) code(s) Non-infectious offensive waste:
Human healthcare – 18 01 04
Animal healthcare – 18 02 03
Municipal, separately collected fractions of absorbents, wiping cloths and protective clothing 15 02 03 not contaminated by infectious substances
Colour of Packaging: Not Specified
Appropriate healthcare waste management activities Storage, Incineration or Landfill. Compaction, where specifically permitted.
Waste types and List of Waste (LoW) code(s) Non-infectious offensive waste:
Human healthcare – 18 01 04
Animal healthcare – 18 02 03
Municipal, separately collected fractions of absorbents, wiping cloths and protective clothing 15 02 03 not contaminated by infectious substances

Treatment and Disposal of Healthcare Waste

With regard to the table above, it can be seen that there are options for incineration and alternative treatment and in some specific cases landfill is acceptable.

Incineration

For incineration, Healthcare Waste will normally be incinerated in High Temperature and Clinical Waste Incineration. Some Residual Waste EFW incinerators are able to dispose of specific Clinical Waste streams, and as a result of the COVID-19 pandemic the EA published a Regulatory Position Statement (RPS C23) clarifying the circumstances where COVID-19 waste can be incinerated with Municipal Waste Waste (MSW) until July 2021. [8]

Alternative Treatment

There are several types of Alternative Treatments (AT) available for the treatment of Healthcare Waste all of which must demonstrate that the Healthcare Waste is 'rendered safe'[4]. 'Rendered safe' means:

  • demonstrates the ability to reduce the number of infectious organisms present in the waste to a level at which no additional precautions are needed to protect workers or the public against infection from the waste;
  • destroys anatomical waste such that it is no longer generally recognisable;
  • renders all Clinical Waste (including any equipment and sharps) unusable and unrecognisable as Clinical Waste;
  • destroys the component chemicals of chemical or medicinal and medicinally-contaminated waste.

such treatments include:

Mechanical Treatment is also available as a pre-treatment option for any of the AT's outlined above. By pulverising, shredding, crushing etc the waste this results in a reduction of the volume of the waste by 60% plus although it does not kill any pathogens, microorganisms or disinfect equipment[9].

NHS Management of Healthcare Waste

The NHS report their management of Healthcare Waste via the Estates Returns Information Collection (ERIC) portal[10] which gives a break down the tonnage, management approach, and associated cost of waste - including Healthcare/Clinical Waste. The figure below for the ERIC data over the last four years shows a downward trend for Healthcare Waste going to incineration[11] (against a backdrop of increasing tonnage overall, notwithstanding the impacts of the pandemic, this means increasing tonnage has gone to treatment). The figure also shows that the proportion of waste incinerated from the NHS has dropped relative to the total Healthcare Waste incinerated - reflecting that non-NHS facilities (such as private hospitals, care homes etc)[12] have relied more heavily on incineration than treatment for the management of their waste over recent years.

 
NHS Clinical Waste Incinerated vs total Clinical Waste Incinerated - all rights reserved Monksleigh Ltd

References

  1. Definition of Healthcare Waste
  2. The Radioactive Substances Regulation Guidance
  3. 3.0 3.1 NetRegs
  4. 4.0 4.1 4.2 Link to pdf document
  5. Published in 2006, this removed the clinical waste classification system categorising into 5 types; A to E
  6. Healthcare Waste:Appropriate Measures for Permitted Facilities
  7. Types of Healthcare Waste
  8. RPS C23
  9. Malsparo
  10. https://digital.nhs.uk/data-and-information/publications/statistical/estates-returns-information-collection
  11. For the data for 2020/21 the figure produced by Monksleigh adjusts the ERIC data for 4 NHS Trusts that appear to have reported in kg rather than tonnes. This is the subject of a review by NHS Digital as it also impacts the Clinical Waste tonnage treated as a whole by the NHS estate
  12. https://digital.nhs.uk/services/organisation-data-service/file-downloads/non-nhs-organisations