A recent Department of Health memorandum looks set to cause the greatest shake up of waste management within the NHS since the disappearance of the hospital incinerator.
The memorandum, Safe Management of Healthcare Waste, is the DoH's response to the plethora of regulatory changes that have taken place in the last 18 months.
In particular, the introduction of the European Waste Catalogue requires infectious healthcare waste to be deemed hazardous rather than merely controlled. This results in an extra regulatory administrative burden, and associated cost. The catalogue also increased the number of healthcare waste sub-categories, which makes the traditional healthcare waste classification system - Groups A to E - obsolete.
The new memorandum has therefore been designed to provide a comprehensive best practice framework to help trusts meet their increasingly heavy legislative duties.
One of the key drivers for the new guidance, and specifically improved segregation, has been growing use of alternatives to incineration such as microwaving for the disposal of clinical waste. These technologies use much lower temperatures than incineration. Clearly, some healthcare waste streams, such as medicinal wastes, require the high temperatures provided by incineration in order to guarantee that they are safe.
The overriding issue for trusts wondering how to implement this guidance is limited resources. For some, the priority has been simply to maintain the status quo, so the new guidance will have a major impact.
Unsurprisingly, trusts which adopt good practice and make the necessary resources available have been able to demonstrate substantial cost savings by cutting the amount of waste. There are good reasons for embracing the memorandum even before anyone mentions legislation.
Given the delay between England and Wales' adoption of the European Waste Catalogue in 2005 and the publication of the memorandum, many trusts took the initiative and made interim provisions for managing of hazardous waste. For most, the major change was to classify all clinical ë¹¥llow bag' waste as infectious, therefore making it ë¨¡zardous'. Clinical staff and domestics would not have noticed a difference as the yellow bag remained the predominant feature of waste disposal in many wards, departments and theatres.
However, this approach resulted in cost increases owing to the administration charges associated with hazardous waste. The memorandum does not prohibit this policy directly but what is made very clear is that trusts can no longer apply a carte blanche approach to waste management, and a more comprehensive and detailed waste policy must be adopted.
The memorandum also introduces revised, non-mandatory classifications for healthcare waste. As the new national colour-coding scheme for healthcare waste is adopted, staff will have to differentiate between the use of:
o Yellow bags or containers for infectious clinical waste that must be incinerated
o Orange bags or containers for infectious wastes that can be treated by alternative technologies
o Purple and yellow bags or containers for cytotoxic and cytostatic wastes
o Black and yellow ë´©ger' bags for offensive wastes.
It is clear that someone within the trust will have to fully understand their waste disposal contract, and the implications for segregation and associated staff training. Moreover, the prescription only medicine category has gone and medicinal wastes that are neither cytotoxic nor cytostatic will have to be risk assessed to establish whether or not they are otherwise hazardous, in order to establish the appropriate method of disposal.
How to determine the correct waste receptacle should always be based upon a waste assessment, and undertaken by a healthcare professional who can appropriately determine whether the waste derived from the area is or is potentially infectious, hazardous, offensive or dangerous for carriage.
Many trusts are concerned about correctly assessing an area's potential to produce infectious waste. However, an assessment will provide the opportunity to develop waste policies specific to individual hospital areas, or for particular services such as community nursing. Developing such a waste policy, and providing the necessary receptacles and training, will require a considerable commitment.
A major incentive for this commitment is the potential reduction in disposal costs, as some infectious clinical wastes may be disposed of through lower cost alternative treatment routes, and offensive waste can be disposed of to landfill.
Trusts cannot ignore the memorandum. The Environment Agency regards healthcare waste as a priority and has increased auditing of NHS premises. Adopting the memorandum's framework methodology will ensure that the Environment Agency's requirements are met. A key part of the methodology is the need to revise existing waste polices by undertaking an assessment of all areas and processes.
The policy should identify the appropriate waste classification and colour coded receptacles for each area. This plan should then be rolled out throughout the trust.
Most important of all, to avoid confusion, a comprehensive training and awareness programme must be set up. The success of the policy will depend on all employees embracing the new system and effective training at all levels in all areas is key.
Trusts should remember that if they embrace the guidelines they will not only achieve legislative compliance, but also significant cost savings.
Greg Roberts is senior environmental consultant at Hyder Consulting