An Introductory Guide to
Healthcare Waste Managementin England & Wales
PUBLISHED APRIL 2014
PRICE: £4.95

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Contents
An Introductory Guide to
Healthcare Waste Managementin England & Wales
Introduction
Who Is The Booklet Aimed At?
What Is Covered In The Booklet?
Managing Waste In The UK
Key Legislation Governing Healthcare Waste
Waste Hierarchy And Disposal Technologies
Waste Hierarchy
Waste Management Treatment Methods
Waste Categories & Treatment Methods
Healthcare Waste Streams
Waste Descriptions
EWC Codes and Waste Descriptions – Legal Paperwork
Documentation
Keeping Records
Waste Handling and Storage
Segregation
Traceability
Temporary Storage At Source
External Storage And Security
Duty of Care
Producer Responsibility - Selecting A Contractor
Waste Transfer
Waste Treatment
Policy and Procedures
Key Sources of Information & Recommended Reading List
Glossary & Acronyms
Acknowledgements
Disclaimer

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ISBN: 978-0-902944-64-0

An Introductory Guide to Healthcare Waste Management in England & Wales

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Sponsor’s Comment“In 2013 the NHS spent over £86m on the disposal of clinical waste … double that of 2006.
This figure is set to rise year on year as landfill becomes more expensive and this against a
backdrop of an increasing requirement to be sustainable. Over the coming months and years
there will be a greater focus on both reducing the amount of waste generated and looking atways of dealing with the waste that is derived.

With a spectrum of waste generators, from the small (kilograms per year) to the large
hospitals (thousands of tonnes per year) there is the need for a toolbox of processes, initiatives
and solutions.
Whilst we as a company have a specific onsite waste to energy technology, our aim is to help
precipitate understanding of and prompt debate in clinical waste as a topic … and indeed a fuelsource! We are therefore delighted to support this booklet and hope that it not only stimulates
thoughts and ideas but also helps individuals and Trusts share solutions.”
Nick Palmer,
General Manager, Environmental Division, DPS Global

4

An Introductory Guide to Healthcare Waste Management in England & WalesIntroduction
Who Is The Booklet Aimed At?
The management of waste from all healthcare premises and practices (including those nonhealthcare premises that produce similar types of waste) involves a considerable amountof fairly complex legislation which must be complied with by all parties involved, from theproducer through to the final disposal company. This document has been produced by CIWM
as an introductory guide to healthcare waste management in England and Wales. It is aimed
at small producers of healthcare waste, as well as members of the Institution who are looking
to expand their general waste management knowledge and to enhance their continuing
professional development (CPD) or structured learning and development (SLD). The document
is based on legal compliance as well as good practice guidance. A recommended reading
section (page 25) has been provided where further advice and assistance may be found.
It is important to note that there is some variation across the UK with respect to legislationand policies. As a result, this guidance is aimed at producers of healthcare wastes fromEngland and Wales only.
Potential small producers of healthcare and he‑althcare type waste include:
•
•
•
•
•
•
•
•
•
•
•

First Aid Rooms at schools and work environments
Alternative Practitioners – eg, chiropractors, acupuncturists, non-NHS physiotherapists
Beauty Salons
Care Homes (with and without nursing care)
Companies dealing with drugs-related litter (not including local authorities)
Gymnasia
Learning Disabilities Homes (residential, day care and respite)
Nurseries
Private Clinics
Private Podiatrists/Chiropodists
Tattooists

What Is Covered In The Booklet?
The guidance document aims to cover the main areas of healthcare waste management that
small producers are likely to come across and will be useful to newcomers to the healthcare
waste management sector.
An Introductory Guide to Healthcare Waste Management in England & Wales

5Healthcare Waste Legislation
Managing Waste In The UK
In the UK, the primary aim in the management of waste is to ensure that it is handled, treated
and disposed of safely, cost effectively and in a manner that does not impact negatively on theenvironment.

Key Legislation Governing Healthcare Waste

Healthcare wastes are defined as any wastes that result during a healthcare procedure. Someof these wastes (known as clinical/infectious waste) may be hazardous to those that comeinto contact with them and are subject to strict controls. Even activities that are not directly or
indirectly related to healthcare can generate similar type wastes that need special attention.
There are a number of pieces of legislation that cover a wide range of issues, from thegeneration, through to the collection, transport and finally either treatment or disposal ofhealthcare waste. It is important to note that many of these are not necessarily solely focusedon healthcare waste and are applicable to other waste streams.

The legislation covers a range of issues, including the working conditions and health and safetyof employees; containment, packaging and transport; and treatment and disposal of the waste.
Each has a key role to play in how healthcare waste is managed. For a full overview of the key
content of the waste legislation, please see the following link:
http://www.environment-agency.gov.uk/business/142643.aspx
It is important to note that there is some variation across the UK with respect to legislationand policies. In England and Wales the Hazardous Waste (England and Wales) Regulations
2005 (as amended) are used.

The management of waste is regulated through various pieces of European Union (EU) and UK
legislation, covering health and safety, packaging, transport and regulation and enforcement.
There are also guidance documents from the Department of Health (DH) and the Royal College
of Nursing (RCN) where you can find more detail (See the Recommended Reading Section,
page 25).

6

An Introductory Guide to Healthcare Waste Management in England & WalesWaste Hierarchy And Disposal Technologies
Waste Hierarchy
The Waste Hierarchy (Figure 1) provides a sliding scale that ranks waste management options
according to what is good for the environment with the best option sitting at the top of thescale and the least preferred option at the bottom. It gives top priority to waste prevention
with final disposal, e.g. landfill or incineration without energy recovery, the least preferred
method.

Figure 1: recommended reading list document 11, page 25
Hazardous and non-hazardous waste producers are required to apply the waste hierarchy.
It is a legal requirement to state on all Waste Transfer Notes (WTN) and Hazardous Waste
Consignment Notes (HWCN) that the Waste Hierarchy has been taken into consideration.

Waste Management Treatment Methods

The following section will summarise the most commonly used waste management treatment
methods for dealing with healthcare wastes, as well as non-healthcare waste streams (i.e.
recycling and municipal waste). It is important that you understand the different treatment
An Introductory Guide to Healthcare Waste Management in England & Wales7

methods as they are related to the colour coding of the packaging for particular waste streams.
It should also be noted that certain wastes must be disposed of via a particular treatment
method to ensure they are properly destroyed.

Most waste treatment processes will result in a small volume of ‘final’ disposal to a landfill
site, or a municipal incinerator as ‘energy from waste’. Some (non-hazardous) wastes are taken
directly to landfill without any material extraction or treatment. However, landfill disposal may
be the final destination for some wastes (avoid where possible) and is the end of the Duty ofCare chain.

Alternative Treatment (AT)The treatment of hazardous (infectious) healthcare waste is intended to provide protection to
the environment and human health. To be effective, the treatment must reduce or eliminate
the hazard present in the waste so that it no longer poses a risk. Treatment facilities are also
required to make the waste unrecognisable (eg, to ensure that no confidential information
is visible and/or that the waste does not cause offense when viewed) and reduce the waste
volume as well as meet stringent requirements for sterilisation and disinfection.

There are several types of AT available for the treatment of healthcare waste. The mostcommon type of AT for infectious healthcare waste involves the use of autoclaves. Autoclaving
involves the addition of steam into a container at high pressures. Please see page 10 for more
information on waste suitable for treatment using AT processes.

High Temperature Treatment

Incineration is the most commonly used high temperature treatment for infectious waste
but other technologies exist including pyrolysis and gasification. Incinerators suitable forhazardous waste (infectious and/or medical) come in a variety of designs, typically they havea primary chamber that operates at 800-1000ºC and a secondary chamber operating at aminimum temperature of 1100ºC. The steam from these incinerators may be used for heatingbuildings near the incinerator itself. Please see page 10 for more information on waste streams
treated by this process.
Waste that is not hazardous, eg offensive waste may be sent for incineration but with energy
recovery. This is where the heat and steam generated from burning the waste may be used togenerate electricity that is fed back into the national grid. These sites are not permitted to takeany hazardous wastes.

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An Introductory Guide to Healthcare Waste Management in England & WalesLandfill
Landfill is the disposal of waste into or onto land in a carefully controlled manner in linewith authorisation from the Environment Agency (EA) and Natural Resources Wales (NRW).
Infectious waste is banned from landfill. Non-infectious offensive waste may be disposedof directly to landfill, as well as residual municipal waste (black/clear bag) that cannot berecycled.

Waste Categories & Treatment Methods
Category of Healthcare Waste
Infectious clinicalTreatment method
Alternative treatment or
hazardous waste incineration

Offensive waste
Non-medicine contaminatedsharpsMedicine contaminated sharps
Cytotoxic & cytostatic
Medicine waste
Medicine contaminated infectious
clinical waste
Domestic or municipal waste

Alternative treatment or
hazardous waste incineration
Hazardous waste incineration
Hazardous waste incineration
Hazardous waste incineration
Hazardous waste incineration

Disposal
Energy from waste orlandfill
Energy from waste or
Landfill
Residual ash recovery or
landfill
Incineration
Incineration
Incineration
Incineration
Re-use, recycle, energy fromwaste or landfill

Table 1: The available waste categories (see page 10) and their relevant treatment methods.

An Introductory Guide to Healthcare Waste Management in England & Wales

9Healthcare Waste Streams
The following table is an extract from the European Waste Catalogue (EWC) and showsdifferent types of waste that may be produced from healthcare related activities. Information isprovided to:• describe the wastes, using a number of examples• indicate how that waste should be packaged (whether in a bag or container) and thecolour coding that should be used
• show the EWC code for that waste stream• describe the disposal route for the waste• indicate which wastes must NOT be placed into each waste stream.

Please note that an asterisk (*) has been placed after the waste streams that are hazardous
in line with WM2 (see recommended reading list document 5, page 25). Please note a waste
description and EWC code(s) must be used on all legal paperwork that is completed prior towaste being removed from the producer’s premises. Where it states that the bag or sharps
container is UN approved then this means that the packaging must comply with international
dangerous goods agreements which is enforced via The Carriage of Dangerous Goods and Useof Transportable Pressure Equipment Regulations 2009 (as amended).

Waste Descriptions

In order to work out what type of documentation is required and the most appropriate
treatment and disposal route, waste must be classified into a colour coded waste stream.
For assistance on classifying your waste as hazardous or non-hazardous, please see therecommended reading list (page 25) or use this EA webpage: http://www.environmentagency.gov.uk/business/topics/waste/32180.aspx
Every single waste that is generated must be allocated a code from the EWC. If you aredelivering healthcare, the codes that you are most likely to use are in Table 2 opposite.

Healthcare waste is waste produced as a result of healthcare practice by or under thesupervision of a trained practitioner. Waste similar in nature to healthcare waste, such asa soiled plaster may be produced in the home or office environment by people other thantrained healthcare professionals, eg a first aider may assist a colleague at work but they are
not a trained healthcare professional. In such instances the waste should not be classified ashealthcare waste (in Chapter 18 of the EWC) but as a municipal waste as defined in Chapter 20of the EWC.
10An Introductory Guide to Healthcare Waste Management in England & Wales

Code
18
18 01
18 01 01
18 01 02
18 01 03*
18 01 04
18 01 08*
18 01 09

Description
Wastes from human and animal health care and/or related research (except kitchen andrestaurant wastes not arising from immediate health care)
Waste from natal care, diagnosis, treatment or prevention of disease in humans
Sharps except 18 01 03*
Body parts and organs including blood bags and blood preserves (except 18 01 03*)
Waste whose collection and disposal is subject to special requirements in order to prevent
infection
Waste whose collection and disposal is not subject to special requirements in order toprevent infection, e.g. dressings, plaster casts, linen, disposable clothing.
Cytotoxic and cytostatic medicines
Medicines other than those mentioned in 18 01 08*

Table 2: Adapted from WM2, version 3 (recommended reading list document document 5, page 25). Please see
WM2 version 3 for the full table of available codes
The code for non-healthcare wastes which may require specialist treatment is 20 01 99(See Table 3). This code is applied to sharps containers and other wastes from beauticians,
tattooists, nurseries, residential homes etc. Other wastes may be generated from these sources
too, eg waste medicines from a care home.
Code
20

20 01
20 01 31*
20 01 32
20 01 99

Description
Municipal wastes (household waste and similar commercial, industrial and institutional
wastes) including separately collected fractions
separately collected fractions (except 15 01)
Cytotoxic and cytostatic medicines
Medicines other than those mentioned in 20 01 31*
Other fractions not otherwise specified (used for offensive waste)

Table 3: Adapted from WM2 version 3 (Recommended reading list document 5). Please see WM2 version 3 for fulltable of available codes

An Introductory Guide to Healthcare Waste Management in England & Wales

11

Infectious clinical waste*

EWC Code: 18 01 03*

Waste that has been produced from the treatment of infectious patients,
those suspected of having an infection and are contaminated with body
fluids, for example:

UN approved orange bagüü personal protective equipment (gloves, masks, aprons)üü wipes, dressings, plasters, bandages
üü incontinence wasteüü empty saline or glucose IV bags and tubing (no active medicines added)–infectious
Disposal route:
This waste stream is usuallydisposed of by alternative
ûû medicines or medicine contaminated items(i.e. empty medicine packaging, IV bags, lines and tubing that have had treatment methods, but may
also be incinerated. The
medicines added)
residue from this processûû sharps waste
may be sent to energy fromûû chemically contaminated waste
waste or landfill.
ûû offensive wasteûû domestic waste or recyclable waste

The following wastes should NOT be placed in this waste stream:

Offensive waste including sanitary/nappy waste

EWC Code: 18 01 04 and 20 01 99

Waste that has been produced from the treatment of non-infectious patientsand are contaminated with body fluids, for example:

Yellow bag with black
stripe(s)üü personal protective equipment (gloves, masks, aprons) – non-infectious
Sanitary waste bins andüü wipes, dressings, plasters, bandages – non-infectious
nappy bins may also beüü incontinence waste – non-infectious
used for sanitary waste andüü empty saline or glucose IV bags and tubing (no active medicines added)
nappies respectively– non-infectious
üü soiled sanitary towels and tampons – from public and work based
female toilets
üü nappies – from baby changing areas and nurseries
These items may cause offence due to their appearance, odour or wetness

The following wastes should NOT be placed in this waste stream:ûû infectious clinical waste
ûû sharps wasteûû medicines or medicine contaminated items (i.e. empty medicine
packaging, IV bags, lines and tubing that have had medicines added)
ûû chemically contaminated wasteûû domestic waste or recyclable waste

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Disposal route:
This waste stream canbe disposed of to landfill(separately to domestic
waste), but may also betreated, recycled, or sent forenergy from waste.

An Introductory Guide to Healthcare Waste Management in England & WalesNon-medicine contaminated sharps*

EWC Code: 18 01 03*

Sharps waste that has been produced from the treatment of infectious
patients and those suspected of having an infection, but has also NOT beenused for the administration of medicines, for example:

Orange lidded sharps
container

üü needles and syringes – non-active medicine contaminatedüü blades – non-active medicine contaminatedüü scissors – non-active medicine contaminatedüü other disposable instruments – non-active medicine contaminated
The following wastes should NOT be placed in this waste stream:ûû medicines or medicine contaminated items (ie sharps used for theadministration of medicines, empty medicine packaging, IV bags, lines
and tubing that have had medicines added)
ûû cytotoxic or cytostatic waste
ûû chemically contaminated wasteûû domestic waste or recyclable waste

Cytotoxic & cytostatic waste*

Disposal route:
This waste stream is usuallydisposed of by alternative
treatment methods, but may
also be incinerated. The
residue from this process
may be sent to energy fromwaste or landfill.

EWC Code: 18 01 03* and 18 01 08*

Waste that has been used in the treatment of infectious patients and thosesuspected of having an infection, and may also have been used for theadministration of cytotoxic and cytostatic medicines, as well as cytotoxic
and cytostatic medicines for example:
üü needles and syringes – cytotoxic/static medicine contaminatedüü blades – cytotoxic/static medicine contaminatedüü scissors – cytotoxic/static medicine contaminatedüü IV bags, lines and tubing that have had cytotoxic/static medicinesaddedüü unused, part used and out of date cytotoxic/static medicines
The following wastes should NOT be placed in this waste stream:ûû medicines or medicine contaminated items (ie empty medicine
packaging, IV lines and tubing that have had medicines added
ûû chemically contaminated waste
ûû offensive wasteûû domestic waste or recyclable waste

Purple lidded sharps
container

Disposal route:
This waste stream must be
disposed of by incineration.

An Introductory Guide to Healthcare Waste Management in England & Wales

13

Medicine contaminated infectious clinical waste

EWC Code: 18 01 03* and 18 01 09

Waste items that have been used in the treatment of infectious patients andthose suspected of having an infection and may also be contaminated withmedicines or chemicals, for example:üü IV bags, lines and tubing that have had medicines added
üü chemically contaminated waste.

Yellow bag or yellow rigid
container – preferablylabelled as “Medicine
contaminated infectious
clinical waste”

Sharps waste that has been used in the treatment of infectious andpotentially infectious patients, and may also have been used for theadministration of medicines or chemicals, for example:
üü needles and syringes – medicine contaminatedüü blades – medicine contaminatedüü scissors – medicine contaminatedüü other disposable instruments – medicine contaminated
The following wastes should NOT be placed in this waste stream:ûû waste that is just clinical infectious
ûû offensive wasteûû domestic waste or recyclable waste

Disposal route:
This waste stream must be
disposed of by incineration.

Medicine waste

EWC Code: 18 01 09

Non-cytotoxic/cytostatic waste medicines, for example:

Blue lidded container –please note that there area variety of designs forthis type of container andcontainers on your site may
not look exactly like that
pictured.

üü unused, part used and out of date tablets, creams, liquid dose
medicines and patches

The following wastes should NOT be placed in this waste stream:ûû waste that is just clinical infectious
ûû chemically contaminated waste
ûû offensive wasteûû domestic waste or recyclable wasteûû IV bags, lines and tubing that have had medicines added

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Sharps

Disposal route:
This waste stream must be
disposed of by incineration.

An Introductory Guide to Healthcare Waste Management in England & WalesDomestic or municipal waste
Waste similar to that produced in the home environment, for example:

EWC Code: 20 03 01
Black or clear bag

üü flowers
üü food and associated food packaging
üü clean packaging and wrappings – from clinical products

The following wastes should NOT be placed in this waste stream:ûû infectious clinical waste
ûû offensive waste
ûû sharps wasteûû medicines or medicine contaminated items (ie empty medicine
packaging, IV bags, lines and tubing that have had medicines added)
ûû chemically contaminated waste
ûû recyclable waste

Disposal route:
This waste stream can besent to energy from waste
or disposed of to landfill.
However, any material which
can be recycled or recovered
should be as best practice.

An Introductory Guide to Healthcare Waste Management in England & Wales

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EWC Codes and Waste Descriptions – Legal Paperwork
All movements of waste, not just healthcare streams, in the UK require a paper trail. There areseveral elements to this and some businesses may require more than others depending on thetypes of waste produced. Using the information below and at the start of the Healthcare Waste
Streams section, this section should be able to help you correctly classify your waste and use
the correct documentation.

Documentation

The documentation required depends upon what the waste is composed of and where it
is collected from. No documentation is required if the waste is collected from a privatehousehold. However, documentation is required for all other collections and movements ofwaste. If the waste is defined in the EWC as a hazardous waste, that is one that has an asterisk(*) after it, then it must be consigned on a HWCN. Non-hazardous waste does not requirecompletion of a HWCN, but a waste transfer note (WTN) should be completed.

Hazardous Waste Consignment Note (HWCN)

There are a number of pieces of information required on a HWCN. Part A contains detailsof the place producing the waste and will also ask for a premises code. A premises code canbe obtained from the EA and NRW following registration as a hazardous waste producer.
Producers only need to register for a premises code from the EA and NRW if their site
produces more than 500kg of hazardous waste each year. This registration can be done online
at https://hwreg.environment-agency.gov.uk/registrationwelcome.jsp?lang=_e for England, or
you can ring 03708 502 858.

When registering the EA or NRW will ask for the organisation’s Standard Industry
Classification (SIC) Code. Table 4 shows the most frequently used SIC codes for both HWCN
and waste transfer notes (WTN) for non-hazardous waste. Different SIC codes are required foreach type of note; 2007 SIC codes must be used on WTNs and the 2003 SIC codes must be usedon HWCNs. Advice on SIC codes from the EA can be found at the following link:
http://www.environment-agency.gov.uk/business/regulation/129242.aspx
Part B of the HWCN contains details of the waste, which includes the EWC code describedabove, an accurate description of the waste, the quantity of waste (kg or litres) and a
description of its packaging, eg bags, sharps containers etc.

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An Introductory Guide to Healthcare Waste Management in England & WalesPrivate consultant clinic
Elderly Day centre (charitable)
Elderly Care Day centre non –charitable
Residential nursing care facilities (supervised by doctors)
Residential nursing care (not supervised by doctors)
Child daycare activities (charitable)
Child daycare activities (non charitable)
Beauty treatment activities
Tattooist
Gym
Physiotherapist (private)
Residential care for learning difficulties (charitable)
Residential care for learning difficulties (non charitable)
Decontamination services

2007 codes for WTNs
86.22
87.30
87.30
87.10
87.10
88.91
88.91
96.02
96.09
93.11
86.9
87.2
87.2
39.00

2003 codes for HWCNs
85.12
85.31/1
85.31/2
85.14
85.11/3
85.32/1
85.32/1
93.02
93.05/9
92.62/985.14
85.31/1
85.31/2
90.03

Table 4 commonly used SIC Codes used in relation to healthcare waste. Please see http://www.ons.gov.uk.guidemethod/classifications/current-standard-classifications/standard-industrial-classification/sic-2007-indexes.pdf forthe full list of both 203 and 2007 SIC codes
Part B also contains some information required by the Department for Transport. If you areconsigning clinical waste then this line should have the description UN3291, Clinical Waste,unspecified, n.o.s 6.2 II. It is important that all of these are included, the 6.2 and II can be in adifferent box but the description must be written in the order shown here.

The driver will fill in part C and then the person on your site who hands the waste over will
sign part D. This must be signed legibly and the date and time added. The driver must not takethe waste if there is no-one there to sign for it. It is a legal requirement to state on all HWCNs
that the Waste Hierarchy has been taken into consideration.

Part E is completed after the waste has been received at the waste transfer station ortreatment plant. You must have a copy of this sent back to you or alternatively, you may receive
a quarterly summary of all the waste you have sent. You must keep all your HWCNs for aminimum of three years.

An Introductory Guide to Healthcare Waste Management in England & Wales

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Waste Transfer Note (WTN)
A WTN is used for the consignment of non-hazardous wastes, eg 18 01 04, 20 01 99 foroffensive wastes, sanitary bin exchanges, domestic waste or recycling. If you have the same
waste collected regularly then you may have a single WTN to cover the year (an annual note).
If you produce different wastes or varying quantities then you should receive a WTN eachtime your waste is collected. WTNs must be kept for a minimum of two years. It is a legal
requirement to state on all WTNs that the Waste Hierarchy has been taken into consideration.

18

An Introductory Guide to Healthcare Waste Management in England & WalesThe WTN provides essential information for carriers and other contractors involved in thetransfer, treatment and disposal of the waste: the Duty of Care chain , also known as a ‘cradle
to grave’ responsibility.

An electronic system of filling in WTNs, called Electronic Duty of Care (edoc) was been
introduced in January 2014, information about this can be found at http://edoconline.co.uk/

Waste Carrier’s Licence

If you carry waste that you have produced as part of your job then you are required to registerwith the EA or NRW for a waste carrier’s licence (lower tier). There is no charge for this typeof registration and it will not expire. You should carry a copy of your registration number withyou, this can be a copy of the printed registration or just a note in your diary as long as you haveit to hand registration can be made online at: https://www.gov.uk/waste-carrier-or-brokerregistration in England only. In Wales you need to contact www.naturalresourceswales.gov.uk.
If you carry waste on behalf of another organisation you may require an upper tier waste
carrier registration, there is a charge for this and the registration will need to be renewed
every three years.

Keeping Records

It is a legal requirement that you keep accurate records of all waste that leaves your site. A
good idea is to set up a folder which can include any aspects below or the entire list:• a copy of your premises registration (if producing over 500 kg of hazardous waste perannum) – renew annually• a copy of your carriers registration – one time registration (for lower tier registrations)• all WTNs
• all HWCNs

If the EA or NRW visit your site, one of the first things they will ask for is your site register (oryour waste management folder). If you have all the above information filed and stored where it
can be easily accessed this will help with any audits you may have.

An Introductory Guide to Healthcare Waste Management in England & Wales

19

Waste Handling and Storage
Segregation
A key part of effective waste management and legislative compliance is the segregation ofwastes at source. Poor segregation will lead to increased costs of disposal and may result inprosecution if the waste is considered to be ‘mixed’ and is deemed no longer suitable for thewaste treatment or disposal option you have chosen to use. A clear policy and awarenesstraining for all staff in effective segregation is fundamental. Please see page 10 for more
information.

Traceability

It is best practice that containers and bags used for final disposal are marked or tagged. This
enables the waste to be traced and its source determined in the event of non-conformance
being identified. This may take the form of specially coded bag ties, self adhesive labels or byclear permanent writing on the container. Most sharps containers and pharmaceutical bins
have space on the label for this purpose. The packaging should ideally be labelled to show thesource and the date produced.
Infectious wastes and other dangerous goods are subject to regulations regarding theirtransport and have to be contained in special UN tested and approved packaging. The use ofordinary bags and boxes is not permitted and your contractor will refuse to collect it in thisform. A detailed colour coding system is in place for healthcare wastes. For further details
please refer to page 10.

Your waste contractor may provide you with the correct form and quantity of packaging foreach type of waste you identify to them. This packaging will be tested and designed to carry aset weight or volume of waste. You should identify what these limits are and not exceed themas you are responsible for any spillage that may result.

Temporary Storage At Source

Infectious, dangerous or offensive wastes should be placed in suitable packaging immediately
to avoid risk of contamination or spillage. This usually means that suitable temporary storageis close at hand (eg, pedal bins/bag holders etc), or that suitable containers are taken to thesource and then returned to a storage location (eg, sharps containers or pharmaceutical bins).

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An Introductory Guide to Healthcare Waste Management in England & Wales

Bag and sack holders should be able to be easily cleaned and disinfected and free fromsharp edges that are liable to tear or puncture bags. To improve infection control, all bag/sack holders used for temporary storage should be pedal operated with self closing lids andmust be labelled to clearly identify their use. Where practical, colour coded pedal bins help toreinforce correct identification and segregation.
Examples of good practice:• The use of 0.5-litre or 1-litre sharps containers for a single user or low use application.
A larger box may be appropriate for a central multi-user application, but limited to a
maximum storage period of three months.
• Bags, sacks and containers must not be over filled. There must be adequate room within
the bag or box to allow it to be easily closed, tied or sealed without the risk of it coming
undone, splitting or bursting during handling or transport.

External Storage And Security

Waste producers are legally responsible for ensuring that wastes are not allowed to escape.
The word ‘escape’ includes:• leakage or spillage from bags or containers, for example:• bags that are not properly tied or secured• bags that are overfilled causing splitting and spillage• bags or containers that have been ripped or torn by rodents (ie, rats) or other vermin• bags and waste containers that are only designed to contain solids used for free flowing
liquids – if liquids are being disposed of then sufficient absorbent material must be
added to take up the liquid• Allowing persons to gain unauthorised access• Unauthorised access to healthcare wastes can be dangerous to human health. In
addition, it is a legal requirement for waste to be stored securely. However “securely”
is not defined in guidance documentation so “securely” could refer to a locked wheeledbin or container, a locked room or cupboard.

You should discuss with your contractor whether they will provide external storage
container(s) (eg wheelie bin or other suitable containers), the location of the container(s)and how access is achieved during service. Waste contractors may offer a range of different
services depending upon the facility the waste will be taken to. Key points to consider are thefrequency of service. As above, wastes should not be allowed to accumulate excessively as thismay cause odour, nuisance or pests to build up.
An Introductory Guide to Healthcare Waste Management in England & Wales

21

Duty of Care
The ‘Duty of Care’ is a legal responsibility under Section 34 of the Environmental Protection
Act 1990.
The Duty of Care applies to any individual and/or organisation producing or handling
controlled waste. Controlled Waste is the legal definition for waste produced by all types ofbusinesses, including healthcare providers.
Controlled waste may be hazardous* or non-hazardous.

Producers of controlled waste must ensure that their waste is stored, collected, treated anddisposed of (or recycled) by organisations/contractors registered with the EA, NRW or the
local authority.

Producer Responsibility - Selecting A Contractor

It is the responsibility of the waste producer to ensure that individuals or companies employed
to transfer or treat their waste have the correct licences, permits or registrations to carry out
these functions.
Can the company accept and/or treat or dispose of the waste type requiring removal?

Prior to selection, initial checks can be undertaken to confirm whether specific contractors areregistered as waste carriers, environmental permit holders, etc via the EA ‘Public Registers’
pages: http://epr.environment-agency.gov.uk/ePRInternet/SearchRegisters.aspx. In Wales
contact the NRW Customer Care Centre on 0300065 3000.
Visiting a prospective site is advisable, particularly where hazardous waste treatment isrequired. Visiting the company website and reviewing testimonials, etc are good examples
of how to measure the reliability of a company. Annual ‘due diligence’ checks are advised
throughout the life of the contract, including:
•
•
•
•
•
•

22

Do licences, permits or other authorisations need updating?
Is the waste taken to the site identified on the WTN (shadowing the transfer is an option)?
Are quarterly returns provided for HWCNs?
Are WTNs completed correctly (and final copies returned to the producer)?
Is the site well managed?
Is the waste treated as stated?

An Introductory Guide to Healthcare Waste Management in England & WalesWaste Transfer
The transfer of waste comes under the Duty of Care. For further information on this topic,
please see page 20.

Waste Treatment

Contractors who treat, recycle or dispose of waste must be registered with the EA or NRW. For
further information on the treatment of waste please see page 7.

An Introductory Guide to Healthcare Waste Management in England & Wales23

Policy and Procedures
To ensure the compliant and appropriate management of healthcare waste, protection ofhuman health and the environment, it is essential that a Waste Management Policy or set ofoperational procedures are available to all waste producers.

The Care Quality Commission (CQC) and Care and Social Service Inspectorate Wales requirethat organisations providing healthcare should have a number of supplementary policies
available, including one for the safe handling and disposal of waste and sharps.

The information in this document may be reproduced to assist in the production of a suitablepolicy and/or procedures. Further information may be found in those documents listed on
page 25.
It is recommended that a Waste Management Policy and/or procedures should include thefollowing sections and relevant information:
•
•
•
•
•

waste types, descriptions and definitions
segregation, colour coding and packaging of the different waste streams
waste handling, storage, collection and movement
responsibilities
health and safety – including risk assessments, immunisations, accidents and incidents(involving waste), dealing with spillages, management of sharps• staff training• legal paperwork – HWCNs and WTNs, site registers and record keeping• auditing and monitoring

Ideally the policy and/or procedures should be reviewed and updated on a regular basis toinclude any changes in practice, legislative requirements or waste contractor.
It is important to ensure that all of those involved in dealing with waste have access to thepolicy and/or procedures and have received training in how to manage waste that they
produce, handle and send for alternative treatment or disposal.

24

An Introductory Guide to Healthcare Waste Management in England & WalesKey Sources of Information & Recommended Reading List
1. The DH offers guidance on healthcare waste management, through a key document,
Health Technical Memorandum (HTM) 07-01: Safe management of healthcare waste,
March 2013: https://www.gov.uk/government/publications/guidance-on-the-safemanagement-of-healthcare-waste

2. The RCN has issued a report on healthcare waste management across the UK, entitled
Freedom of Information report on waste management, April 2011: http://www.rcn.org.
uk/__data/assets/pdf_file/0005/372308/004108.pdf
3. In 2010, the EA produced guidance on Healthcare Waste Pre-Acceptance Audits for
producers of healthcare and related wastes. A copy of the document can be found at
the link below: http://www.environment-agency.gov.uk/static/documents/Business/
Briefing_note_Oct_2010_vs_6_final.pdf
4. In 2013, the EA produced their latest briefing note on clinical waste pre-acceptanceinformation (September 2013). This document can be located at the link below:
http://www.ciwm.co.uk/web/FILES/Technical/Briefing_Note_-_Clinical_Waste_Preacceptance_Information_(Sept_2013).pdf

5. In 2013, the EA updated the latest version of WM2 (version 3), which describes how toclassify whether your waste is hazardous or non-hazardous. This document can be foundat the link below: http://www.environment-agency.gov.uk/business/topics/waste/32180.
aspx
6. The EA have produced a basic guide to understanding hazardous wastes, called HWR01A.
This document can help you to classify your waste and can be found at the following link:
http://a0768b4a8a31e106d8b0-50dc802554eb38a24458b98ff72d550b.r19.cf3.rackcdn.
com/LIT_5552_28b742.pdf

7. For policies on healthcare waste specifically, please see: https://www.gov.uk/healthcarewaste
8. The Health and Safety Executive (HSE) provides information on a range of health andsafety issues associated with the management of healthcare waste: http://www.hse.gov.
uk/healthservices/healthcare-waste.htm

An Introductory Guide to Healthcare Waste Management in England & Wales25

9. This also includes guidance on ‘best practice’ for the management of offensive/hygiene
waste: http://www.hse.gov.uk/pubns/waste22.pdf

10.CIWM has produced guidance for large organisations that have to undertake preacceptance audits: http://www.ciwm.co.uk/web/FILES/Technical/Pre-acceptance_audit_
guidance_document_140114.pdf
11. Defra produced guidance on applying the Waste Hierarchy in 2011. This document can befound below: https://www.gov.uk/government/uploads/system/uploads/attachment_
data/file/69403/pb13530-waste-hierarchy-guidance.pdf

12.The EA ‘Public Registers’ pages can be used to undertake prior checks to confirm whether
specific contractors are registered as waste carriers, environmental permit holders, etc :http://epr.environment-agency.gov.uk/ePRInternet/SearchRegisters.aspx.

26

An Introductory Guide to Healthcare Waste Management in England & WalesGlossary & Acronyms
ADR: European agreement concerning the international carriage of dangerous goods by road.
AT: Alternative Treatment.

BAT: Best Available Techniques.

Care and Social Service Inspectorate Wales: The regulator for social care and social services
in Wales, from child minders and nurseries to homes for older people.
Category A/Category B: Classification of infectious substances in line with the Carriage
Regulations.

Clinical waste: means waste from a healthcare activity (including veterinary healthcare) that:(a) contains viable micro-organisms or their toxins which are known or reliably believed tocause disease in humans or other living organisms,(b) contains or is contaminated with a medicine that contains a biologically active
pharmaceutical agent, or(c) is a sharp, or a body fluid or other biological material (including human and animal
tissue) containing or contaminated with a dangerous substance within the meaning ofCouncil Directive 67/548/EEC on the approximation of laws, regulations and administrative
provisions relating to the classification, packaging and labelling of dangerous substances (b).
COSHH: Control of Substances Hazardous to Health Regulations.
CPD: Continual Professional Development.

CQC: Care Quality Commission. The health and social care regulator for England.

Cytotoxic and cytostatic: Classification of medicinal waste used in the List of Wastes
Regulations for medicinal products with one or more of the hazardous properties toxic,
carcinogenic, toxic for reproduction or mutagenic.
Defra: Department for the Environment, Food and Rural Affairs.

DH: The Department of Health. They lead, shape and fund health and care in England.

An Introductory Guide to Healthcare Waste Management in England & Wales

27

Duty of Care: When used in relation to waste management, this term refers to the statutory
responsibilities of individuals and organisations.
EA: Environment Agency. Regulator responsible for environmental regulation (including
waste) in England.
EU: European Union.

EWC: European Waste Catalogue (code).

Hazardous waste: Waste classified as hazardous waste by the Hazardous Waste Regulations
and the List of Wastes Regulations.
Healthcare waste (HCW): defined as any waste that result during a healthcare procedure.
Some of these wastes (known as clinical/infectious waste) may be hazardous to those thatcome into contact with them and are subject to stringent controls.
HSE: The Health and Safety Executive.

HTM 07-01: Otherwise known as the Health Technical Memorandum (HTM) 07-01: Safe
management of healthcare waste. This document is produced by the Department of Health andprovides detailed guidance on how to deal with healthcare wastes.
HWCN: Hazardous Waste Consignment Note.
LoW: List of Wastes (Regulations).

Medicinal waste: Medicinal waste includes expired, unused, spilt, and contaminatedpharmaceutical products, drugs, vaccines, and sera that are no longer required and need to bedisposed of appropriately.

NRW: Natural Resources Wales. Regulator responsible for environmental regulation (including
waste) in Wales.

28

An Introductory Guide to Healthcare Waste Management in England & Wales

Offensive waste: is waste that:(a) is not clinical waste,(b) contains body fluids, secretions or excretions, and(c) falls within code 18 01 04, 18 02 03 or 20 01 99 in Schedule 1 to:(i) the List of Wastes (England) Regulations 2005(d), in relation to England, or(ii) the List of Wastes (Wales) Regulations 2005(e), in relation to Wales;

Permit: (Environmental Permit) Approval or consent issued by the Environment Agency(England) and Natural Resources Wales (Wales) for a specified waste processing activity.

Pharmaceutically active: Pharmaceutically active medicines may be non-hazardous or
hazardous depending upon properties and include, but are not limited to, cytotoxic andcytostatic medicinal wastes (hazardous waste). Examples of non-pharmaceutically-active
products include saline and glucose.
PPE: Personal Protective Equipment.
RCN: Royal College of Nursing.

Sharps: Sharps are items that could cause cuts or puncture wounds. They include needles,
hypodermic needles, scalpels and other blades, knives, infusion sets, saws, broken glass, andnails.
SIC Code: Standard Industry Classification Code.
SLD: Structured Learning and Development.
UN: United Nations.

WM2: Technical document produced by the Environment Agency, Natural Resources Wales,
the Scottish Environment Protection Agency and the Northern Ireland Environment Agency toprovide guidance on the assessment and classification of hazardous waste based on the Waste
Directive definition of hazardous waste.
WTN: Waste Transfer Note.

An Introductory Guide to Healthcare Waste Management in England & Wales

29

Acknowledgements
The Chartered Institution of Wastes Management (CIWM) would like to thank all those whohave contributed to this guidance document and given their time to critically assess thework. The following members played an important role in contributing to the content of thisguidance document:
Sian Fisher, Catalyst Waste Solutions
Martin Foulser, SMDSAMaria Mahon, G W Butler Ltd
Matthew Smith, CIWM
Dr Terry Tudor, University of Northampton
Charles Wanjir, COHEMASDr Anne Woolridge, Independent Safety Services Ltd
The following members reviewed the final versions of this document:
Matthew Smith, CIWM
Pat Jennings, CIWM
Wendy Rayner, WR Environmental Consulting Limited
Julie Tate, Natural Resources Wales

The input of the members of the CIWM Healthcare Waste Special Interest Group is gratefully
acknowledged, as well as the members of the CIWM Journal Team for formatting the final
version of the document.

Disclaimer

This guidance document is intended to provide information to all those who produce
healthcare and healthcare type waste and/or are looking to become more informed on this
sector of the waste and resource management industry. It has never been the intention that
this document should be used for legal or public appeal cases.

Please note that the Environment Agency website is currently moving to the .GOV.UK website.
As a result of this, some of the links within this booklet may not work in future. Please see therecommended reading list, item 7, if any links do not work.
Published in April 2014
The Chartered Institution of Wastes Management,
9 Saxon Court, St Peter’s Gardens, Marefair, Northampton NN1 1SX
Tel: +44 (0)1604 620426, Email: technical@ciwm.co.uk & Twitter: @CIWM
30

An Introductory Guide to Healthcare Waste Management in England & WalesA picture of good health
Cromwell Polythene is a major supplier of waste management solutions
to the healthcare sector, including yellow and orange UN accredited andtiger stripe sacks for clinical waste, as well as a broader range of refuse
and recycling sacks, disposable gloves and aprons.
Our products are used by healthcare professionals and specialist waste collection
companies working in compliance with the latest European Waste Collection
legislation and we are active members of the Sanitary Medical Disposal Services
Association, (SMDSA).
And after more than 30 years in business, we’re delighted to say that Cromwell
Polythene is in the very best of health.

Cromwell Polythene Ltd.,
Orion Building, Seafox Court, Sherburn Enterprise Park,
Sherburn-in-Elmet, Leeds LS25 6PL
t: 01977 686 868 e: info@cromwellpolythene.co.uk
w: cromwellpolythene.co.uk