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ESTATES & FACILITIES
Managing waste effectively M
edical practices that produce five or more tonnes of clinical waste a year must carry
out a mandatory pre-acceptance waste audit annually.
The audit, under the Environment Agency’s EPR 5.07 guidance, ensures healthcare wastes are sent for the correct treatment and disposal.
According to the Chartered Institution of Wastes Management (CIWM), in addition to ensuring compliance with the Environmental Permitting (England & Wales) Regulations, there are several other benefits.
For example, audits can help identify specific locations where potentially hazardous wastes are being wrongly assigned (e.g. medicinal sharps being placed in clinical waste bags) and by identifying any potentially incorrect segregation, harm to employees and contractors that can be prevented.
The environmental benefits can also be significant. A 2011 freedom of information request on waste management by the Royal College of Nursing suggested annual savings of £5.5m if just 20% of incorrectly classified ‘infectious waste’ was reclassified as ‘offensive waste’, with its lower treatment and disposal costs.
Matthew Smith, co-ordinator of CIWM’s Healthcare Waste Special Interest Group, told NHE: “There is quite a lot that needs to be covered in the audit (see box out). It is a legal requirement under the Environment Agency’s EPR 5.07 document, so you have to make sure you have covered all the necessary aspects. It is not just the audit itself, but also the audit report afterwards, which the Environment Agency may ask to see. So you have to make sure everything is there.”
Auditing in action
Audits may be completed by NHS staff or an external party, such as a representative of the waste contractor or waste management consultants. But the person carrying out the audit must be suitably trained and competent with regards to healthcare waste management.
Smith, who recently shadowed an audit at a medium-sized acute hospital, said: “If hospitals are doing the audits themselves, it is important they have a good piece of guidance available to
48 | national health executive Sep/Oct 14 The minimum information required
• A list (or diagram) of the different wards, departments, or functional areas that exist within the premises, identifying those included in the audit; • The audit’s start and end dates, and description of the audit, the procedures employed, the auditors and their affiliation; • For each unit or area audited, identification of the waste items produced, the type (including colour), size and labelling of containers in-use, the segregation practices, contents of a representative number of each type of container; • The hazardous properties associated with the waste and its components (medicines, chemicals etc.); • Where relevant, the audit must include examination of the segregation of waste containers placed in departmental and main storage areas, and bulk containers (for example 770 litre carts); and • A summary report indicating the findings for each area in the producer premises, each waste stream produced there, highlighting any issues identified, including proposed waste descriptions and classifications derived from the audit findings for each waste stream.
help, like the one CIWM launched earlier this year.”
This is particularly important as the Environment Agency has the power to fine non-compliant sites.
Smith expected on his hospital visit that, considering it was a large site with several hundred patient beds, there would be an employee solely responsible for waste management. But his guide had multiple roles – head of waste management, head of security on the hospital grounds and in charge of parking and some aspects of estates management.
Smith added: “Multiple roles and workload can impact on the potential success of any waste management system put in place, for example the requirement to regularly engage with the staff and to encourage uptake of training.”
During Smith’s site visit he noticed ‘misclassification in action’, such as in the antenatal department where placentas were being disposed of in a yellow container, when they should have gone into a red-lidded anatomical container.
Relationships with the staff are important. “Because you’re perceived as an external auditor, you have to make it known that you’re helping them with their jobs, not being a burden,” he said.
Continuous training But continuous training can help, especially
as it is the staff who will be implementing waste segregation policies. “Staff are busy providing important care to patients, so waste management is not going to be at the top of their agenda,” he said. “But if you’re constantly nudging them in the right direction – by providing training that fits in with them, and is easy to understand – this will help develop best practice.”
He was confident that the CIWM guidance, which has input from a range of healthcare waste experts including practitioners, academics, and consultants, can help provide useful information to any hospital prior to undertaking a pre-acceptance waste audit.
Mat Crocker, head of illegals and waste for the Environment Agency, added that it is essential that producers of waste correctly segregate and describe their waste to ensure that it is managed correctly and gets to the right place.
“This guidance for producers of healthcare waste sets out how waste audits can help producers both to fulfil their requirements and to enable their waste management contractor to comply with their legal obligations,” he said. “The Environment Agency welcomes this publication and the work that CIWM has put into its production.”
Matthew Smith
FOR MORE INFORMATION W:
www.tinyurl.com/EA-waste-audit
Matthew Smith, co-ordinator of the Chartered Institution of Wastes Management’s Healthcare Waste Special Interest Group, talks to NHE about the need for continuous training.
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