Clinical And Offensive Waste Legislation

Please see the latest clarification from the Environment Agency for the digital waste tacking of Clinical and Offensive waste

Waste Tracking Principles: for offensive wastes

The purpose of this note is to clarify the requirements set out in the guidance document Healthcare Waste: Appropriate Measures for permitted facilities for some specific types of offensive healthcare wastes. This guidance sets out the standards that operators should meet to comply with their environmental permit. If an operator does not meet a specific requirement, they can propose alternative measures to the Agency setting out how they will achieve the same level of protection.

Offensive wastes from healthcare premises (EWC 18 01 04)

Packaging containing these types of wastes (e.g. tiger bags) need to be uniquely identified with a label or marked identifier of the producer (usually premises address if multiple premises), but bags do not need to be tracked individually. Where these offensive wastes are not sent directly for final disposal or energy recovery but are removed to a healthcare waste transfer station there needs to be a system in place to ensure that the waste operator complies with their environmental permit requirements for example, ensuring they know the length of time the bags have been on site so they meet the storage time limits. Such mechanisms for meeting the permit requirements should be justified as alternative measures for 18 01 04 offensive waste and set out in the facility’s operational procedure (management system). A pre-requisite to all of this is ensuring an up-to-date pre-acceptance audit is in place.

Offensive wastes from community (EWC 20 01 99)

These types of wastes would need to follow the procedures detailed above for 18 01 04 waste but should not be linked to an individual but to a service/Trust producing the waste.

Exceptions to the tracking requirements:

The tracking requirements detailed in the healthcare waste appropriate measures guidance do not apply to offensive wastes produced from washroom services. However, procedures must be in place to enable operators to ensure they meet all the requirements of their permit eg. storage time limits etc. Again, these should be set out in the facility’s operational procedures (management system).

All other healthcare wastes:

The expectation is that all other healthcare wastes received at a healthcare waste facility should meet the requirements set out in the Healthcare Waste Appropriate Measures for permitted facilities guidance document. Where specific measures cannot be met or are deviated from, an operator must propose and justify an alternative measure and have it agreed in writing with the Agency.