B2159 Health Technical Memorandum 07-01

Classification: Official
Publications approval reference: PAR38

England
Health Technical Memorandum

07-01: Safe and sustainable
management of healthcare
waste
20
22
ed
iti
on
Health Technical Memorandum 07-01: Safe and sustainable management of healthcare waste
Preface
About Health Technical • “Must” is used when indicating

compliance with the law.
Memoranda
• “Should” is used to indicate a
Health Technical Memoranda (HTMs) give recommendation (not mandatory/
comprehensive advice and guidance on the obligatory), i.e. among several
design, installation and operation of possibilities or methods, one is
specialised building and engineering recommended as being particularly
technology used in the delivery of suitable – without excluding other
healthcare. possibilities or methods.
The focus of Health Technical Memorandum • “May” is used for permission, i.e. to
guidance remains on healthcare-specific indicate a course of action permissible
elements of standards, policies and up-to- within the limits of the HBN or HTM.
date established best practice. They are
applicable to new and existing sites, and are
for use at various stages during the whole Typical usage examples
building lifecycle. • “All publicly-funded organisations
must ensure that all contracts
established to collect and treat waste
Language usage in technical conform to the Public Contracts
guidance Regulations.” [obligation]
In HTMs and HBNs, modal verbs such as • “All low voltage (LV) distributions
“must”, “should” and “may” are used to should be configured as TN systems.”
convey notions of obligation, [recommendation]
recommendation or permission. The choice • “Alcohol hand gels that do not
of modal verb will reflect the level of contain siloxanes may be rinsed out
obligation needed to be compliant. and the packaging recycled or placed
into the municipal waste stream.”
The following describes the implications
[permission]
and use of these modal verbs in HTMs/HBNs
(readers should note that these meanings “Shall”, in the obligatory sense of the word,
may differ from those of industry standards is never used in current HTMs/HBNs.
and legal documents):
This guidance is not mandatory (unless specifically stated). However, any departures/
derogations from this HTM – including the measures implemented – should provide
a degree of safety not less than that achieved by following the guidance set out in
this HTM.
ii
Preface
Project derogations from the While it is recognised that derogation is

required in some cases, this must be risk-
Technical Guidance assessed and documented in order that it
Healthcare facilities built for the NHS are may be considered within the appraisal and
expected to support the provision of high- approval process.
quality healthcare and ensure the NHS
Constitution right to a clean, safe and Derogations must be properly authorised by
secure environment. It is therefore critical the project’s senior responsible owner and
that they are designed and constructed to informed and supported by appropriate
the highest and most appropriate technical technical advice (irrespective of a project’s
standards and guidance. This applies when internal or external approval processes).
organisations, providers or commissioners
invest in healthcare accommodation
(irrespective of status, for example
Sustainability and “Net Zero
Foundation and non-Foundation trusts). Carbon” targets
The UK is leading the way on tackling
Statutory standards plus technical climate change and improving sustainability,
standards and guidance specific to NHS and the NHS is leading the way in England.
facilities:
In 2019, the UK became the first major
Health Building Notes economy to commit to net zero emission by
2050. In 2020, the NHS set out its intent to
Health Technical Memoranda support this ambition through its
‘Delivering a “Net Zero” National Health

Complete list of NHS estates-related
Service’ report (NHS England, 2020a). The
guidance
report sets a clear target for achieving a net
zero health service for direct emissions by
The need to demonstrate a robust process 2040 and indirect emissions by 2045.
for agreeing any derogation from Technical
Guidance is a core component of the In 2021, NHS England published supporting
business case assurance process. guidance for the NHS Estate in its ‘Estates
Net Zero Carbon Delivery Plan’, available to
The starting point for all NHS healthcare NHS staff via the Estates and Facilities Hub
projects at Project Initiation Document (PID) on the FutureNHS website, and further
and/or Strategic Outline Case (SOC) stage is guidance is planned over the coming years.
one of full compliance.
The NHS estate has a critical role to play in
Derogations to standards will potentially achieving net zero carbon emissions. It is
jeopardise business case approval and will vital that every opportunity is seized across
only be considered in exceptional the NHS to do so, and the NHS Estate is an
circumstances. A schedule of derogations area where direct and cost-effective action
will be required for any project requiring can be taken with a high degree of
external business case approval and may be confidence.
requested for those that have gone through
an internal approvals process.
iii
Executive summary
Health Technical Memorandum (HTM) 07-01 In line with NHS Clinical Waste Strategy,
provides a framework for best practice there is a need for the guidance to better
waste management across the UK to help reflect the principles of circular economy,
healthcare organisations and other environmental safeguarding, improved
healthcare waste producers meet legislative, social outcomes, and reducing our carbon
technical and policy requirements, as well emissions from the production/processing
as plan for future challenges and of our waste, as well as other new policies
opportunities. from across the waste, health and
environmental sectors. The impact of these
This guidance is applicable to all NHS Trusts is reflected in the revised document.
and commissioned service providers
including primary care providers, ambulance The new document supports the NHS’s drive
services and other community services. In to be a Net Zero health system, prioritising
addition, the guidance covers waste decarbonisation and circular economy
produced by laboratories and veterinary measures in alignment with Defra’s ‘A
surgeries. For ease, throughout the Green Future: Our 25 Year Plan to Improve
document, this spectrum of organisations is the Environment’ (2018a) and ‘Our waste,
referred to as “healthcare organisations”. our resources: a strategy for England’
Where reference is made to “NHS (2018b), as well as the NHS’s ‘Delivering a
organisations”, this relates to organisations “Net Zero” National Health Service’ (2020a)
including NHS trusts and primary care and ‘The NHS Long Term Plan’ (2019b).
providers that are subject to policies,
strategies and plans that only apply to NHS The revised document maintains the high
commissioned services. level of technical robustness of previous
versions but also integrates concepts related
This document has been produced to to sustainable waste management, the
replace the 2013 version of ‘Safe circular economy, and links to strategic
management of healthcare waste’. objectives.
This guidance is a best practice guide not Key changes:

only to the safe management of healthcare
waste, but also to the sustainable • strategic thinking, outlining the main
management of healthcare waste. points of the NHS Clinical Waste Strategy
with the overarching ambition of
Since 2013 there have been many eliminating avoidable waste, supporting
subsequent changes to environmental the drive to prevent offensive waste
legislation and regulation that need to be being incorrectly classified and
reflected in the new guidance. segregated as infectious waste in order
to improve the effectiveness of waste
iv
Executive summary
management systems, reduce costs and • there is a drive to develop in-house

move waste up the hierarchy. The workforce knowledge and capability to
following targets are set out: support an improvement in waste
management decisions
– 20% of waste segregated to be
sent to incineration, with only 4% • since the previous version there have
of that being hazardous/clinical been several pieces of new legislation
incineration and changes to existing legislation and
technical instruments. This document
– 20% of waste segregated to be reflects the latest technical practice,
sent to alternative treatment external guidance, and compliance
– 60% of waste segregated to be requirements
classified as offensive waste • innovation regarding waste
• promoting the circular economy and management solutions has been
improving carbon performance are key included, along with a defined process
topics running throughout this guidance, for better embedding opportunities
with the intention of promoting within the system
management techniques that actively • specific sectoral guidance has been
implement the waste hierarchy and removed from this version; previous
improve resource efficiency within versions containing sectoral guides were
the waste management system. often repetitive and sometimes
Opportunities to reuse, repurpose and contradictory. By streamlining the flow
recycle wastes and materials are of the document, the aim of removing
highlighted with reference to case repetition is achieved; the document
studies with a focus on minimising and summarises key sections for various
eliminating waste through green health sectors and includes guidance
procurement where specific to a particular sector.
• this document also includes actions
required to reduce the use of single-use The safe and sustainable management of
plastics, in alignment with Government waste is everyone’s responsibility, and it
policy, and support the commitment to starts before goods and services have even
be Net Zero across the NHS by 2050 been procured. This document is intended
to be the foundation for creating a better
• managing waste services effectively, the understanding within all staff groups of
revised document addresses the key their role in contributing to a safer, greener
principles in effective contract world. More detail is provided in Chapter 1
management and provides a checklist of on how each staff group and sector should
standardised activities that need to be refer to this document and the training
undertaken to monitor contractors. It needed for them is discussed in Chapter 6.
also considers the approach to
contingency planning in the event of
contractor failure
v
Acknowledgements
The following individuals and organisations have contributed to the development,

drafting and production of this guidance:
Alexandra Hammond, Head of Sustainable Procurement and Supply Chain at NHS England
Alyson Prince, Infection Prevention and Control Nurse Specialist, Archus Ltd
Anita Leite, Estates Energy and Waste Officer, West Suffolk NHS Foundation Trust
Dr Anne Woolridge, Technical Expert, Chartered Institute for Wastes Management and
Independent Safety Services Ltd
Ayse Gungor, Net Zero Policy Manager, Greener NHS Programme at NHS England
Cameron Hawkins, Head of Energy and Environment, NHS Property Services Ltd
Chris Davies, Southport and Ormskirk Trust NHS Trust
Christopher Lewis, Senior Environment and Facilities Management Advisor, NHS Wales
Shared Services Partnership – Specialist Estates Services
Dan Jacobs, Technical Author, Mott MacDonald Ltd
David McCabrey, Principal Engineer, NHS Northern Ireland
David McNeill, Principal Engineer, NHS Scotland
David Tucker, Waste, Sustainability & Energy Manager, Cambridgeshire & Peterborough
NHS Foundation Trust
David Wilson, Principal Engineer, NHS Northern Ireland
Debbie Cockcroft, Facilities Services Manager, East & North Hertfordshire NHS Trust
Dominique Baptiste, Facilities Waste Manager, Epsom & St Helier University Hospital NHS
Trust
Fiona Daly, National Deputy Director of Estates, NHS England
Grace Peel, Technical Author, Mott MacDonald Ltd
vi
Acknowledgements
Guy Carson, Publishing and Editorial, Archus Ltd
Helen North, Head of Frameworks and Engagement, Dangerous Goods Division,

Department for Transport
Joaquim Duarte, Senior Sustainable Waste Manager, University Hospitals Bristol and
Weston NHS Foundation Trust
Jock Graham, typesetting and editorial services
John Prendergast, Senior Editor, Archus Ltd
Keith White, Dangerous Goods Packaging Lead, Vehicle Certification Agency
Laura Harris, NHS Clinical Waste Strategy Development Lead, NHS England
Lenora Bond, Facilities Services Manager, NHS Property Services Ltd
Liam Hogg, Head of Net Zero Carbon Waste and Resource, NHS England
Matthew Boycott, Senior Programme Lead, Primary Care Commissioning, NHS England
Michael Rope, Head of Technical Guidance, NHS England
Neil Allen, Waste & Environment Manager, Bart’s Health NHS Trust
Nick Wilson, Technical Author, Mott MacDonald Ltd
Nigel Davies, Head of Estate Development, NHS Wales Shared Services Partnership –
Specialist Estates Services NHS Wales
Paul Chivers, NHS England
Paul Fernee, Team Leader – Hazardous Waste Transfer, Environment Agency
Paul Hinton, Head of Nuclear Medicine Physics and Quality Manager for Radiopharmacy –
Royal Surrey County Hospital, Guildford
Peter Chesney, Senior Advisor – Hazardous Waste Storage & Treatment, Environment
Agency
Richard Davies, Service Assurance Manager, NHS Property Services Ltd
Rose Gallagher, Lead Infection Prevention and Control, Royal College of Nursing
Sally Yates, Logistics & Waste Manager, Northern Lincolnshire & Goole NHS Foundation
Trust
Samantha Stanhope, Head of Sustainability, University Hospitals of Leicester NHS Trust
Sarah Griffiths, Technical Author, Mott MacDonald Ltd
Simon Picking, Estates and Facilities Manager, Northern Care Alliance NHS Trust
vii
Susan Grant, Principal Architect, NHS Scotland
Sushant Daga, Technical Author, Mott MacDonald Ltd
Wonett Hall, Policy Adviser, Dangerous Goods Division, Department for Transport
NHS England would also like to thank all those who took the time to comment and send
contributions during the scoping and technical engagement phases of this document.
viii
Contents
Contents
Preface��ii
About Health Technical Memoranda ii
Language usage in technical guidance ii
Project derogations from the Technical Guidance iii
Sustainability and “Net Zero Carbon” targets iii
Executive summary�� iv
Acknowledgements�� vi
1.0 Introduction��3
Structure of the document 3
Who should use this guidance? 4
Changes since the previous guidance 6
Sustainability and “Net Zero Carbon” targets 7
2.0 Strategic objectives��9
NHS Clinical Waste Strategy 9
Net Zero Carbon 11
Circular economy 13
Sustainable procurement good practice 17
NHS Supply Chain 19
Environmental impact and social outcomes 19
Policy links 21
3.0 P
rinciples of sustainable waste management��23
Waste hierarchy 23
Other key principles 27
4.0 Legislative framework��30
Key legislation 30
The importance of effective regulation 37
How to keep up to date 38
5.0 Technical approach��40
Non-clinical waste and resources 40
Clinical waste 43
Offensive waste 81
1
6.0 Management approach��84

In-house services 84
Contract management 91
Managing risk 93
Training95
Compliance98
Emergency preparedness 106
Appendix 1 – Technical�� 110
A1.1: Category A pathogen list 110
A1.2: Duty of care checklist 112
A1.3: WM3 hazards 113
Appendix 2 – Non-clinical waste and resource management principles �� 114
Appendix 4 – List of case studies�� 125
References�� 126
Legislation126
Approved Codes of Practice 128
International Standards 129
Health Technical Memoranda 129
Guidance, research and other resources 129
Useful websites 134
Abbreviations used in this document 135
2
1.0. Introduction
1.0 Introduction
1.1 Health Technical Memorandum (HTM) • clinical waste

07-01 ‘Safe and sustainable management of
healthcare waste’ provides a framework for • offensive waste
best practice waste management across the • hazardous waste and non-hazardous
UK to help healthcare organisations and waste
other healthcare waste producers meet
legislative, technical and policy • the circular economy
requirements, as well as plan for future • the waste hierarchy
challenges and opportunities.
• clinical waste segregation targets.
1.2 This publication replaces HTM 07-01
(2006) and its subsequent 2013 revision. 1.7 This guidance has been developed
based on the legislative, regulatory and
1.3 This guidance is intended to better sectoral environment within England. It
reflect the key principles in sustainable should therefore not be relied upon by any
healthcare waste management, and devolved nation. Where devolved nation
specifically that of the circular economy, legislation materially deviates from that of
environmental protection, improved social England, this has been highlighted in
outcomes, and reduced carbon emissions. shaded boxes for reference.
1.4 Additionally, this guidance also reflects 1.8 Reference is made throughout to
on and supports the implementation of the external documents, data sources and
NHS Clinical Waste Strategy. guidance; these are signposted or
hyperlinked. This is to minimise prescriptive
technical text where this is already provided
Structure of the document externally, avoiding the likelihood of
1.5 This HTM is split into two clear repetition, contradiction or duplication.
segments: one which provides context and
background information in Chapters 2 to 4 1.9 Case studies and practical examples of
and one which provides guidance on how sustainable healthcare waste management
to apply it, in Chapters 5 and 6. and circular economy application are
summarised in shaded boxes. Flow charts,
1.6 This HTM defines the following tables and illustrations have been used to
principal elements: summarise information where appropriate,
with the intention of avoiding extensive,
• healthcare waste prescriptive or duplicative text.
3
Who should use this individuals involved in or having specific

responsibility for managing waste for an
guidance? organisation providing NHS services.
1.10 The guidance has been developed to a However, certain chapters and sections are
level of technical detail to facilitate the applicable to a wider audience, as
compliant and safe management of summarised in Table 1.
healthcare waste. It is primarily targeted at
Table 1 Relevant chapters and sections for NHS roles
Typical NHS organisation role Relevant sections

Waste handling staff • Technical approach
Clinicians and other practitioners, including nurses, • Strategic objectives
doctors, dentists and optometrists • Principles in sustainable waste management
• Legislative framework
Procurement managers • Strategic objectives
• Principles in sustainable waste management
• Management approach
Healthcare organisation chairperson • Strategic objectives
Estates and facilities director • Technical approach
Waste manager and/or identified accountable • Strategic objective
individual • Principles in sustainable waste management
• Technical approach
Dangerous Goods Safety Advisor • Transport and Packaging
• Legislative Framework
NHS commissioners, including NHS England, NHS • Strategic objectives
Clinical Commissioning Groups and Integrated Care • Principles in sustainable waste management technical approach
Boards • Management approach
• Non-clinical waste and resources
• Primary care
General Practice (contract holder)/Primary Care • Strategic objectives
Networks (PCNs) and their staff (clinical and non- • Principles in sustainable waste management
clinical) • Technical approach
• Primary care
Pharmacists/pharmacy staff • Strategic objectives
• Primary care
Health and Safety staff • Technical approach
Primary care dentistry (contract holder) and their staff • Strategic objectives
(clinical and non-clinical) • Principles in sustainable waste management
• Primary care
4
1.0. Introduction
1.11 Specific sectoral guidance has not 1.12 Table 2 is a reference guide for the
been included in this publication. Key chapters and sections of HTM 07-01 which
sectoral considerations (where there is a are particularly relevant to each sector
material deviation from standard guidance) noted. Clinicians and other practitioners
have instead been flagged within the main from each respective sector should read the
body of the document, where applicable. applicable chapters and sections in full to
Specific sections have been included for familiarise themselves with what is required
radioactive waste, dental waste, community of them.
healthcare, ambulance services and primary
care.
Table 2 Healthcare sector quick reference
Sector
Chapter Subsection Ambulance Research Community Community General Practices Dental Practices
Services and Healthcare Pharmacies and Health Centres
Laboratory
1 All      
2 All      
3 All      
Environment and
     
waste legislation
Duty of care and
     
controlled waste
Environmental
     
permitting
Producer
     
responsibility
Hazardous waste      
Consignment notes      
European waste
     
catalogue
4
Controlled drugs      
Infection
prevention and      
control
Transport and
 X  X X X
carriage legislation
Health and safety
     
regulation
Importance of
     
effective regulation
How to keep up to
     
date
Non-clinical waste
     
and resources
Definitions and
     
waste types
Classification and
     
segregation
5
Colour coding and
     
storage
Transport and
     
packaging
Treatment, recovery
     
and disposal
5
Sector
Chapter Subsection Ambulance Research Community Community General Practices Dental Practices
Services and Healthcare Pharmacies and Health Centres
Laboratory
Radioactive waste X  X X X 
5
Dental waste X X X X X 
Introduction X X X X X X
Contract
     
management
Governance
X X X X  X
arrangements
Data recording,
monitoring and      
reporting
Community
6 X X  X X X
healthcare
Primary care  X  X  
Ambulance services  X X X X X
Managing risk      
Training      
Compliance      
Emergency
     
preparedness
1.13 Critically, this guidance is intended to Changes since the previous

reinforce the importance of accurate
healthcare waste segregation so that the guidance
targets and measures of success, set out in 1.15 This document includes updated
the NHS Clinical Waste Strategy, can be requirements of legislative and regulatory
achieved to help deliver a sustainable information. See Chapter 4, which sets out
healthcare waste system that is more the legislative framework, in particular key
resilient in the long term. Therefore, within legislation in paragraphs 4.1–4.44.
Chapter 5, a dedicated section has been
included to describe offensive waste 1.16 The guidance prioritises the themes of
(paragraphs 5.225–5.238) so that it can be decarbonisation and the circular economy in
clearly differentiated from infectious waste, alignment with Defra’s ‘A Green Future: Our
which is defined in paragraphs 5.55–5.57. 25 Year Plan to Improve the Environment’
(2018a) and ‘Our waste, our resources: a
1.14 Failure to implement the practices set strategy for England’ (2018b), and the NHS’s
out within this guidance may lead to non- ‘Delivering a ‘Net Zero’ National Health
compliance with the legislative framework, Service’ (2020a) and the ‘NHS Long Term
which could result in potential enforcement Plan’ (2019b).
action. Individuals with responsibility for
managing waste should ensure that they 1.17 These themes are outlined at the start
have systems in place to adhere to the of this guidance in Chapter 2, which sets
guidance, including arrangements for out the strategic objectives, and Chapter 3,
training staff who handle waste. Where which explains the principles of sustainable
localised procedures and training materials waste management. The intention of this is
are used, these should be consistent with to set the scene and provide context for the
this guidance. practical application of technical guidance
as set out in Chapter 5, emphasising the
6
1.0. Introduction
importance of waste minimisation through delivery of healthcare waste services. These

resource efficiency and green procurement. include:
1.18 In addition, a new Chapter 6 focuses • Chapter 12 “Immunisation of

on best practice in the management healthcare and laboratory staff” in
approach and has been included to help the UK Health Security Agency and
establish key principles associated within Department of Health & Social Care’s
the management of healthcare waste (2021) ‘Immunisation against
services. infectious disease’ (commonly referred
to as the “Green Book”).
1.19 Chapter 6 includes content on
• Chartered Institution of Wastes
emergency preparedness (paragraphs
Management (2014) ‘Pre-acceptance
6.143–6.158) which is intended to reflect on
waste audits’
key lessons from the response to the
COVID-19 pandemic. Whilst this is in part a • Defra’s ‘Statutory guidance: Waste
response to a particular pathogen, the duty of care code of practice’ (2018)
outflowing key principles are pertinent to
future business continuity planning. • Cabinet Office’s Policy paper
‘Procurement Policy Note 06/20 –
1.20 Since the publication of the taking account of social value in the
predecessor of this document, HTM 07-01 award of central government
(2013), there have been several changes to contracts’ (2020)
legislation. A consolidated summary of all • the Environment Agency’s ‘Waste
legislation relevant to the sustainable storage, segregation and handling
management of healthcare waste is appropriate measures – Healthcare
provided in Chapter 4 and reflects on waste: appropriate measures for
pertinent requirements for the permitted facilities’ (2021b).
consideration and planning of:
• the circular economy Guidance documents and best practice
standards are updated regularly. Make
• transport and packaging of dangerous sure to check that the most current and
goods up-to-date version is being used.
• hazardous waste management
• producer responsibility for batteries, Sustainability and “Net Zero
waste electricals and packaging
Carbon” targets
• the control of drugs
1.22 HTM 07-01 has been updated to
• the control of substances hazardous to support UK legislation to bring all
health (COSHH) greenhouse gas emissions to net zero
carbon, and to achieve the NHS target of
• persistent organic pollutants (POPs) net zero by 2045; it promotes sustainable
• management of radioactive waste and methods of waste management in
materials healthcare facilities.
• international waste shipments. 1.23 Healthcare provision is a significant

contributor to the UK’s carbon footprint. In
1.21 Similarly, since the publication of the 2019, this was estimated to be almost 5% of
previous guidance, best practice standards UK carbon emissions. Accordingly, all NHS
have also been introduced which affect the organisations have their part to play in
7
meeting net zero carbon targets alongside are due to patients and their visitors
other sustainability measures. travelling to access the NHS
1.24 In January 2020, the three steps the 3. Technology and Innovation: the
NHS would take during 2020 to tackle this panel will consider changes that can
problem were announced: be made in the NHS’s medical
devices, consumables and
1. Whole system commitment: NHS pharmaceutical supply, and areas the
England has established an expert NHS can influence such as the energy
panel to chart a practical route map sector, as the health service moves to
to enable the NHS to get to net zero using more renewable energy.
carbon
1.25 Chapter 2 of this document focuses on
2. Out-patient transformation: the NHS strategic objectives at play, and the key
Long Term Plan commits to better agendas of a safe and sustainable waste
use of technologies to make up to 30 management system, including:
million out-patient appointments
redundant, sparing patients • sustainable procurement
thousands of unnecessary trips to
and from hospital. It is estimated • waste prevention and avoidance
that 6.7 billion road miles each year • implementing a circular economy
• planning for sustainable disposal.
8
2.0 Strategic objectives
2.1 The purpose of this chapter is to

introduce a set of strategic themes, policy
NHS Clinical Waste Strategy
documents and other initiatives upon which 2.3 NHS England has produced
healthcare waste should be sustainably a clinical waste strategy to steer
managed. how decisions and future plans will be
made over a 10-year period from 2022.
2.2 Each of the documents, strategic The clinical strategy is referred to
initiatives and policies referred to in the throughout this document.
sections that follow have clear links to safe
and sustainable healthcare waste 2.4 Success in delivering the strategy will
management. The effective use and also support the wider net zero carbon
application of HTM 07-01 will therefore ambition for emissions by 2045.
help to support their implementation and
reinforce their relevance. 2.5 The strategy is underpinned by six
strategic priorities. Table 3 summarises each
priority and identifies what should be done
to help.
Table 3 Summary of strategic priorities from the NHS Clinical Waste Strategy
Strategic priority Summary What can be done

Use better data Utilise comprehensive, consistent Ensure that waste data is accurately recorded and regularly
data from across all healthcare reported into the locally/organisationally defined route
organisations to drive decision- (such as the Estates Returns Information Collection (ERIC)
making and proactive risk system).
management. Ensure that waste contractors provide waste data promptly,
and in accordance with contractual requirements.
Invest in a skilled Invest in developing a skilled and Ensure that the requirements of this guidance are fully
workforce diverse waste management workforce understood.
with appropriate support and defined Share knowledge and best practice with others.
career paths. Raise awareness of this guidance and seek specialist advice
when it is needed.
Improve our ability to Ensure all NHS staff understand and Ensure that the compliance requirements are fully
comply adhere to compliance requirements. understood and adhered to.
Regularly refer to and update a compliance checklist.
Maintain robust, auditable duty of care records.
Establish a commercial Support the standardisation of Correctly segregate clinical waste as set out in paragraphs
model that delivers contracting arrangements and 5.24–5.61 on classification and segregation, avoiding over-
better value develop a commercial model that classification of infectious waste.
supports healthy market conditions. Introduce offensive waste segregation and collection where
it is currently not in place.
Ensure that waste contracts are proactively monitored.
Use standardised waste service contracts and refer to best
practice in contract management.
9
Strategic priority Summary What can be done

Develop resilient Invest in clinical waste infrastructure Correctly segregate clinical waste as set out in paragraphs
infrastructure that to increase capacity and regional 5.24–5.61 on classification and segregation, so that each
meets future demand resilience and to support sustainable waste type is treated using an appropriate method,
waste processing practices. avoiding unnecessary or excessive transport of infectious
waste.
Promote on-site treatment and share surplus capacity with
other organisations where it is available.
Improve use of Proactively work to reduce harmful Always seek to avoid waste production, and to reuse, repair
resources and carbon emissions, improve local air quality, and remanufacture products (where safe and practical
impact and achieve the 2045 net zero carbon to do so) as described in paragraphs 3.2–3.19 on waste
target. hierarchy.
Encourage green procurement practices as described in
paragraphs 2.22–2.34 on the circular economy.
2.6 Six targets have been established to

measure progress in the implementation of
the strategy, as summarised in Figure 1.
Figure 1 NHS Clinical Waste Strategy targets
100% of NHS trusts and foundation trusts to have a

All NHS organisations introduce
dedicated waste manager role (at least 0.5 FTE) by
1 2 arrangements for the management of
2023, and 100% of other NHS providers have identified
accountable individuals for waste management the offensive waste stream by 2023
50% reduction in the carbon

All clinical waste generated by NHS
4 emissions produced from waste
3 organisations is regularly reported with
management by 2026, en route to an
80% reduction by 2028-32 a minimum of 95% accuracy by 2024
NHS providers achieve clinical waste The average net cost of clinical waste
5 segregation targets of 20:20:60 HTI, 6 management is reduced by 15%
AT and OW by 2026 by 2030
2.7 The target to introduce offensive waste • 20% of waste segregated to be sent
collections across all NHS organisations by to incineration, with only 4% of that
2023 is of critical importance, as is the need being hazardous/clinical incineration;
to correctly segregate healthcare waste see paragraphs 5.144–5.174 for further
based on its properties by 2026, as information
illustrated in Figure 2. The improper
management of offensive waste represents • 20% of waste segregated to be sent
a significant cost to the NHS, and helping to to alternative treatment
address this issue should lead to financial • 60% of waste segregated to be
savings as well as reduction in classified as offensive waste.
environmental harm.
2.8 The NHS Clinical Waste Strategy

imposes a set of critical targets to help
deliver a more sustainable waste
management system in the long term,
mainly through accurate segregation:
10
Figure 2 Clinical waste segregation targets
Strategy implementation
Improved waste segregation
Better compliance with HTM 07-01

20%
Better tracking of consignments
Accurate record keeping and reliable

data
20%
Full compliance with Duty of Care
requirements and compliance
checklist
Offensive waste stream fully

introduced 60%
Training and engagement strategies
Non-compliance notifications
Strategy implementation
2.9 The targets illustrated in Figure 2 can 2.11 The Department of Health and Social
be achieved by proper segregation based Care’s ‘Health Infrastructure Plan’ (2019)
on a clear understanding of each waste provides an opportunity to rationalise NHS
type. Chapter 5 has more information on organisations’ physical infrastructure by
classification and segregation and offensive providing better building fabric, new zero-
waste, including how to correctly identify carbon heating systems, and increased
and segregate each waste type. reuse and recycling of waste generated
through better segregation and the
disposal of carbon-heavy assets.
Net Zero Carbon
2.10 The ‘Delivering a “Net Zero” National 2.12 The supply chain is responsible for
Health Service’ report (the NHS Net Zero more than half of the NHS greenhouse gas
Plan, 2020a) outlines key points for five (GHG) emissions, with pharmaceuticals
focus areas in cutting carbon emissions: contributing an estimated 20% of this. The
NHS Net Zero Plan commits to direct
• NHS organisation interventions on procurement and more
broadly, to engage with the supply chain to
• travel and transport
eliminate waste by improving design and
• supply chain increasing reuse/recycling options when
considering the entire life cycle of the
• behavioural change product.
• digitisation.
11
2.13 The NHS is committed to achieving net Similarly, implementing circular economy
zero carbon emissions by 2045 across all approaches, for example through
Greenhouse Gas Protocol Scopes (direct and sustainable procurement, that replace
indirect; see https://ghgprotocol.org/). single-use products with reusable ones,
Figure 3 outlines the role healthcare waste reduces transport demand and emissions.
plays as an indirect source for major GHG
emissions. For further details, see 2.16 All employees, visitors and patients to
‘Delivering a “Net Zero” National Health NHS facilities should be made aware of the
Service’ (NHS England 2020a). importance of reducing energy
consumption and waste production.
2.14 From April 2028, suppliers to the NHS
will need to provide details of the carbon 2.17 An upskilled workforce will be needed
impact of the products and services sold to to achieve the interventions identified by
the NHS as part of the Supplier Net Zero the Net Zero Plan. Updating the curricula
Roadmap. and training of medical and healthcare
graduates and implementing local initiatives
2.15 Managing healthcare waste in a safe that have been proven to reduce waste are
and efficient manner, in compliance with vital in ensuring that the existing and future
the relevant legislation, contributes towards NHS workforces are fit for purpose.
reducing whole-life carbon emissions (see
Rizan et al. (2021) for further details). Any 2.18 Specific waste management training
failure to correctly segregate infectious should be provided to all employees.
waste from non-infectious waste means the Training should be tailored to specific
entire waste stream may be over-managed. positions, settings and needs where
Figure 3 NHS carbon footprint
12
practical, but should be in accordance with Circular economy

the technical requirements of this HTM. For
instance, all staff should be trained on 2.22 The difference between Figure 4 and
correct waste segregation, but not Figure 5 illustrates the shift that needs to
everyone needs training on handling or take place from “linear economy” thinking
transporting waste unless their role requires to a circular approach. A “linear economy”
it. limits opportunities to utilise resources for
as long as possible and places a burden on
2.19 Of NHS emissions, 5% are due to the waste management at the end of life of a
propellants used in metered dose inhalers product, especially for future generations.
and some anaesthetic and medical gases, in
particular desflurane and nitrous oxide. 2.23 Through the implementation of the
Green disposal of inhalers by incineration Social Value Model for all procurements
via hospital and community pharmacies is (paragraphs 2.39–2.51), there is an
the best way to avoid the leakage of potent opportunity to incorporate circular
greenhouse gases from used metered dose economy principles and measurement
inhaler canisters into the atmosphere. indicators into the full life-cycle of the
procurement of goods and services. See
2.20 Likewise, minimising the waste of ‘Applying net zero and social value in the
nitrous oxide by avoiding the atmospheric procurement of NHS goods and services’ on
release of nitrous oxide within ambulances the GreenerNHS website. Additional
and acute trusts, and having regular and resources are available to NHS staff via the
rigorous nitrous oxide manifold and piped NHS Central Commercial Function Hub on
nitrous oxide infrastructure audits, as per the Future NHS website.
HTM 02-01 – ‘Medical gas pipeline systems’,
are essential to reducing these emissions. Definition of a circular economy: a
circular economy aims to move beyond
2.21 Digitisation presents enormous the traditional concept of a “take, make,
opportunities in providing cheaper, more waste” society to one that decouples
effective and efficient care. However, the economic activity from the consumption
introduction of technological advancements of finite resources and designs waste
will increase the quantities of waste out of the system. It is based on three
electrical and electronic equipment (WEEE) principles:
in the future. Procurement options of
leasing or take-back schemes, and inherent • regenerate natural systems
design that allows for repair for longevity,
can assist in managing the anticipated • design out waste and pollution
exponential growth of WEEE waste.
• keep products and materials in use
Figure 4 Linear economy
Infinite
Infinite Resource regenerative
resources Production Distribution Consumption Disposal
extraction capacity of the
Earth
Take Ma ke W a s te
13
Figure 5 Circular economy
Minimal use Design for

Design for of materials durability Cradle to
disassembly cradle
Material
recycling
Recyclable
materials
External
re-use
Circular
Disassembly
Economy technologies
Re-use and
re-deploy Principles
Bio-degradable
materials
Closed Loop
recycling
Reduced Hiring &

packaging Collaborative Incentivised leasing
consumption return
* Based on definition by the Ellen EXEMPLAR SCHEME:

MacArthur Foundation
East Staffordshire Clinical Commissioning
Group ran a “What a Waste” campaign
2.24 For circular economy examples, case
to promote optimisation of repeat
studies and further guidance, see the NHS
prescriptions to prevent waste.
Supply Chain webpage (https://www.
Pharmacies, local hospitals, GP practices
supplychain.nhs.uk/sustainability/waste-
and community teams were encouraged
and-the-circular-economy/) on waste and
to work with patients to identify
the circular economy.
medicines no longer required, and
patients were educated on efficient use
Sustainable procurement of medicines and medical devices such
as inhalers. The campaign resulted in an
2.25 Sustainable procurement is the
average saving of £60 per patient per
purchasing of products and services that
year.
deliver environmental and social value, and
is fundamental in applying the circular
economy and waste hierarchy. It involves
agreeing contractual measures with
suppliers and contractors to deliver EXEMPLAR SCHEME:
environmental benefits, such as waste
prevention, packaging reduction and take- The Hospital Caterers Association
back of end-of-life products for supported WRAP in developing guidance
reprocessing. for the prevention of food waste in
14
the healthcare sector. The guidance • liaising with suppliers to assess

identifies opportunities for prevention alternatives to existing packaging
of food waste and the associated cost practices
savings, including effective menu
planning. • checking the environmental claims
of manufacturers and suppliers, such
as recognised accreditations and
2.26 NHS England’s ‘Net Zero Supplier
schemes
Roadmap’ (2020) sets out the key milestones
required by 2030 that the NHS expects from
suppliers of goods and services.
CONSIDER: opportunities for change
2.27 The NHS has developed the Evergreen within your department. When
Supplier Framework, which allows suppliers procuring a service or product, ask the
to demonstrate their progress against the following questions:
Net Zero Supplier Roadmap through a
simple and cost-free self-assessment. The • Is the current product or service fit
framework will be piloted in 2022, and for purpose? What needs to change
available to all suppliers in 2023. to ensure best outcomes for patients
and staff?
2.28 The NHS Clinical Waste Strategy is clear
that procurement plays a vital role in • What can be done to eliminate waste
working towards the target of reducing or the use of single-use items? Does
waste arisings by 15% by 2030 because it the potential new provision impact
helps control the first step of the waste waste management requirements
hierarchy (prevention). When considering (space for storage and/or collection
procurement options, attention should be provisions)?
made to reducing product demand,
• Can suppliers reduce packaging or
reviewing options to reduce consumption,
implement circular economy principles
and identifying opportunities for reuse,
as part of the new provision?
redistribution or refurbishment.
• Does the manufacturer or supplier
2.29 The 5 Rs approach, as explained in
note any recognised accreditations or
paragraph 2.35, should be followed to
parts of relevant schemes? Can these
reduce consumption and subsequent waste.
be verified?
Other examples of measures are provided
below to further limit the end-of-life • (from 2023) Is the supplier signed
impacts of the use of procured products. up to the Evergreen Supplier
Framework? If so, what level is the
CONSIDER: supplier?
• carrying out trials and pilot schemes • Are there provisions, services and
to assess whether a product is fit for training/awareness to upskill and
purpose. retain colleagues for as long as
possible within the healthcare
• additional waste management setting?
requirements (storage and collection
provisions). • Are there good examples of similar
products or services being procured
sustainably?
15
2.30 Innovation in waste prevention and towards a more circular economy. The key
sustainable products is supported by Defra’s areas include:
‘Our waste, our resources: a strategy for
England’ (2018b). Developments in • resource efficiency (using resources
sustainable packaging and improved use of more efficiently for a greener, more
products and services should be followed to competitive economy)
identify opportunities to apply the key • raw materials (ensuring our use of raw
principles of sustainable waste materials does not deplete the
management. Further information on planet’s resources)
innovations and funding support can be
found on the UK Research and Innovation • consumption (providing transparent
(UKRI) website, which includes the Small information to consumers, enabling
Business Research Initiative. them to make greener choices)
• eco-innovation (enabling green
Legislative context growth)
2.31 The European Commission adopted • production (promoting greener
the new Circular Economy Action Plan products and supporting greener
(CEAP) in 2020. This builds on the EU companies and organisations)
Circular Economy Package which came into
force in July 2018. All four UK nations are • waste prevention and improved waste
committed to following the EU Circular management.
Economy Action Plan, aiming to drive action
2.33 Defra’s ‘Waste Prevention Programme
further up the waste hierarchy (see Chapter
for England: Towards a resource efficient
3 and paragraphs 2.22–2.34 on working to
economy’ (consultation version; March 2021)
move to a more circular economy).
aims to build on Defra’s ‘Our waste, our
2.32 The plan includes a range of measures resources: a strategy for England’ (2018b)
and legislative proposals to boost and embeds a circular economy approach to
sustainable growth and transition Europe ensure that products and goods remain in
circulation for as long as possible at their
highest value. It recommends that
EU Circular Economy Action Plan and Reuse Targets
Managing waste in a more efficient manner is the first step towards a more circular
economy, where most if not all products and materials are recycled or reused
repeatedly. The EU Circular Economy Action Plan outlines a common recycling/reuse
target of 65% of packaging waste by 2025 and 70% by 2030. There are separate targets
for specific materials:
By 2025 By 2030
All packaging 65% 70%
Plastic 50% 55%
Wood 25% 30%

Ferrous metals 70% 80%
Aluminium 50% 60%
Glass 70% 75%
Paper and cardboard 75% 85%
16
government bodies, including the NHS, 2.34 Applying circular economy principles,
should extend their buying standards to in which the way that healthcare products
demand more in terms of the recyclability are consumed and disposed of is
of materials and recycled or reused content. transformed, could help ease pressure on
the sector by saving money.
WALES
Key areas where circular economy
The Welsh Government’s circular principles can be applied to healthcare
economy strategy; ‘Beyond Recycling: A waste management include:
strategy to make the circular economy
in Wales a reality’ (2021) aims to reduce • reducing consumables, in particular
the material and consumption carbon single-use plastics
footprints of core services such as health
and social care. • prioritising reusable equipment
over single-use, leasing or hiring
This includes the ‘NHS Wales equipment where appropriate
Decarbonisation Strategic Delivery Plan’
which was published in March 2021 • purchasing remanufactured devices
and sets clear targets to reduce the
amount of waste produced and increase • refurbishing furniture or equipment
recycling.
• digitalisation over print (where
possible/applicable)
SCOTLAND • purchasing materials that are
recyclable and composed of recycled/
Many of the Scottish Government’s reused content.
circular economy targets and policy
commitments align with, and already
go beyond, the requirements of the Sustainable procurement
CEAP. See the Scottish Government’s
‘NHS Scotland Climate Emergency & good practice
Sustainability Strategy 2022–2026, 2.35 NHS Procurement has developed the
Consultation Draft’ (2021) for details. “5 Rs” to guide sustainable procurement
good practice as summarised in Figure 6. It
provides a framework for considering waste
minimisation and materiality in purchasing
decisions.
17
Figure 6 Five Rs of sustainable procurement
As a general rule, consider the ‘5 Rs’ of sustainable procurement in this order:
1. Reduce: Can you do without the

product? Are you buying the correct Reduce
amount?
2. Reuse: Can you buy reusable

Reuse
products instead of single use?
3. (Buy) Reprocessed: Can you buy
reprocessed or refurbished? Can a
Reprocessed
product be repaired? Can the product
be taken back by the supplier at end of
life for repurposing? 4. (Buy) Renewable: What is the
Renewable
product made of? Are the sources
renewable?
5. (Buy) Recyclable: Is the product Recyclable

recyclable?
EXEMPLAR: Reduce: EXEMPLAR: Reprocess:
The ‘Gloves are off’ campaign by Great Imperial College Trust established
Ormond Street Hospital NHS Foundation endoscope reprocessing units at
Trust (GOSH) addressed the over-use of Hammersmith and Charing Cross in
non-sterile gloves through education 2012, with St Mary’s following in 2014.
and training. Staff are now following These facilities now reprocess more than
evidence-based practice rather than 40,000 scopes a year. Activity is growing
wearing gloves out of habit, leading to a at 5% a year.
30% reduction in examination gloves.
EXEMPLAR: Reuse:
EXEMPLAR: Renewable:
Mid-Essex Hospital Trust led an in-
hospital walking aid reuse scheme. After Skåne region, Sweden, healthcare
achieving a 40% return rate at its pilot procured biopolymer aprons with 91%
site, the scheme was expanded to a renewable content and materials sourced
second hospital. Collectively some 3000 locally, resulting in a reduced number of
items worth £27,000 are reused each disposable aprons used and disposed of.
year, with additional income generated
from metal recycling of damaged items, EXEMPLAR: Recyclable:
helping to take them out of circulation
and improving patient safety. Reuse Automedi, a UK-based company,
schemes also use third-party service produced an on-site manufacturing
providers. NHS staff can access further machine to make healthcare equipment
information on reducing scope 3 directly at the point of care from
emissions via the ‘How To Guides’ on the recyclable plastics. Use of the machine
NHS Central Commercial Function Hub removes delivery emissions, increases
on the Future NHS website. plastic recycling, and prevents
equipment shortages (note that this
process requires a suitable permit).
18
NHS Supply Chain Research has found that

2.36 NHS Supply Chain and procurement remanufacturing devices can result in up
managers are key in selecting providers of to 50% cost savings per product, reduced
products and services who are committed waste to landfill and incineration, and
to improving the way the NHS consumes reduced CO2 emissions by 50% per device
and disposes of goods. (Schulte, Maga and Thonemann, 2021).
2.37 Partnering with suppliers who are

developing innovative ways to improve the Online marketplaces such as Warp It:
environmental performance of their Reuse Network provide a platform
products will be vital to transitioning to a where hospitals can identify surplus
circular economy and implementing the equipment on a regional and national
waste hierarchy (see Chapter 3). level.
2.38 Refurbishing rather than replacing

equipment is another important part of a Environmental impact and
circular economy. By extending the useful
life of existing equipment rather than
social outcomes
buying new, health systems can reduce
procurement costs and waste.
Preventing environmental impacts
2.40 Healthcare organisations must comply
2.39 NHS Supply Chain operates a number with relevant legislation to prevent or
of reuse, refurbishment and repurposing reduce environmental harm. Incorrect
frameworks, including re-upholstering old storage, handling and treatment/disposal of
furniture, repurposing single-use medical healthcare waste could lead to
devices, and supplying several environmental pollution which could
remanufactured products. Local NHS Supply expose non-compliant Trusts, organisations
Chain customer relationship managers or individuals to breaches in key legislation.
should be contacted for more information
about these initiatives. 2.41 Harmful substances can enter the
environment through improper waste
Figure 7 P
otential environmental impacts from improper management, as illustrated in Figure 7.
waste management
Injury Littering
sharps injuries due to waste enters the
incorrect use of environment from staff,
receptacles, incorrect patients and visitors
use of PPE, unsecure littering, and from
storage of waste unsecure transportation
resulting in slips and from collection point to
trips waste facilities
Odour and air Contamination

pollution unsecure storage and
infrequent collection poor handling of wastes
and unsecure storage can result in leaks and
of waste can lead to spills of waste, lack of
odour, waste effective reporting of
management facilities pollution incidents could
can increase air result in ineffective
pollution through non- clearing of waste
compliant emissions substances
19
2.42 Eliminating and minimising the use of • delivery optimisation and use of low/
harmful substances in products used in zero carbon vehicles (also applicable
healthcare facilities is an effective measure for waste management logistics)
in minimising the environmental impact of
healthcare waste, also helping to • sourcing materials from and
implement the circular economy. manufacture products within the UK
(or relevant region) to reduce carbon
2.43 Where the use of products with emissions and improve supply chain
harmful substances cannot be avoided, their transparency
use, storage, handling, decontamination/
cleaning (if applicable) and waste • reduction of single-use plastics and
management must be undertaken in packaging and increase recyclability
accordance with manufacturer’s of products
instructions, legislation and relevant
technical guidance to prevent exposure to • initiatives to reduce environmental
the environment and people. impact with the redesign of the
product or service
2.44 Where waste cannot be avoided it
should be managed in a manner that • selection of products with no
minimises environmental harm. It is of harmful substances (including in the
particular significance for healthcare waste packaging)
given the fundamental environmental and
health risks associated with managing (and • selection of products with smaller
needing to control) potentially hazardous quantities of harmful substances
substances and infectious wastes.
• applying an effective stock control
2.45 The potential environmental hazards system to limit the number of
posed by healthcare products can remain products with harmful substances
present when the products become waste. stored on site.
Hazards may range from those that pose
little to no environmental risk, to those that 2.47 A common and significant hazard is
may cause significant environmental persistent organic pollutants (POPs). These
damage (such as high levels of toxicity, are chemical substances that are harmful
environmental persistence and because they break down slowly and are
bioaccumulation potential). able to remain in the environment,
meaning they can enter food chains.
2.46 Environmental hazards should be
indicated on product packaging, and on 2.48 The manufacture, sale and use of
relevant safety data sheets (SDSs). products containing POPs is now banned in
the UK (although already purchased
When procuring or purchasing products may be used). Commonly known
healthcare products, consider the POPs include DDT (insecticide),
following approaches to help minimise polychlorinated biphenyls and dioxins.
potential environmental harm and Plastic components of WEEE may also
improve environmental performance contain POPs. See the Environment
during a procurement and in the Agency’s webpage “Classify different types
contract management phase: of waste” on how to classify WEEE .
2.49 Wastes containing POPs, or any other

hazardous substance, must be completely
20
destroyed or irreversibly transformed at an weighting of 10% of the total score in

authorised disposal or recovery site. For tendering evaluation to be dedicated to net
further guidance, see relevant EA guidance zero and social value; this is applicable to all
notes. procurements, regardless of size. See
‘Applying net zero and social value in the
Exceptions to the ban include POPs procurement of NHS goods and services’ on
used for laboratory-scale research and the GreenerNHS website. Additional
use of products where POPs occur as an resources are available to NHS staff via the
unintentional trace contaminant. NHS Central Commercial Function Hub on
the FutureNHS website.
Social outcomes
Policy links
2.50 Sustainable waste management
2.53 Defra’s 25-year Environment Plan (‘A
programmes contribute to the overall
Green Future: Our 25 Year Plan to Improve
health and wellbeing of communities. The
the Environment’, 2018a) embodies the UK
waste management decisions made have a
Government’s aspirations for protecting
societal impact and therefore it is important
and enhancing the natural environment
to consider not only onward waste
with the intention to “leave our
management methods and destinations,
environment in a better state than we
but the suppliers, contractors and re-
found it”. The goals set have far-reaching
processors engaged in the whole supply
implications for the NHS, covering areas of
chain.
environmental concern from waste
2.51 The Public Services (Social Value) Act reduction, to minimising single-use plastics,
2012 requires people who commission to implementation of the 5 R’s for
public services to think about how wider sustainable procurement.
social, economic and environmental
2.54 The NHS has its own separate targets,
benefits can be secured. PPN 06/20: ‘Taking
outlined in Strategic Objectives, which if
account of social value in the award of
achieved, help attain the goals of Defra’s
central government contracts’ (Cabinet
Environment Plan.
Office, 2020) is an addition to the Public
Services (Social Value) Act, which provides a
model to enable the evaluation of net zero Relevant Environment Plan targets:
and social value when awarding contracts,
• zero avoidable waste by 2050
as summarised in Table 4.
• eliminate
avoidable plastic waste by
2.52 The NHS has adopted the Social Value
end of 2042
Model, which requires a minimum
Table 4 The Public Services (Social Value) Act – key social themes and policy outcomes
Theme Policy outcome

Fighting climate change • Effective stewardship of the environment.
Tackling economic inequality • Create new business, new jobs and new skills.
• Increase supply chain resilience and capacity.
Equal opportunity • Reduce the disability employment gap.

• Tackle workforce inequality.
Wellbeing • Improve health and wellbeing.

• Improve community integration.
21
• meeting all existing waste targets set sustainable development and reduce use of
by Defra natural resources. Key to this will be
delivering improvements, including
• substantially reducing and, where reductions in single-use plastics, throughout
possible, preventing all kinds of the entire NHS supply chain, reducing waste
marine plastic pollution – especially by sharing best practices across various
material that came originally from disciplines, and increasing reuse and
land. recycling through better classification and
segregation.
2.55 Defra’s ‘Our waste, our resources: a 2.57 The ‘Health Infrastructure Plan’
strategy for England’ (2018b) sets out (Department of Health & Social Care, 2019)
guidance on minimising waste, promoting requires the NHS to better understand the
resource efficiency and moving towards a cost of its estate, with comprehensive,
circular economy. The strategy helps direct accurate and comparable information that
the NHS in taking actions towards a longer- underpins decision making. This necessitates
term view on eliminating avoidable plastic improvement in waste data collection
waste, doubling resource productivity, and (see paragraphs 6.1–6.50) to support
eliminating all avoidable waste by 2050. development of appropriate strategies that
This is to be supported by research and reduce carbon emission from storage,
innovation along with improved data transport and treatment of waste.
monitoring and evaluation.
2.56 The NHS Long Term Plan (2019b)

requires the NHS to lead by example in
22
3.0 Principles of sustainable waste management
3.0 Principles of sustainable

waste management
3.1 There are several key principles waste is generated, dealing with it in a way
associated with well-defined and that will help to achieve circularity and
sustainable waste management. They form sustainable development.
the foundation of short-, medium- and
long-term waste management decisions 3.3 Waste management in the NHS should
and should be used as the basis upon which be driven by and assessed against
healthcare waste is managed, and good compliance with the waste hierarchy and
practice applied. the NHS’s own targets, to be accomplished
by 2030, as illustrated in Figure 8.
Waste hierarchy 3.4 The waste hierarchy prioritises the

3.2 Sustainable waste management means different steps that should be taken to
using resources more efficiently, reducing manage waste, with step 1 being the
the amount of waste produced and, where optimal solution and step 7 the last resort.
Figure 8 Waste management hierarchy and NHS 2030 targets
23
3.5 Avoidance and prevention mean • extending the life of equipment,

limiting the demand for products and through regular maintenance and care
material resources, thereby preventing the
generation of waste. It is the best way of • educating healthcare staff in the
implementing a circular economy. There are efficient use of products and
a number of examples of good practice: materials, such as medical equipment,
paper, food etc to prevent generating
• good storage and stock rotation to avoidable waste.
use products prior to expiration
3.6 NHS staff and contractors must take
• going digital and changing practices steps to prevent waste generation and
to reduce the use of materials, such as minimise situations where waste cannot be
replacing the need for film for X-rays avoided. Staff must keep up to date with
by converting to digital imagery, or current waste prevention programmes at
implementing community hubs to organisational level and across the NHS; in
minimise unnecessary in-person turn identifying whether a product is
patient visits and interactions, thus needed and used appropriately.
reducing waste generation
3.7 Figure 9 sets out the steps to follow to
• purchasing goods as a service can
help minimise unnecessary product use and
provide more robust, durable items,
maximise resource efficiency. For PPE and
encouraging repair, remanufacture
medical products, an evidence-based
and disassembly for recycling at the
approach should be applied for the use of a
end of life
product, such as the ‘Gloves are off’
• purchasing safer alternative products campaign by Great Ormond Street Hospital
with no or fewer hazardous NHS Foundation Trust.
substances
3.8 Where product use is necessary, the
• designing out waste by using effective NHS is currently exploring opportunities for
dispensers that prevent taking more safe, sustainable and cost-effective reuse of
than required, for example for gloves PPE, such as masks. The NHS is collaborating
and wipes with industry, academic partners,
• sourcing products derived from healthcare providers and government
recycled materials, including bodies such as DHSC to couple innovation
packaging with evidence-based IPC best practice.
• inventory controls to reduce purchase 3.9 For details on reducing waste through
of surplus products procurement, see further information on
sustainable procurement in Chapter 2.
• prioritising use of reusable products vs
single-use products, such as swapping 3.10 Correct segregation of waste helps to
disposable cleaning wipes with use of maximise opportunities for reuse, recycling
handcloths and recovery, and helps to enable effective
and safe management of waste. Further
• procuring products and equipment
detail on classification and segregation is
with less packaging
available in Chapter 5.
• procuring alternatives to single-use
items, where safe to do so
• use of equipment or processes that
require fewer resources
24
Figure 9 Step process to minimise product use
Consider the What is the

Do you need the
following before minimum quantity
product?
using a product needed?
Refer to
Refer to Is a reusable
instructions to
instructions for alternative
prepare for reuse
correct use available?
(if applicable)
EXEMPLAR: EXEMPLAR:
Leeds’ St James’s Hospital’s Intensive St Mary’s Hospital, Isle of Wight,

Care Unit took part in a waste engaged with Warp It, an online
segregation and recycling project which reuse network for large organisations,
involved more staff undertaking training to prioritise procuring second-hand
and attending briefings to encourage furniture. Through the service the NHS
correct waste segregation. The scheme has also provided medical equipment
resulted in improvements to segregation and hospital furniture for reuse overseas,
between domestic and offensive waste. including in rural hospitals in Sri Lanka.
EXEMPLAR: RECIRCULATE: Preparing for reuse

checklist:
NHS Property Services’ website provides
printable posters and schematics as 1. Refer to the Medicines and
resources for correct segregation of Healthcare Products Regulatory
wastes generated for their tenants (NHS Agency’s (2021) guidance ‘Managing
properties). medical devices’.
2. Operate an effective return scheme

EXEMPLAR: for patients’ medical equipment, such
as crutches and wheelchairs.
University Hospitals Coventry and
Warwickshire NHS Trust changed the 3. Follow the 5 R’s of Sustainable
types of containers it used for sharps Procurement when procuring items
from disposable containers to reusable (see paragraph 2.35).
sharps bins which can last for 10 years.
4. Follow decontamination and
The scheme resulted in savings of
reprocessing procedures, and ensure
approximately £20,000 per year.
products are cleaned after use.
5. Make routine checks to identify need

for maintenance or repair.
25
6. Carry out maintenance and repair 3.13 When planning to reuse a material
products as soon as possible when that could be a waste, make sure to check
damaged/not working. whether End of Waste (EoW) status applies.
Quality protocols are available for a
7. Train maintenance staff to repair on selection of waste types that have been
site, or utilise third-party services. agreed as meeting the Environment
Agency’s EoW status. For all other waste
8. Arrange for reuse as soon as types, refer to the end of waste test
practicable, to avoid demands on guidance to confirm whether the waste can
storage. meet EoW status.
9. Provide a suitable storage area for Recycling good practice:

temporarily storing items pending
preparation for reuse on-site or • Procure products made of recyclable
collection. material, in recyclable packaging, and
ensure the waste can be collected on-
10. P
rocure products or equipment from site
suppliers who provide rental schemes
and/or offer cleaning/sterilizing and • Place separate bins for dry recyclables
repair services. to collect waste such as glass,
cardboard, plastic. Review NHS
11. P
rocure products and equipment Property Services’ general waste and
that is easily disassembled for repair recycling information for waste types
or refurbishment. suitable for recycling collection
12. A
ssess whether reuse is suitable on • Reusable healthcare textiles at the
site before redistributing elsewhere. end of their working life may be
13. Refurbish items or equipment. suitable for recycling for use in a non-
healthcare setting
For textiles: Ensure efficient logistics to
collect and deliver to laundry services, • Some clinical wastes are suitable for
and check the services have capacity. recycling following treatment.
Laundry services must be in line with Note: Always check waste contractor
HTM 01-04 – ‘Decontamination of linen restrictions on collecting potentially
for health and social care’. recyclable clinical waste from healthcare
settings. Many cannot accept wastes
3.11 “Recirculate” is when waste cannot be from a healthcare setting, such as
prevented and products can be considered disposable face masks.
for reuse, where suitable. The steps listed
above can be followed to ensure effective 3.14 “Generate for energy sources” (see
preparation for reuse, which plays an Step 5 in Figure 8) is the processing of
important role in preventing the generation wastes for the generation of energy and/or
of avoidable waste. recovery of other resources (water, heat,
material, nutrients) and should be
3.12 “Recycling” is turning waste into a
considered if reuse and recycling are not
new substance or product. Recycling should
feasible.
be the last resort for recovering material
from waste, because it usually entails using 3.15 Energy from Waste (EfW) facilities
resources and energy in generating a new produce energy (and sometimes heat), and
product.
26
also recover metals from bottom ash.

Bottom ash can also be recycled into EXEMPLAR:
aggregate, for use in construction. EfW
The Somerset NHS Foundation Trust
should be the most commonly used option
collects food waste separately as part
for offensive waste and non-recyclable
of the waste management service. Food
domestic waste because it provides an
waste from wards is removed from
opportunity to recover energy and
patient plates into caddies placed on
resources.
wheeled trolleys and taken to a central
3.16 Reducing food waste and disposing of waste storage area. The food waste
it in a more environmentally friendly is sent for anaerobic digestion, which
manner not only reduces carbon emissions generates energy.
but has also resulted in large cost savings.
When opportunities for reduction of food 3.19 Landfill is the last option for
waste have been exhausted, food waste management of healthcare waste.
from healthcare facilities should be Landfilling secures waste in one location;
collected for recovery, to avoid however, there is finite capacity, and it
biodegradable waste entering landfills. It contributes to GHG emissions from
can be treated using two main methods: decomposing of biodegradable waste.
Moving waste away from landfill will also
• anaerobic digestion (AD; help achieve net zero carbon targets.
decomposition in the absence of
oxygen), which generates biogas to
produce heat and electricity, and Other key principles
produces solid and liquid digestate
3.20 There are a number of other key
(fertiliser)
principles that underpin sustainable waste
• composting (decomposition in the management and circular economy
presence of oxygen) to produce thinking. Figure 10 summarises these
compost. principles.
3.17 Appendix 2 sets out further details on 3.21 By managing healthcare waste in a
other treatment and recovery options that safe and sustainable manner now,
are available. precautions are actively being taken against
potential environmental damage or harm to
3.18 Management options for the human health in the future.
treatment, recovery and disposal of clinical
waste are discussed in Chapter 5. 3.22 Correct application of the proximity
principle can enhance the ability of the NHS
EXEMPLAR: to achieve its net zero carbon targets by
improving on-site resilience and reducing
London North West University Health transport emissions.
NHS Trust, in collaboration with their
waste contractor, has implemented 3.23 Those involved in making decisions
training on correct segregation to about how waste is collected and where it
facilitate sending offensive waste to is managed should therefore seek to ensure
EfW facilities to produce approximately that it is treated or disposed of at the
8 MWh of energy per year, equivalent to closest compliant and economically viable
providing power to 35 houses. location.
27
Figure 10 Key principles in sustainable waste management
Precautionary principle
Precautions should be taken at the earliest opportunity to avoid possible environmental damage or harm to human health
Proximity and self

Polluter pays and ‘producer responsibility’
sufficiency
Promote the integration of environmental costs associated with goods and supplies
Waste should be treated or disposed of throughout their lifecycle into the market price of the products.
as near as possible to the point where it Businesses that manufacture, import and sell such products are responsible for their
is generated in order to avoid end-of-life environmental impact.
unnecessary transport.
Environmental
sustainability and the Prior informed
Reducing hazardous
circular economy consent
substances
Environmental harm associated with a Designed to protect public health and
healthcare products can be reduced Making manufacturers and distributors the environment from hazardous waste.
without compromising its usefulness. accountable for eliminating,
Patients and other stakeholders are told
substituting and/or reducing hazardous
of the hazards and risks, and their
Efficiency is maximised, avoiding waste substances. consent is obtained.
in the supply chain by facilitating the
circular use of resources.
Duty of care
Any person handling or managing hazardous substances, wastes or related equipment is ethically responsible for using the utmost care in
carrying out that task.
Data management
Waste data is recorded effectively enabling all waste movements to be quantifiably tracked from production through to treatment or disposal.
Waste management decisions as well targets and KPIs are founded on reliable data.
3.24 Those responsible for the procurement 3.27 Waste “duty of care” places legal
of healthcare products should seek to responsibility on all organisations that
engage with responsible producers and handle waste. This is an important
suppliers to purchase products that overriding principle and can be used to
minimise environmental harm, promote govern waste regulation by ensuring that
resource efficiency and encourage greater appropriate licensing and permitting
circularity in the use of products. controls are in place to avoid unnecessary
harm to the environment. Information on
3.25 Environmental sustainability can be how to comply with duty of care
demonstrated when demands placed on the requirements is set out in paragraphs
environment can be met without reducing 6.87–6.92.
its capacity to allow people to live well, now
and in the future. This includes dramatically 3.28 Prior informed consent is a principle
reducing carbon emissions to reduce the designed to protect public health and
impact on climate change and ozone protect the environment from hazardous
depletion. waste. Stakeholders (patients and the local
community) are told of the associated
3.26 Mechanisms can be introduced that hazards and risks, and their consent is
make manufacturers and distributors more obtained.
accountable for the level of hazardous
substances contained within healthcare 3.29 Good data management is
products. fundamental in effective waste
management. It can help to keep track of
how much is produced, where it is sent,
28
how it is treated and how much it costs to

do so. It is also essential in complying with
duty of care requirements. Having a robust
waste database helps to inform decisions
about how healthcare waste should be
managed in the future, as it can be used to
help set performance targets and monitor
KPIs. Further information on the approach
to data management is included in
paragraphs 6.2–6.47.
29
4.0 Legislative framework
road transport legislation applying in

Key legislation Northern Ireland.
4.1 England and Wales, Scotland, and
Northern Ireland each have their own sets 4.3 Local authorities have specific duties in
of laws and regulations, which may differ relation to healthcare waste as specified in
from each other. The name of the Section 45 of the Environmental Protection
regulatory instrument is often very similar Act (in Northern Ireland, Article 20 of the
or the same, although the date when it Waste and Contaminated Land Order).
came into force may vary. It is for this
reason that wherever a regulatory 4.4 Schedule 1 of the Controlled Waste
instrument is cited in this guidance, the Regulations identifies where a charge can
date has been omitted. be made for the collection of household
waste. This includes clinical and offensive
SCOTLAND: waste from a domestic property. This
schedule also identifies where clinical waste
Readers of this guidance in Scotland is “industrial” (not household) waste.
should use the term “special waste” in
line with the Special Waste Amendment Healthcare professionals delivering
(Scotland) Regulations 2004, which treatment to patients in their homes
implement the requirements of the should take any clinical or hazardous
Waste Directive in Scotland. waste generated away with them for
safe disposal.
4.2 The term “dangerous goods” signifies
substances with intrinsic hazards posing a 4.5 The legislative framework for the
potential risk to persons or the environment healthcare sector is summarised in Figure 11.
while in the transport chain, with similar
Figure 11 Healthcare legislative framework
Healthcare waste legislative framework
Environment and Drug and Health and Transport

waste infection control safety
• Duty of Care • Level of control • Risk assessment • Dangerous goods
• Hazardous waste • Destruction and • Harmful and • Land (road/rail),

disposal hazardous air, sea and
• Permitting and substances inland waterways
licensing • Producer
responsibility • Handling • Packaging
• Environmental
protection • Assessing risk • Training
30
Environment and waste legislation mandatory, and the requirements set out
within such must be followed.
4.6 The relevant environment and waste
legislation is listed in Table 5. The table 4.8 Approved Codes of Practice (ACoP)
includes both primary legislation, noted as issued by the Health and Safety (HSE)
Acts, and secondary legislation, noted as Executive is approved by the Health and
Regulations or Approved Codes of Practice Safety Executive with the consent of the
(ACoP). Secretary of State. ACoPs have a special
legal status, and the HSE state: “if you are
4.7 A statute is an Act of Parliament, is law
prosecuted for breach of health and safety
made by the UK Parliament, and is known
law, and it is proved that you did not follow
as primary legislation. Often, Acts of
the relevant provisions of the ACoP, you will
Parliament allow the creation of secondary
need to show that you have complied with
(or delegated legislation) known as
the law in some other way, or a Court will
Statutory Instruments (SI’s). Compliance
find you at fault”.
with primary and secondary legislation is
Table 5 Summary of waste and environmental legislation
Legislation Summary
The Misuse of Drugs (Safe Custody) Requires controlled drugs other than those specified in Schedule one generally to be
Regulations kept either in a locked safe or room or in a locked receptacle.
The Environmental Protection Act Defines that everyone who handles waste has a responsibility for its management and
is required to fully comply with their own “duty of care”, including those who import,
produce, hold or carry waste.
The Environmental Protection (Duty These regulations define the terms Waste Producer, Waste Manager, Waste Broker and
of Care) Regulations Waste Carrier, and set out the duties required of each relating to controlled wastes.
Not to be confused with the Waste duty of care code of practice.
Radioactive Substances Act Defines “radioactive material” and “radioactive waste”, and governs the accumulation
and disposal of radioactive substances, and the inspection of premises generating,
storing or disposing of them.
The Carriage of `Dangerous Goods For further details, see guidance on the Transport and Carriage Regulations in
Regulations paragraphs 4.37–4.42, and the transport and packaging section in paragraphs 5.78–
5.142.
The Misuse of Drugs Regulations The regulations set out the regime of control that governs the various legitimate clinical
activities associated with controlled drugs, for example:
• which professionals are allowed to prescribe, order, supply or administer the drugs
• destruction and/or disposal procedures
• associated record-keeping requirements.
Clean Neighbourhoods and The operator must take reasonable steps to prevent nuisances from litter, noise, pests
Environment Act and artificial lighting outside of the site boundary. This needs to be considered if the site
is to operate during antisocial hours.
The Hazardous Waste (England and Defines and regulates the segregation and movement of hazardous waste in England
Wales) Regulations and Wales from the point of production to the final point of disposal or recovery. The
regulations cover any waste with properties that pose a threat to human health or the
environment.
Waste Framework Directive Provides additional labelling, record keeping, monitoring and control obligations
from the “cradle to the grave”, in other words from the waste production to the final
disposal or recovery. It also bans the mixing of hazardous waste with other categories of
hazardous waste, and with non-hazardous waste.
Regulation (EC) No 1272/2008 of Regulation and standards on the classification, labelling and packaging of substances
the European Parliament and of the and mixtures. This includes definitions for classification of dangerous substances.
Council
31
Legislation Summary
The Waste (England and Wales) Producers must confirm that the waste management hierarchy has been applied when
Regulations transferring waste and include a declaration to this effect on the waste transfer note or
consignment note.
The Controlled Waste (England and Gives legal definitions of “clinical waste” and “offensive waste”. Such wastes are
Wales) Regulations regulated due to their toxicity, hazardous nature, and capacity to do harm to human
health or the environment. This regulation gives a statutory obligation to ensure the
waste is managed correctly to prevent harm.
The Animal By-Products Regulations Designed to prevent animal by-products from presenting a risk to animal or public
health through the transmission of disease. Animal by-products from healthcare (for
example research facilities) have specific legislative requirements for disposal and
treatment.
The Ionising Radiations Regulations Medical ionising radiation is used widely in hospitals, dental care, clinics and in medical
(IRR) research to help diagnose and treat conditions. Examples are X-rays and nuclear
scans, and treatments such as radiotherapy. The regulations aim to make sure that it is
used safely to protect patients from the risk of harm when being exposed to ionising
radiation.
The Ionising Radiation (Medical Legislation which provides a framework intended to protect healthcare patients from
Exposure) Regulations (IR[ME]R) the hazards associated with ionising radiation.
The Environmental Permitting Requires the environmental permitting of any establishment or undertaking that
(England and Wales) Regulations recovers or disposes of waste. This regulation is also applicable to sites and activities that
pose a pollution risk from waste storage.
The Waste (Circular Economy) Aims to make sure fewer resources are sent to landfill if they can be reused or recycled.
Regulations This will make steps towards a circular economy and resource optimisation by increasing
a product’s lifespan. It focuses on bringing resources back into circulation once a
product has reached its end of life, so that parts can be reused or repurposed for new
products.
The Producer Responsibility These further develop the principle of “extended producer responsibility”, whereby
Obligation (Packaging Waste) producers, usually brand owners or suppliers, are required to take responsibility for
Regulations the environmental impact of their products, especially when they become waste. This
includes regulations governing:
• waste electrical and electronic equipment (WEEE)
• waste batteries
• waste packaging
• end-of-life vehicles.
The Environment Act Sets out environmental targets, including for air quality, water, biodiversity and waste
reduction.
Adds legal responsibility to segregate waste streams (including food waste).
Establishes the Office for Environmental Protection (OEP), with the responsibility to
hold the government and other public bodies to account, and to ensure environmental
regulations are obeyed.
Duty of care and controlled waste • The Environmental Protection (Duty of

Care) Regulations (Scotland)
4.9 The statutory requirements covering
duty of care in waste management across • The Environmental Protection (Duty of
the home nations are contained in: Care) Regulations (Wales).
• Section 34 of the Environmental 4.10 It is the producer’s responsibility to
Protection Act ensure the transport and destination are
• Section 5 of the Waste and correctly authorised when waste is
Contaminated Land (Northern Ireland) transferred.
Act
4.11 The statutory duty of care applies to
• The Controlled Waste and Duty of everyone in the waste management chain.
Care Regulations (Northern Ireland) It requires producers and others who are
32
involved in the management of waste to required for the storage of waste on the
prevent its escape, and to take all site where it was produced, as this is
reasonable measures to ensure that the covered by an exemption to the regulations
waste is dealt with appropriately and in (see the Environment Agency’s (2010) non-
compliance with legislation. waste framework directive exemptions).
Further information on compliance is found
4.12 A written description providing an in paragraphs 6.84–6.142.
accurate description of the type and
quantity of waste, is provided for transfer 4.16 Permitted healthcare waste
of the waste as it is moved from point of management sites in England and Wales are
production to point of final disposal. Where required to obtain pre-acceptance audits
an annual waste transfer note is used, the from producers of healthcare waste before
written description will only be required for they can accept the waste from that
the initial transfer if the original note meets producer. The pre-acceptance audit
Defra’s ‘Waste duty of care code of practice’ requirements are detailed in paragraphs
(2018). 6.103–6.107.
NORTHERN IRELAND: 4.17 Environmental permits and waste

management licences (and related
See also the Northern Ireland exemptions) are regulated by:
Environment Agency’s website for the
• the Environment Agency in England
statutory ‘Code of Practice’.
(as well as local authorities for small
waste incineration plants)
• the Northern Ireland Environment
SCOTLAND:
Agency (NIEA) in Northern Ireland
Carrier registrations may be checked in • the Scottish Environment Protection
Scotland on the SEPA website. Agency (SEPA) in Scotland
4.13 Anyone wishing to carry controlled • Natural Resources Wales (NRW) in

waste must be registered as a carrier of Wales.
controlled wastes, as required by the
Controlled Waste (Registration of Carriers Producer responsibility
and Seizure of Vehicles) Regulations (1991).
Waste carrier registrations can also be 4.18 For redundant electronic items,
checked online at the Environment Agency’s healthcare waste producers will likely fall
website. Waste can only be handed to such within the “business-to business” element
authorised persons as registered carriers, and will need to take responsibility for their
permit/licence holders or someone who is electronic and electrical equipment waste
exempt. either by returning the waste to the
producer from whom it was purchased (or
4.14 Information on how to comply with their compliance scheme) or by disposing of
duty of care requirements is set out in it directly. The principle of producer
paragraphs 6.87–6.92. responsibility extends beyond the non-
exhaustive key items covered above.
Environmental permitting
4.15 Permits and licences are required for
the management of many different types of
waste. Generally, a permit/licence is not
33
For further information refer to the WALES:

UK.Gov page on Producer Responsibility
Regulations for signposting to individual In Wales, these regulations require that
regulations across the home nations: most premises producing hazardous
waste be registered with NRW. Premises
https://www.gov.uk/government/ are exempt from the requirement to
collections/producer-responsibility- register if they produce less than 500
regulations kg of hazardous waste in any period
of 12 months. Premises registration is
4.19 For waste batteries, healthcare waste not required in England, Scotland or
producers will also need to take Northern Ireland.
responsibility by returning the waste to the
producer (or their compliance scheme) or by 4.23 Hazardous waste consignment notes
disposing of it directly. must be completed when waste is collected
by a carrier or transferred between
4.20 Healthcare facilities are unlikely to fall premises.
under the packaging producer responsibility
obligations. However, consumers play a vital 4.24 Where premises are shared, each
role, and therefore waste packaging should occupant retains their own responsibility for
be disposed of appropriately through waste under duty of care. For further
recycling when reuse is not an option. details, see the section on duty of care in
Hazardous waste
Further details on hazardous waste are
4.21 The term “hazardous waste” is used in available in:
England, Wales and Northern Ireland to
describe waste with hazardous properties. • UK
government guidance at https://
These characteristics were transposed into www.gov.uk/dispose-hazardous-
domestic legislation through the List of waste
Waste Regulations and provide European
Waste Catalogue (EWC) codes for all • paragraphs 6.119–6.122.
wastes.
4.22 Hazardous waste is governed by the Consignment notes

Hazardous Waste Regulations, for which 4.25 Consignment notes are required when
each home nation has its own transporting hazardous waste. These are
requirements. These regulations set out the the responsibility of the waste producer. For
requirements for the management, further information, see the UK
transport and transfer of hazardous wastes. government page on Hazardous Waste
A full list of hazardous properties [and Consignment Notes.
classification codes?] is included in the
Environment Agency’s (2021a) Technical
Guidance WM3: ‘Guidance on the
classification and assessment of waste’, with
further guidance on defining hazardous
and non-hazardous waste in paragraphs
5.8–5.10.
34
SCOTLAND: edition was published after exiting the EU

(1st Edition v1.2.GB) entitled Technical
In Scotland, consignment notes are Guidance WM3: ‘Guidance on the
available to purchase from SEPA. They classification and assessment of waste’
may also be supplied by the waste (2021a). In Northern Ireland, Edition v1.1.NI
contractor. There is no legal obligation applies.
to purchase the note itself; however, the
relevant codes must be purchased which 4.29 The EWC categorises waste into 20
can be used on bespoke paperwork if chapters. Each chapter is defined by either
preferred. the source of the waste or the waste type.
Within each chapter, each type of waste is
described using a six-digit numerical code.
4.26 The producer is legally responsible for
ensuring the accuracy of a consignment 4.30 The list should be used in accordance
note; in some instances it may be with the rules set out in Appendix 1.3:
appropriate to seek advice from the waste WM3. Chapter 18 of the European Waste
contractor. Catalogue (EWC) provides a list of codes
specifically for the healthcare sector. These
NORTHERN IRELAND AND SCOTLAND: codes cannot be recycled under a waste
exemption; the activity must be listed on
In Northern Ireland and Scotland, the environmental permit.
producers (or consignors) of hazardous
waste are not required to register with
the regulatory authority (NIEA and SEPA, Controlled drugs
respectively). Instead, they are required 4.31 Controlled drugs are subject to special
to provide 72 hours’ prior notification to legislative controls, as they are potentially
the relevant regulator of their intention harmful. The Misuse of Drugs Regulations
to move hazardous/special waste. Not list the medicines that are classified as
every movement has to be notified (this controlled drugs. There are five schedules
is usually for the first movement in a that dictate the level of control to be
succession, a “carrier’s round” or a one- applied to each medicine – Schedule 1
off movement). having the most controls and Schedule 5
the fewest.
In Scotland, pre-notification is not
needed if the waste remains in Scotland. 4.32 The Misuse of Drugs (Safe Custody)
See SEPA Consigning Special Waste Regulations list additional requirements in
Guidance. terms of safe storage, for example lockable
cupboards of sufficient strength.
European Waste Catalogue 4.33 Schedules 1 and 2 stock-controlled
4.27 Producers must adequately describe drugs can only be destroyed in the presence
their waste using both a written description of a person authorised under those
and the use of the appropriate EWC code(s) regulations to witness destruction, unless a
on both waste transfer and consignment T28 waste exemption is employed.
notes.
4.34 The Environment Agency’s (2014b)
4.28 The Environment Agency, NRW and guidance ‘T28 waste exemption: sort and
SEPA produced a joint guidance document denature controlled drugs for disposal’
on the interpretation, definition and allows pharmacies and similar places to
classification of hazardous waste. A new denature controlled drugs to comply with
35
the Misuse of Drugs Regulations. This Infection prevention and control

exemption means that the following cannot
4.36 Effective prevention and control of
be treated:
infection must be part of everyday practice
• any waste drugs that are hazardous and be applied consistently by everyone.
waste Good management and organisational
processes are crucial to prevent cross-
• controlled drugs that are waste at any contamination of otherwise non-infected
other place than where the waste was materials, thus preventing unnecessary
produced. infectious waste generation.
When a stock-controlled drug is

destroyed, details of the drug must Transport and carriage legislation
be entered into the controlled drugs 4.37 Relevant transport and carriage
register. This should include: legislation is listed in Table 6.
• the name of the drug 4.38 The Carriage of Dangerous Goods and
Use of Transportable Pressure Equipment
• its form Regulations implement the requirements of
• its strength and quantity the ‘Agreement concerning the
International Carriage of Dangerous Goods
• the date it was destroyed by Road’ (commonly known as ADR) (United
Nations Economic Commission for Europe,
• the
signature of the authorised 2020).
person who witnessed the
destruction, and the person 4.39 The Carriage of Dangerous Goods
witnessing it (that is, two signatures). Regulations make direct reference to ADR
and RID (the Regulation concerning the
International Carriage of Dangerous Goods
4.35 Healthcare organisations should be
by Rail) (Intergovernmental Organisation
aware of who within their organisation is
for International Carriage by Rail (OTIF),
authorised to witness destruction (witnesses
2021). Both documents are revised every
must be authorised by the Controlled Drugs
two years, and the updated versions are
Accountable Officer). Further guidance and
incorporated into the UK by the Carriage of
details of the categories of people currently
Dangerous Goods Regulations. Note that
authorised are available in the Care Quality
the transportation of clinical wastes via rail
Commission’s ‘Controlled drugs accountable
is uncommon in the UK. If moving waste by
officers’ (2021).
sea (for instance from an island to the
Table 6 Summary of transport and carriage legislation

Legislation Summary
The Carriage of Dangerous Goods and Use of Intended to reduce, to reasonable levels, the risk of harm or damage to people,
Transportable Pressure Equipment Regulations property and the environment posed by the carriage of dangerous goods
throughout the UK.
International Waste Shipments (Amendment Applies to international shipments of waste from the point of loading until
of Regulation (EC) No 1013/2006 and it has been fully recovered or disposed of. Wherever waste is shipped, the
1418/2007) Regulations relevant regulations and import controls must be complied with.
International Waste Shipments (Amendment) This instrument amends Regulation (EC) No 1013/2006 Trans frontier Shipment
(EU Exit) Regulations of Waste Regulations 2007, and related direct EU legislation to enable their
continued operability as retained EU law under the European Union following
the UK’s withdrawal from the European Union.
36
mainland), the International Maritime Health and safety legislation

Dangerous Goods code (International
Maritime Organisation, 2019) must be The Health and Safety Executive (HSE) is
obeyed. the regulatory body with responsibility
for enforcing health and safety in the
4.40 Other international regulations apply workplace legislation in Great Britain.
to the movement of dangerous goods by The Health and Safety Executive for
air, sea and inland waterway. Specialist Northern Ireland (HSENI) is the lead
advice should be sought if healthcare waste body responsible for the promotion and
is to be transported by means other than enforcement of health and safety at
road transport. In the UK, the vast majority work standards in Northern Ireland.
of dangerous goods are carried by road.
4.43 Relevant health and safety legislation
4.41 The Carriage of Dangerous Goods
is listed in Table 7.
Regulations apply to all dangerous goods
regardless of whether a substance is waste 4.44 Arrangements for managing
or not. Goods are assessed on their healthcare waste should be part of an
hazardous properties and, if applicable, are overall health and safety management
categorised based on nine classes of system. Guidance documents, produced by
dangerous goods (items may be put into the HSE, are available in relation to the
multiple classes). Once goods have been management of inadvertent exposure to
classified, the information is used to infectious waste, including:
identify appropriate packaging, labelling
and transport requirements. The nine • ‘Safe working and the prevention of
classes and the packaging, labelling and infection in clinical laboratories and
transport requirements are shown, along similar facilities’ (HSE Books, 2003)
with examples, in paragraphs 5.78–5.142.
• ‘HSG283: Managing infection risks
4.42 The Health and Safety Executive (HSE) when handling the deceased:
is the regulatory body responsible for Guidance for the mortuary, post-
enforcing transport legislation in Great mortem room and funeral premises,
Britain (the HSENI in Northern Ireland). and during exhumation’ (2018).
Police officers and the Driver and Vehicle
Standards Agency (in England, Wales and The importance of effective
Scotland only) carry out “on the road”
enforcement under an agency agreement regulation
with the HSE. 4.45 Legislation describes the legal
expectations and the consequences of
Further information on the Carriage wilful or unintended breaches of these
Regulations can be found on the regulations; they are intended to provide a
Government website and on the HSE deterrent effect, which in turn improves the
website: standards of environment protection across
a range of industries including waste
• https://www.gov.uk/government/
management in the healthcare sector.
collections/transporting-dangerous-
goods 4.46 Healthcare waste should be managed
in accordance with regulations to prevent a
• https://www.hse.gov.uk/cdg/regs.htm risk to human health through spread of
infection or disease, fire and other hazards,
37
Table 7 Summary of health and safety legislation
Legislation Summary
Health and Safety (Sharp Instruments in Provides practical advice on:
Healthcare) Regulations • safe use and disposal of sharps
• training requirements
• procedures for responding to sharps injuries.
Health and Social Care Act: Code of practice on the The Care Quality Commission, who regulate and inspect all healthcare
prevention and control of infections and related providers, use this document to measure compliance and quality of an
guidance organisation’s safety profile.
The Control of Substances Hazardous to Health Measures to protect employees and other persons from the hazards of
(COSHH) Regulations substances used at work by risk assessment, control of exposure, health
surveillance and incident planning.
Health and Safety at Work etc. Act The primary piece of legislation covering occupational health and safety
in Great Britain. The operator and staff must take all reasonable steps to
ensure the health and safety of everyone on site. This will include health
and safety policies, training and procedures in addition to stringent
equipment inspections and maintenance programmes.
Health and Safety (Consultation with Employees) Employers must consult employees and their representatives about aspects
Regulations of their health and safety at work.
The Safety Representatives and Safety Committees States the cases in which recognised trade unions may: appoint health
Regulations and safety representatives; specify the functions of such health and safety
representatives; and set out the obligations of employers towards them.
The Reporting of Injuries, Diseases and Dangerous RIDDOR puts duties on employers, the self-employed and people in control
Occurrences Regulations (RIDDOR) of work premises (Responsible Persons) to report certain serious workplace
accidents, occupational diseases and specified dangerous occurrences (near
misses).
The Management of Health and Safety at Work Explicitly outline what employers are required to do to manage health
Regulations and safety, and apply to every work activity. The regulations place a set
of duties on employers and employees to maintain a safe and healthy
workplace.
The Public Services (Social Value) Act An Act to require public authorities to have regard to economic, social and
environmental wellbeing in connection with public services contracts; and
for connected purposes.
in turn keeping individuals and the conditions or notices which have a deadline
environment safe from harm. for completion.
4.47 Without legislation and regulation,

there would be no minimum standards to How to keep up to date
enforce, to ensure that risks are mitigated 4.50 Changes to legislation can be searched
and appropriate measures are taken to for manually by date or title on the gov.uk
safeguard all individuals involved in the website. Any legislative amendments will
management of waste. be available on the site within two weeks
of the new legislation being published.
4.48 The regulators listed in Table 8 may Specialist legal advice may need to be taken
intervene when a material breach to the regarding the interpretation of specific
law has been found. For major breaches the clauses to ensure legal compliance.
consequences can be large fines or criminal
prosecution. 4.51 The HSE offer a free email update
service on a wide range of topics, including
4.49 In the situation of a minor breach, legislation, COSHH, health and social care
regulators will often issue improvement services and carriage of dangerous goods.
38
Table 8 Summary of healthcare regulators
Regulator Frequency of inspections Details Enforcement actions

Care Quality Commission 6 months following an Visits are announced unless acting Refer to the CQC’s (2015)
inadequate visit on a complaint Enforcement Policy and the
CQC’s (2017) Enforcement
12 months following Decision Tree.
a visit which requires
improvement
5 years following an
outstanding visit
Health and Safety Executive Varied Notice in writing typically provided See the HSE’s (2015)
when a formal inspection is Enforcement Policy
intended to be carried out and HSE Statement, and the HSE’s
have not inspected in the previous (2013a) Enforcement
three months. Unannounced visits Management Model.
may however be carried out.
Environment Agency Varied Visits can be announced or See the Environment

unannounced. Agency’s (2022a)
enforcement and sanctions
policy
NHS England N/A Oversees the budget, planning, See NHS England’s
delivery and day-to-day operation Monitoring and enforcement
of the commissioning side of the page.
NHS in England as set out in the
Health and Social Care Act 2012.
Directly commissions NHS general

medical practitioners, general
dental practitioners, optometrists
and some specialist services.
Office for Nuclear Regulation Varied Responsible for the regulation, See the ONR’s guidance
licensing and inspection of sites page and the ONR’s (2020)
handling nuclear material. Enforcement Policy Statement
Land Transport Security Varied Responsibility for the transport Land Transport Security page
Inspectorate of high consequence dangerous
goods (Cat A waste)
The subscription topics and further • Scotland – please refer to SEPA

information can be found on the HSE’s guidance, available at: https://www.
website. sepa.org.uk/regulations/waste/.
4.52 The Environment Agency has detailed • Wales – see the Natural Resources
guidance on the government website Wales website, available at: https://
relating to the management of waste. This naturalresources.wales/guidance-and-
is available at: https://www.gov.uk/topic/ advice/environmental-topics/waste-
environmental-management/waste management/?lang=en.
HOME NATIONS:
• Northern Ireland – refer to guidance

from the Department of Agriculture,
Environment and Rural Affairs
Northern Ireland, available at: https://
www.daera-ni.gov.uk/topics/waste.
39
5.0 Technical approach
5.1 The purpose of this chapter is to set

out how healthcare waste must be
Non-clinical waste and
managed to comply with the key legislation resources
set out in Chapter 4. Failure to follow this 5.6 The Venn diagram demonstrating the
guidance will result in non-compliance, relationship between waste types in Figure
environmental damage, harm to human 12 does not include non-clinical wastes and
health and potential enforcement action. resources, which might be produced in a
healthcare setting, and may include:
5.2 Healthcare waste is waste produced
during human or animal healthcare, or • fluorescent tubes
related research activities. All wastes
produced in a healthcare setting are • food waste
healthcare wastes, including clinical waste, • batteries
offensive waste and other non-clinical
waste and resources. • furniture
• cleaning chemicals
5.3 Waste produced by healthcare in the
community, and similar types of waste • construction and demolition waste
produced by non-healthcare activities are
included, such as: • oils (hazardous and edible)
• cosmetic body piercing and body art • asbestos
• non-medicinal procedures in the hair • grounds waste (garden waste etc.)

and beauty sector • paints
• substance misuse/abuse • domestic waste streams
• crime scene clean-up. • paper, glass, cans and bottles
5.4 Healthcare waste is a broad • waste electrical and electronic
classification which includes clinical waste equipment (WEEE).
and items which may not pose a risk of
infection or may not have hazardous 5.7 The approach to the management of
properties. some of these waste types, including
consideration towards waste prevention
5.5 This chapter outlines the technical and circular economy implementation,
approach to the management of the waste principles in segregation, storage, handling,
streams summarised in Figure 12. Specific collection and appropriate forms of
guidance for each is set out in the sections treatment, recovery and disposal is
that follow.
40
summarised in Appendix 2, ‘Non-clinical 5.10 It is illegal to mix hazardous or POPs

waste and resource management principles’. waste with non-hazardous or other types of
hazardous waste (unless specifically
authorised by an environmental permit).
Defining hazardous and non- Doing so may result in fines and/or a prison
hazardous waste sentence if convicted. For further details
5.8 Certain types of healthcare waste may refer to the Environment Agency’s (2014a)
be hazardous. All wastes which do not fit guidance ‘Hazardous waste: segregation
the legal definition of hazardous are non- and mixing’.
hazardous. Examples of how hazardous
healthcare wastes may harm the Domestic households are exempt from
environment are summarised in paragraphs the ban on mixing and may sometimes
2.40–2.52. return mixed waste medicines to
pharmacies and healthcare facilities.
5.9 Hazardous waste is defined in the Staff should attempt to segregate these
Hazardous Waste Regulations, with the medicines (and identify controlled
specific hazards defined and detailed in the substances) where safe to do so.
Environment Agency’s (2021a) Technical Examining the contents of containers
Guidance WM3: ‘Guidance on the through opening them or emptying onto
classification and assessment of waste’. a tray for examination will minimise the
A list of properties which make a waste safety risk.
hazardous is included in schedule A.3 WM3
hazards; this schedule is included in
Appendix 1.3. The importance of accurate waste
segregation
Some waste types are known as mirror
hazardous. This means that they are
imposes a set of critical targets to help
only considered hazardous under certain
deliver a more sustainable waste
conditions (for instance, a drug which is
management system in the long term,
only dangerous is large concentrations,
mainly through accurate segregation:
or a substance which is only flammable
in certain conditions). In a healthcare • 20% of waste segregated to be sent
setting, mirror hazards are typically to incineration, with only 4% of that
chemical. being hazardous/clinical incineration,
see paragraphs 5.143–5.173 for further
In WM3, these wastes have a hazardous information
waste entry (or entries) marked with
an asterisk (*), and an alternative non- • 20% of waste segregated to be sent
hazardous waste entry (or entries) not to alternative treatment
marked with an asterisk.
• 60% of waste segregated to be
These differ from absolute hazardous classified as offensive waste.
entries, where the item must be
considered hazardous in all situations. 5.12 In order to meet these targets, waste
There are exceptions where ‘absolute must be identified and segregated correctly
hazardous’ entries are linked to other (so that it can be managed appropriately).
entries, and additional consideration
5.13 Misclassification of waste, where waste
may be needed.
is classified incorrectly, can lead to injury or
cause ill health, for instance from hazardous
41
wastes being handled as though they are waste is now defined in legislation and
non-hazardous, and can result in summarised in Technical Guidance WM3.
environmental damage, for instance from
hazardous wastes being disposed of 5.16 Figure 12 illustrates the relationship
improperly. between hazardous, non-hazardous, clinical
and dental wastes. It also includes
5.14 Over-classification of waste, where information on the hazards, appropriate
wastes are classified as more hazardous bins/bags, EWC codes, and whether each
than they actually are, is a major issue for stream contains sharps. It is intended to
the NHS and often results in wastes being serve as a quick reference guide to help
disposed of using hazardous or clinical inform the broad approach to classification
waste incineration or alternative treatment, and segregation.
rather than more cost-effective or
sustainable methods. 5.17 The legend and icons contained in
Figure 12, which demonstrates the
5.15 The previous version of this HTM relationship between waste types, are
included a detailed risk assessment for explained below:
offensive waste; however, this is no longer
needed and has been removed, as offensive
LEGEND:
This is the
name/description of the
These are the waste
EWC codes used This symbol indicates
to classify waste whether the waste can
contain sharps
Cytotoxic/cytostatic waste
(18 01 08*, 18 02 07*, 20 01 31*)
L S No sharps in
this stream:
These symbols show what Symbols here indicate

types of bins this waste can hazards (if any) Can contain sharps:
be put into (this will depend
on the form of the waste)
ICONS:
Medicines
Hazardous Bag L bin
(liquids)
No sharps in
Bioazard Rigid bin
this stream
Can contain
Sharps bin sharps
Radiation
Medicines Bin body

Toxic
S bin (colour may
(solids) vary)
42
Clinical waste • medicines and medicinally-

contaminated waste containing a
5.18 The guidance in this section is pharmaceutically-active agent.
intended to help waste handling staff in
healthcare organisations to correctly 5.21 The key principle is that all clinical
identify, segregate and manage waste. waste, other than under the four following
exceptions, should be managed as
5.19 Healthcare organisations may wish to hazardous waste:
produce their own simplified guidance for
internal use, for a wider audience. Note • segregated non-cytotoxic and non-
that the guidance included in this HTM is cytostatic medicines (that is, from
based on legislation and practices in human (EWC Code 18 01 09) or animal
England, and may not be applicable in (EWC Code 18 02 08) healthcare and
Scotland, Wales and Northern Ireland. manufacturing, or separate fractions
of out-patient-returned medicines
(EWC Code 20 01 32))
Definitions and waste types
• clinical waste from municipal sources
Clinical waste is defined under the that are not in any way directly or
Controlled Waste (England and Wales) indirectly associated with healthcare
Regulations 2012 as follows: (for example needles and swabs from
“clinical waste” means waste from a healthcare
cosmetic body art or piercing)
activity (including veterinary healthcare) that –
• anatomical waste without chemical
(a) contains
viable micro-organisms or their toxins contamination or infectious properties
which are known or reliably believed to cause
disease in humans or other living organisms • non-hazardous sharps (note that these
(b) contains
or is contaminated with a medicine that
may be considered dangerous goods).
contains a biologically active pharmaceutical
agent, or 5.22 Many healthcare wastes contaminated
with hazardous chemicals will be classified
(c) is
a sharp, or a body fluid or other biological
material (including human and animal tissue) as a clinical waste. Any healthcare waste
containing or contaminated with a dangerous contaminated with a medicine that contains
substance within the meaning of Council
Directive 67/548/EEC on the approximation of
a biologically active pharmaceutical agent is
laws, regulations and administrative provisions considered clinical waste.
relating to the classification, packaging and
labelling of dangerous substances.
For example, on its own, a bottle of
waste chemical would not fall under the
Northern Ireland: definition of clinical waste, although it
may still be hazardous.
Clinical waste is defined by the Waste
and Contaminated Land (Northern
5.23 Any sharp, or biological material
Ireland) Order 1997.
contaminated with a dangerous substance,
as defined by Regulation (EC) No 1272/2008
5.20 Clinical waste can be divided into three of the European Parliament and of the
broad groups of materials: Council, is considered clinical waste.
• any healthcare waste which poses a
risk of infection
• certain healthcare wastes which pose
a hazard
43
Health Technical Memorandum 07-01: Safe and sustainable management of healthcare waste 5.0 Technical approach
Figure 12 Relationship between waste types
Clinical
Hazardous
Non -Hazardous Cytotoxic / cytostatic waste Cytotoxic / cytostatic sharps

(18 01 03* and 18 01 08* / 20 01 31*) or
(18 01 08*, 18 02 07*,
Uncontaminated 20 01 31*)
(18 02 02* and 18 02 07* / 20 01 31*)
Gypsum
Icon key (18 01 04, 18 02 03) Medicinally contaminated

sharps
Gypsum
(18 01 01 and 18 01 09) or Hazardous Anatomical waste Infectious and contaminated Very Low -level Radioactive
(18 02 01 and 18 02 08) waste
(18 01 03* and 18 01 06* / 18 01 07) or with medicines
(18 02 02* and 18 02 05* / 18 02 06) (18 01 03* and 18 01 09) or
Hazardous Confidential waste
(18 02 02* and 18 02 08)
(EWC code depends on properties)
(various EWC codes)
Non cytotoxic / cytostatic
Biohazard medicine waste
(18 01 09, 18 02 08, Infectious medicinally Infectious and contaminated Low -level Radioactive
20 01 32) contaminated sharps with chemicals 20% infectious waste
(18 01 03* and 18 01 09) or (18 01 03* and 18 01 06* / 18 01 07) or y
yellow waste* (EWC code depends on properties)
Radiation Recyclable waste (18 02 02* and 18 02 08) (18 02 02* and 18 02 05* / 18 02 06)
(various EWC codes) Decay in storage
Non -infectious Anatomical
waste without chemicals
Toxic (18 01 02)
02, ) Known infectious waste Used, non medicinally Radioactive Solid waste
20% infectious (no medicines) contaminated sharps (EWC code depends on properties)
g waste*
orange
(18 01 03*, 18 02 02*) (18 01 03*, 18 02 02*)
Domestic waste
Bag (20 03 01)
Uncontaminated sharps
(18 01 01, 18 02 01)
Rigid Bin
No separate bin -
Dispose of with Infectious gypsum
Sharps Bin used sharps (18 01 03*, 18 02 02*)
Offensive waste
(18 01 04, 18 02 03, Not exclusive Dental Amalgam
Infectious
Gypsum
20 01 99)
Medicines Bin (solids) S
to dentistry (18 01 10*)
Infectious waste containing
dental amalgam
Medicines Bin (liquids)
infectious
Amalgam
Non -
L 60% offensive (18 01 03* and 18 01 10*)
waste*
Amalgam
Infectious
No sharps in this stream X-ray fixer & Developer
(09 01 01* - 09 01 05*) Dental
Can contain sharps
X-ray
*see NHS Clinical
Waste Strategy
44 45
When handling clinical waste always are never determined by the type of
ensure the following: receptacle used.
• the
hospital ward/department is 5.26 Staff segregating waste must be
visible on every bag and sharps provided with appropriate training and
container (pre-marked tags may be clear instructions on waste segregation,
used for this) specifically which items go in which
container.
• never
overfill bags (no more than
two-thirds full) 5.27 Figure 13 shows a summary
methodology for identifying and
• segregate
waste correctly – sharps segregating waste. Technical Guidance
always go in a sharps bin WM3 contains more complete guidance.
Figure 13 has been included in an enlarged
• never
open a clinical waste bag to format in Appendix 3 to allow waste
examine the contents managers and clinical staff to print a
separate copy as a guide.
• never
handle spillages from clinical
waste bags without ensuring health 5.28 There are a number of key
and safety procedures are followed considerations that should be followed
– see the NHS’s Standard Infection when attempting to classify healthcare
Prevention and Control Precautions waste. These are summarised below and
should be read in conjunction with WM3.
• do
not use force to compress waste
bags – this may result in bags splitting
Is it clinical waste?
• damaged
or leaking bags must not
5.29 Clinical waste is defined at the
be moved until the complete bag is
beginning of this section. If the waste is not
placed inside a new bag
clinical, it is very likely non-hazardous unless
• appropriate
PPE clothing must be it contains any of the following:
worn. • radioactive material
• dental amalgam
Classification and segregation
• X-ray fixer and/or developer
5.24 This section provides the definitions
and assessment framework for typical • electrical equipment or electronics.
healthcare wastes based on the legislative
5.30 For information on the management
framework set out in Chapter 4. It
of non-clinical wastes, see Appendix 2.
emphasises the need to undertake an
assessment to classify a waste. This section
does not address all packaging issues Is it hazardous?
related to transport, which is addressed in
5.31 The handling and disposal
requirements of a waste are typically based
5.25 The EWC contains codes that apply to on its hazardous properties. A hazard is
waste produced from healthcare and similar anything which can cause harm to humans
wastes from municipal sources. The codes or the environment. A full list of hazards is
applied to waste streams are defined by the defined in Technical Guidance WM3, which
individual items placed in a receptacle; they is available in Appendix 1.3.
46
Figure 13 Waste segregation and classification

For information on
Is it identifying hazards
hazardous? and segregating Dental
Non -Hazardous No Yes
waste, see chapter 6
Uncontaminated Does it contain Infectious gypsum
Gypsum Does it contain Does it contain (18 01 03*, 18 02 02*)
medicines or
(18 01 04, 18 02 03) Yes gypsum No gypsum (casts Yes
hazardous Not exclusive
(from casts)? or dental)?
Infectious
Gypsum
Gypsum
chemicals? to dentistry
No
Yes No
Non -infectious Anatomical Dental Amalgam
Does it contain
(18 01 10*)
(18 01 02)
02, ) Yes anatomical
Yes
material?
infectious
Amalgam
Non -
No Does it contain
dental
(18 01 01, 18 02 01) Is it an amalgam?
Yes, from an Infectious waste containing
No separate bin - Yes uncontaminated infectious dental amalgam
Dispose of with sharp? (18 01 03* and 18 01 10*)
used sharps patient
No
Amalgam
Infectious
No
Non cytotoxic / cytostatic Is the item a

medicine waste medicine or non -
(18 01 09, 18 02 08, Yes X-ray fixer & Developer
sharp containing (09 01 01* - 09 01 05*)
20 01 32) Is it x -ray fixer
medicine? Yes
or developer?
No
X-ray
Medicinally contaminated
sharps Is it a sharp
(18 01 01 and 18 01 09) or
(18 02 01 and 18 02 08)
Yes containing No Radioactive Solid waste
medicines? (EWC code depends on properties)
No
No
Can it be
Offensive waste Is it
Yes decayed in
(18 01 04, 18 02 03, radioactive?
20 01 99)
storage? Low -level Radioactive
Yes Is it offensive? waste
Yes
Decay in storage
No
After
Confidential waste Decay
(various EWC codes)
Is it No
Yes Very Low -level Radioactive
confidential?
waste
No
Recyclable waste
(various EWC codes)
Is the item
Yes Does it contain Hazardous anatomical waste
recyclable? (18 01 03* and 18 01 06* / 18 01 07) or
hazardous Yes (infectious and / or (18 02 02* and 18 02 05* / 18 02 06)
anatomical chemically contaminated)

No material?
Domestic waste
(20 03 01) No
No Is it infectious?
Known infectious waste

Yes (no medicines)
No (18 01 03*, 18 02 02*)
Does it have
cytotoxic / Is it a sharp?
Is it a sharp? Yes
cytostatic Used, non medicinally
properties? contaminated sharps
Yes (18 01 03*, 18 02 02*)
No (infectious and
No (infectious and
medically
No Yes No chemically
contaminated)
contaminated)
Cytotoxic / cytostatic waste Cytotoxic / cytostatic sharps Infectious medicinally Infectious and contaminated Infectious and contaminated
(18 01 08*, 18 02 07*, (18 01 03* and 18 01 08* / 20 01 31*) or contaminated sharps with chemicals with medicines
20 01 31*) (18 02 02* and 18 02 07* / 20 01 31*) (18 01 03* and 18 01 09) or
(18 02 02* and 18 02 08)
(18 01 03* and 18 01 06* / 18 01 07) or
(18 02 02* and 18 02 05* / 18 02 06)
(18 01 03* and 18 01 09) or
(18 02 02* and 18 02 08) Hazardous
5.32 Healthcare products with hazardous • containing medicines which cause

properties, excluding medicines, should damage to cells (cytotoxic/cytostatic
have those properties clearly marked on wastes)
packaging, with a detailed description
included in the safety data sheet. • containing medicines or chemicals
which can harm humans or the
5.33 Hazardous properties of waste include: environment (chemical and medicinal
wastes)
• containing infectious pathogens
(infectious wastes)
47
• having radioactive properties form supplied by the manufacturer or

(radioactive wastes). distributor and does not consider the
effects of any subsequent dilution that may
5.34 Sharps wastes are not considered occur during routine use.
hazardous by themselves under the
definition of Technical Guidance WM3; 5.38 Medicines may take the form of pills,
however, once used, many sharps wastes liquids or powders in various containers,
generated in a healthcare setting will be gels, patches, ointments, aerosols or
hazardous. It should be noted that a non- intravenous (IV) fluids.
hazardous sharp may still cause needle-stick
injuries if handled inappropriately and 5.39 If a medicine is delivered via a sharp, it
should therefore be handled with caution. must not be disposed of with non-sharps
medicinal wastes. Excess liquid material in
5.35 Sharps from mass vaccination in non- syringes should not be discharged into
registered premises are not considered drains, but left in the syringe and placed
hazardous. In all other situations, sharps into the appropriate lidded sharps box
waste must be assessed for hazards. suitable for pharmaceutically contaminated
sharps – these are yellow for non-cytotoxic/
non-cytostatic and purple for cytotoxic/
Identifying hazards cytostatic.
5.36 Many hazards can be identified by
warning symbols located on packaging or 5.40 A sharp must be put in a bin for
signage and correspond to the hazards infectious, medicinally contaminated sharps
listed in Appendix 1.3. if it has been used on a patient in a
healthcare setting or has been in contact
Consideration should be given to which with infectious material.
ward/area the waste came from.
5.41 Medicine and chemical containers,
Wastes with certain hazards are unless completely empty and rinsed out,
generally only generated in specific should be assumed to be contaminated and
areas of a healthcare facility. should be classified based on the chemical
they contain.
These include radioactive wastes, which
will typically only occur in nuclear 5.42 Liquid medicines should not be
medicine departments, laboratories, discharged to the sewer; see paragraphs
operating theatres, and potentially in 5.144–5.174 for more information on
areas using X-ray equipment (radiation- treatment, recovery and disposal. Further
contaminated PPE). guidance is also available in Water UK’s
‘National guidance for healthcare waste
Known infectious wastes will usually water discharges’ (2014).
only come from wards treating patients
(or patient samples) and certain specialist 5.43 Used absorbents and spill-kits for
departments, including GUM clinics, skin chemical spills should be classified under
clinics and laboratories. Chapter 15 of the EWC.
5.44 Inhalers contain active pharmaceutical

Is it a medicine, or does it contain a ingredients (APIs) and should accordingly be
disposed of alongside other medicinal
pharmaceutically active medicine? waste by incineration through hospital/
5.37 Classification is determined by community pharmacy disposal or sent to a
assessment of the medicinal products in the permitted pharmaceutical aerosol recovery
48
process. This prevents the potent parent organisation, the pharmacy

greenhouse gas propellants used in must hold an environmental permit.
metered dose inhalers (MDIs) from leaking
into the atmosphere after disposal.
The World Health Organization’s
A pharmaceutically active medicine is ‘Guidelines for medicine donations’
one which may have an effect or impact (2010) should be followed when
on human biology. Non-pharmaceutically donating unneeded medicines
active medicines include saline, sterile internationally.
water, and sugar solutions.
5.45 Where non-pharmaceutically active IV Does the waste contain a cytotoxic or

fluids occur in small quantities and present cytostatic medicinal waste?
no other hazard, for example infection due
to contamination with body fluids or the 5.46 Cytotoxic and cytostatic medicines are
addition of pharmaceutically-active among the most dangerous drugs used in
substances, these can: healthcare. They are often used for
chemotherapy and other specialised
• be discharged to foul sewer, subject to purposes, but some are more commonly
approval by the sewage undertaker, prescribed, such as chloramphenicol.
and the empty containers can be
placed in the offensive/hygiene waste 5.47 A cytotoxic or cytostatic medicine is
stream defined within Technical Guidance WM3 as
any medicinal product that possesses one or
• be placed in the offensive waste more of the following hazardous
stream for EfW or another permitted properties:
process.
• HP6: Acute toxicity
Where medicines from a primary care • HP7: Carcinogenic
setting are taken to a pharmacy, for
example where the pharmacy supplies • HP10: Toxic for reproduction
medicines and collects unwanted
• HP11: Mutagenic.
material:
5.48 If a waste contains cytotoxic or
• cytotoxic
and cytostatic medicines
cytostatic material, it is both clinical and
must be consigned from the practice
hazardous and should be handled in
to the pharmacy, which must send the
compliance with HSE’s ‘Safe handling of
practice and the regulator consignee
cytotoxic drugs in the workplace – Health
returns
and Social Care’ (2013).
• other
medicines must be transferred
5.49 In England and Wales, mixing cytotoxic
using a duty of care waste transfer
and cytostatic medicines with other
note
medicines is prohibited except in homes.
• a
registered waste carrier is normally Medicines should be segregated at source
required to transport the material wherever possible.
• if
the practice is charged for 5.50 In a case where a healthcare
collection or disposal of the waste organisation receives mixed medicines from
medicines by the pharmacy or its a patient’s home, the consignment note for
the removal of mixed medicines must both
49
clearly identify the presence of wastes and

list the components, through EWC codes, X-ray fixer and developer wastes are
descriptions and hazardous properties. chemically hazardous but have their own
separate, specific containers (typically
white, clearly marked, resealable jugs).
SCOTLAND AND NORTHERN IRELAND:
Medicines should be segregated These wastes should not be mixed with

wherever possible; however, if mixed, each other or any other waste.
cytotoxic and cytostatic medicines and
other medicines should be labelled These wastes should be returned to the
using EWC code 18 01 08* (cytotoxic/ supplier or sent to a specialised, licensed
cytostatic) and EWC code 18 01 09 (other treatment facility.
medicines), with a description on the
consignment note that reads “cytotoxic 5.53 Gypsum, which is present in plaster
and medicines”. casts and certain types of dental mould,
should be segregated from other wastes
and disposed of in a designated gypsum
Does it contain any other chemicals? bin, or infectious gypsum bin.
5.51 This section is not provided for use in
assessing laboratory chemicals and Is it infectious?
reagents. It is provided as an overview to
5.54 Annex III of Directive 2008/98/EC
support the assessment of other healthcare
‘Waste Framework Directive’ defines
waste streams that may contain or be
“Infectious” as ‘waste containing viable
contaminated with waste chemicals.
micro-organisms or their toxins which are
5.52 The following advice applies for waste known or reliably believed to cause disease
chemicals: in man or other living organisms’.
• they should not be placed in clinical, 5.55 It is, however, very difficult to know
offensive or municipal waste streams; whether a waste contains viable micro-
in England and Wales such mixing is organisms without testing it, and it is not
prohibited feasible to test every piece of potentially
infectious waste. To determine whether a
• they should be segregated and waste is likely to be infectious, consider
packaged according to transport whether:
classifications and chemical
compatibilities • it came from a patient being treated
for infection or from contact with a
• they should normally be classified as patient carrying a transmissible
EWC code 18 01 06* or EWC code 18 disease, for example PPE items that
01 07 unless they are photo-chemicals, have come into contact with an
where these are classified under infectious patient
subchapter 09 01
• it came from a patient with a history
• hazardous properties should be of a known infection, for example a
assessed, and classification codes blood-borne virus or Clostridioides
assigned using the procedures set out difficile
in Technical Guidance WM3.
• it has been identified as infectious by
a clinician
50
• it is a culture, stock or sample of Does it contain recognisable human

infectious agents from laboratory tissue?
work or it has been in contact with
them. 5.58 Anatomical waste is waste which
contains recognisable human parts. It is not
5.56 If the answer is “yes”, the waste may necessarily hazardous on its own, but can
be infectious and should be treated as such: be infectious or contain hazardous
chemicals (or both).
• if it is infectious but does not have any
other hazardous properties, it should 5.59 Anatomical waste should be
be placed in an orange bag. The segregated, based on the hazards present,
orange bag is for wastes which are into the following categories:
only infectious.
• non-hazardous anatomical waste,
• if it is infectious and contaminated blood bags and blood preserves which
with medicines or chemicals, it should are not infectious or chemically
be placed in a yellow bag. The yellow contaminated
bag is for wastes which are believed
to be infectious, but that also contain • infectious anatomical waste which is
chemical or pharmaceutical not chemically contaminated
contamination. • chemically contaminated anatomical
waste which is not infectious
Nappies and personal hygiene wastes are
not considered infectious waste (unless • infectious and chemically
they are from an infectious person) and contaminated anatomical waste.
should not be put into a clinical waste
bin. They are considered offensive waste 5.60 In some healthcare scenarios it may
and go in a yellow and black striped bag. not be feasible to separate infectious
Only if they meet the criteria for “known anatomical material from non-infectious. In
infectious” (for instance, if they come such cases a single (red) infectious
from an isolation ward), should they go anatomical waste bin may be used.
in an orange bin.
If none of the above?
Nappies and sanitary pads never go in a
yellow bin. 5.61 If these considerations do not apply
and the waste is non-hazardous, assess
whether it is offensive, confidential,
Is it radioactive? recyclable or domestic waste. Key
management principles associated with
5.57 Radioactive materials should only be
these waste types are detailed in
generated by specific areas within a
Appendix 2.
healthcare facility such as nuclear medicine
areas, operating theatres and labs. No other
parts of a healthcare facility should Colour coding and storage
generate radioactive waste or handle
5.62 The colour-coded waste classification
radioactive material. Only staff with
system outlined in this section identifies and
specialised training should handle
segregates waste on the basis of waste
radioactive materials. For more information
type, hazard and suitability of treatment/
on radioactive waste, see paragraphs 5.174–
disposal options in line with the approach
5.207.
summarised in paragraphs 5.24–5.61
51
regarding classification and segregation of determine the type and quantity of bins
waste. needed and to inform storage and logistical
requirements, a waste audit must be
5.63 The use of this colour-coding system is performed as discussed in paragraphs 6.94–
unlikely to change; however, its 6.97.
implementation, such as which categories
are in use, may change in response to Wastes stemming from research,
emergencies and other impactful diagnosis, treatment or prevention of
developments such as pandemics, as disease involving animals are classified
discussed in paragraphs 6.143–6.158. using EWC codes beginning with 18 02.
5.64 This colour-coded system must be
utilised to aid the consistent identification 5.68 Note that the bodies of bins may be
and segregation of waste. any colour, as long as the bag, bin lid, and/
or label match the colour coding scheme
defined in Table 9 or the relevant colour
SCOTLAND:
coding system used in the pertinent
NHS Scotland employs a different colour- administration/country. This is to allow bins
coding system, which is outlined in made from recycled plastics which are often
Scottish Health Technical Note (SHTN) available only in limited colours, such as
3 (National Services Scotland, 2015). grey, due to manufacturing constraints.
Facilities in Scotland should adhere to
this distinct system. Container labelling
5.69 Each container must be labelled in
NORTHERN IRELAND: accordance with the details of the legal
requirements for transport and packaging.
Northern Ireland employs a distinct
colour-coding system, laid out in the 5.70 The container labels should clearly
Northern Irish Public Health Agency’s identify the waste type(s) present within.
‘Public Health Agency Infection Control The purpose of this is to ensure that wastes
Manual: Waste Management’. such as anatomical wastes and medicines
are not moved in yellow-topped bins,
which may lead to their subsequent
5.65 Regular training of all waste handling/ mismanagement, injury or legal
producing staff, and the use of written and consequences of incorrect handling or
visual reminders, are fundamental to disposal.
correct classification, segregation and
treatment. 5.71 In addition, the container should be
tagged or labelled in a manner that
5.66 Proper segregation of different wastes identifies the facility and place/ward of
is critical for safe management of origin. This is required by waste
healthcare waste and helps control management facilities in accordance with
associated hazards, environmental impact duty of care.
and costs. The use of colour-coded and
properly labelled receptacles is key to good 5.72 Bags should be labelled or tagged
segregation practice. individually, rather than just the container
(such as carts) holding the bags, as waste is
5.67 The number and type of bins used at a often repackaged during transport and
facility should be based on the types and handling.
quantities of waste generated. In order to
52
Table 9 Clinical waste colour coding and storage summary
Colour Waste stream Example items Disposal methods EWC codes Hazards Container Sharps
requirements
Yellow Infectious/medical/anatomical IV bags Incineration or 18 01 03* and Infectious (HP 9) Depends on May contain
waste requiring incineration alternative treatment 18 01 06* characteristics of sharps (in a
Pharmaceutically Medical/chemical
or alternative treatment at a suitably waste designated
contaminated sharps 18 01 03* and contamination
permitted facility sharps bin)
18 01 09
Chemically
contaminated lab 18 02 02* and
waste 18 02 05* or 18
02 06
Orange Known infectious Infectious dressings Alternative treatment 18 01 03* Infection Depends on May contain
Swabs at a suitably characteristics of sharps (in a
Phlebotomy needles/ 18 02 02*
permitted facility waste designated
syringes or incineration 18 01 01 sharps bin)
(legal, but not
recommended under 18 02 01
the waste hierarchy)
Purple Cytotoxic and cytostatic Chemotherapy drugs Hazardous/clinical 18 01 08* Cytotoxicity Depends on May contain
waste Incineration (damaging to cells) characteristics of sharps (in a
Other cytotoxic drugs 18 01 03* and waste designated
18 01 08* or sharps bin)
Other waste
20 01 31* contaminated with
18 02 02* cytotoxic: purple
striped bag
Sharps: sharps bin
Medicines: solid or
liquid rigid bin

L
53
54
Table 9 Clinical waste colour coding and storage summary (continued)
requirements
Yellow/Black Offensive/hygiene waste Used non-infectious EfW (can be 18 01 04 or Unpleasant, Tiger stripe bag Must not
PPE, sanitary waste/ incinerated at lower generally not only contain sharps
20 01 99
nappies temperatures than hazardous
infectious/known 18 02 03
Couch roll (paper used infectious streams)
to cover exam tables)
Landfill (legal, but
Non-infectious items not recommended
contaminated with under the hierarchy
blood and other body of waste)
fluids
Animal faeces/soiled
animal bedding
Red Anatomical waste Amputated tissue, Incineration 18 01 02 Unpleasant, Rigid containers Must not
full and partial blood generally not only. Red or red contain sharps
18 01 02 and
bags, and blood hazardous unless lidded. Marked as
preserves 18 01 03* (if infectious anatomical.
infectious)
Black Domestic/municipal waste Food packaging Recycling (limited 20 03 01 Generally, not Black bag or clear Must not
if recyclables are hazardous bag contain sharps
segregated at source)
EfW
Landfill
White Recyclable wastes Empty drinks cans Recycling Various Not hazardous White bag or clear Must not
(recycling) bag contain sharps
Glass
Paper (excluding
confidential)
requirements
Blue Medicinal waste Expired medicines Incineration/specialist 18 01 09, Chemical/ Blue lidded bin Must not
(excluding cytotoxic treatment environmental based on physical contain sharps
18 02 08, or
and cytostatic drugs) properties (sharps
20 01 32 go in a sharps
Testing kits bin, liquids go in
Medicines returned to a liquids bin, and
healthcare facilities by solids in a solids
the public bin).
Bags may be used

if they are in a
blue-lidded or
primarily blue
container.
Medicinal waste
should not be
stored in loose
bags
S L
Dental Dental amalgam Dental amalgam Recovery (non- 18 01 10* Chemical Specific, marked, Must not
amalgam infectious) (amalgam) white bin or contain sharps
Infection (if container labelled
18 01 03* infectious) with contents.
and 18 01 10
Amalgam Amalgam bins
(amalgam must feature
contaminated mercury vapour
with infectious suppressants.
material)
Infectious
amalgam must
be in separate

bins from non-
infectious.
Amalgam
Infectious
Amalgam
55
56
requirements
Gypsum Gypsum Gypsum Recovery (non- 18 01 04 Chemical Specific, marked,
infectious) (gypsum) white bin or
Infection (if container labelled
Incineration 18 01 03* infectious)
Gypsum with contents.
(infectious) (infectious
gypsum) Infectious gypsum
must be in
separate bins from
non-infectious.
Uncontaminated
gypsum may also
be disposed of
in a black and
yellow tiger-stripe
bag. Gypsum has
specific disposal
requirements,
and should not
be mixed with
offensive waste.
Gypsum
Infectious
Gypsum
requirements
Radioactive Radioactive waste Nuclear medicine Decay storage (for None Radiation Standard May contain
waste low level radioactive (radioactive bins or bags sharps (in a
May possess
wastes) waste is not appropriate to the designated
Radiation other hazardous
included in the characteristics of sharps bin)
contaminated PPE Aqueous waste properties (even
EWC) the waste being
disposal to sewers after decay) collected should be
Low-level
Specialist disposal (for used.
wastes should
radioactive wastes be assigned a These should be
which cannot be code based on labelled with
decayed on-site) their properties tape bearing the
after decay. trefoil symbol
and the word
“Radioactive”
and a reference
number and a
description of the
contents including
the radionuclide,
amount of
radioactivity
and date. Once
logged, the waste
should be stored
in an appropriately
shielded and
secure radioactive
waste store.
If stored until
decayed, the
radioactive tape
should be removed
before disposal
of the waste via
the standard
waste streams,

otherwise the
solid waste may be
disposed as such to
licensed specialised
contractors.
57
Radioactive
Radioactive
58
requirements
Recyclable Recyclable waste Empty, un- Recycling Various Not hazardous Clear (or green) Must not
contaminated drink bag or rigid bin contain sharps
Clean paper may be
cans
reused on-site for
Food packaging printing or other uses
(rinsed)
Devices/medicine
packaging
Non-confidential
paperwork
Newspapers
Confidential Confidential waste Paperwork containing Shredding, followed No specific EWC No hazard. Bag, rigid bin or Must not
patient data or by recycling code Separate stream console (no specific contain sharps
commercially sensitive due to data colour required;
information protection however, it is
legislation recommended to
standardise the
colour across the
organisation)
5.73 Contractors are required by the Bulk storage

Environment Agency to only collect
5.75 A summary of requirements for the
properly labelled waste. See the
storage of larger quantities of waste is
Environment Agency’s additional guidance
provided in Table 10.
for clinical waste for further information
(Environment Agency, 2011a, 2011b). 5.76 Note that these requirements apply
only to facilities which require a permit.
5.74 Each waste bag must be traceable back
Many healthcare facilities may qualify for a
to its producer; this includes the postcode,
waste exemption as set out in guidance
facility and department.
from the Environment Agency. Exempt
facilities should aim to comply with the
Labelling of individual bags may points below which are feasible and
not be practical in a busy or large relevant to their site, in order to minimise
healthcare facility. Pre-numbered tags risk.
or pre-printed stickers may be used for
labelling. 5.77 For further information refer to the
Environment Agency’s (2021b) guidance
‘Waste storage, segregation and handling
appropriate measures – Healthcare waste:
appropriate measures for permitted
facilities’.
Table 10 Summary of bulk storage requirements
Bulk storage requirements

Individual bags and containers (for example, bins and boxes) of waste must not be stored loosely. Bagged waste should be stored
and handled in fully enclosed, lockable, rigid, leak-proof and weatherproof containers.
Rigid waste containers (bins and boxes) must be sealed and in good condition. They should be stored and handled in an upright
position to minimise the risk of spillages.
Containers must have a lid which is securely closed whenever they contain any waste, except when waste is being loaded into or
unloaded from them.
Anatomical waste and animal carcasses must be stored in designated refrigerated units (operating below 5°C) unless stored on
site for less than 24 hours.
Infectious wastes that are not pharmaceutical, chemical, anatomical or palletised wastes must be stored in a secure building.
These infectious wastes may be stored outside at facilities that were operating before this guidance was published, but only if all
of these conditions are met:
• it is not technically or economically feasible to store them in a building
• alternative storage arrangements provide an equivalent level of environmental protection to storage in a building
• an appropriate site-specific environmental risk assessment is carried out which includes (but is not limited to) an assessment of
emissions to land and water (including odour), pests and flood risk
• the waste is in containers that remain closed and locked at all times, except when waste is being loaded or unloaded from them
• the containers are stored in a secure area of the site that has impermeable surfacing and sealed drainage.
Store and handle offensive wastes in a secure building or in secure, fully enclosed, rigid, waterproof and leak-proof containers.
If waste is stored externally in containers (such as 770l bins), the containers must remain closed at all times, except when waste is
being loaded or unloaded from them.
Do not store or hold wastes on site in vehicles or vehicle trailers, unless they are being received or prepared for imminent transfer
(that is, they will be removed from site within 24 hours, or 72 hours if over a weekend) or unless as agreed in response to an
emergency or business continuity scenario (see paragraphs 6.143–6.158).
Always maintain the integrity of waste packaging in a way that minimises handling. Never throw, walk on or handle healthcare
wastes in a way that might damage the packaging. Pay particular attention to items at or near the bottom of containers, and
avoid overloading, compressing or puncturing waste.
59
Transport and packaging 5.84 Healthcare waste dangerous goods

can be transported in two ways:
5.78 Dangerous goods are solids, liquids or
gases that can harm people, other living • packaging (boxed, drums etc.)
organisms, property or the environment.
Common examples originating from the • bulk loose material in skips, containers
healthcare sector include infectious and vehicles.
material, medical gases and radiotherapy
5.85 This section considers only packaging
isotopes, as well as some drugs and
and bulk transport with regards to
medicines.
healthcare waste, primarily clinical waste
5.79 Offensive wastes are not classified as and waste medicines.
dangerous goods and therefore can be
5.86 Healthcare organisations will often use
transported and packaged differently to
other dangerous goods, for example gases
other healthcare wastes which are classified
or cleaning materials, that are not dealt
as dangerous goods. For further guidance
with in this guide.
on appropriate management routes for
offensive waste, see paragraphs 5.224–
5.237. Further guidance on the transport of
dangerous goods can be found at the
5.80 Healthcare facilities (as producers) are following websites:
responsible for ensuring that dangerous
goods are packaged and labelled • The
HSE’s ‘Carriage of Dangerous
appropriately, and are transported off-site Goods Manual’ provides guidance on
by a properly licensed contractor, in all aspects of road transport.
compliance with the Carriage Regulations.
• The
Vehicle Certification Agency’s
5.81 Contractors have a legal requirement (VCA) website provides the Packaging
to collect only waste which is properly Approvals database, which lists all UN
labelled, with the producer identified. approved packaging.
• The
Department for Transport’s
5.82 The Carriage Regulations specify the
website provides guidance on
requirements for packaging, marking,
transporting dangerous goods and
labelling and documentation, for which the
copies of authorisations.
duty rests with healthcare organisations as
the consignor in the first instance. • The
ONR website provides guidance
on the transport of radioactive
‘Carriage Regulations’ is used to refer to materials.
the Carriage of Dangerous Goods and
Use of Transportable Pressure Equipment For detailed advice contact the VCA at
(EU Exit) Regulations (2020). packagingdg@vca.gov.uk
5.83 The Carriage Regulations use criteria

that are different from other legislative Dangerous Goods Safety Advisor (DGSA)
systems. They require that all dangerous 5.87 Under certain circumstances, the
goods be identified using a four-digit Carriage Regulations require healthcare
number (UN number) and a description organisation sites to appoint a DGSA. The
(proper shipping name) and are assigned to requirement to appoint such a person is a
a “class” of dangerous goods. duty on the employer and is in large part
60
dependent on the quantity of dangerous • advising the employer on the

goods transported. transport of dangerous goods
5.88 DGSAs will be required when the • ensuring that an annual report to the
quantity of healthcare waste classified as employer is prepared on the activities
dangerous in transport exceeds certain of the employer concerning the
thresholds in ADR (see Table 15). transport of dangerous goods
Transporting UN 2814, UN 2900, UN 3549
(Category A) or radioactive materials • monitoring practices and procedures
(Class 7 – UN Nos. 2912 to 2919, 2977, 2978 relating to the activities of the
and 3321 to 3333) requires a DGSA. employer.
5.89 Larger healthcare organisations, for For further information, see the
example hospitals, may need to appoint a Department for Transport’s (2020)
DGSA, while small clinics and surgeries may guidance on employing a DGSA.
not.
5.90 From 2023, organisations whose main Transport of packaged goods

or secondary activities are not the carriage,
loading or unloading of dangerous goods 5.94 Once the UN number of a substance is
but which move such goods only known, ADR provides information on the
occasionally will need to appoint a DGSA. packing group, packing instruction and any
special packing provisions that apply.
5.91 If an organisation requires a DGSA to
advise on transport of radioactive materials, 5.95 Table 11 shows the most common
the DGSA must have specialist knowledge packing provisions for healthcare waste.
of Class 7 transport.
* UN 3373 “BIOLOGICAL SUBSTANCE,
5.92 It is important that all those involved CATEGORY B” should never be used
in the movement of healthcare waste are for waste consignments.
aware of the person providing DGSA
support. The name and contact number(s) ** The three categories are generic
of the DGSA(s) should be listed in the and will not be appropriate for
healthcare waste management policy. all medicines, including cytotoxic
and cytostatic. Some waste will be
5.93 Healthcare organisation sites that do classified in accordance with ADR
not need to appoint a DGSA may still find it but in some cases, a safety data
useful to approach DGSA consultants for sheet (SDS) for the medicine would
general advice on an ad-hoc basis to ensure show the appropriate transport
that they, as consignors of dangerous classification. Advice from a DGSA
goods, are complying with the should be sought where such
requirements concerning classification, information is not provided in the
packaging, marking, labelling and Safety Data Sheets.
documentation.
5.96 All packaging, including UN-approved
The functions of the DGSA include: packaging or packaging for limited
quantities used for dangerous goods, must
• monitoring compliance with the rules be fit for purpose and capable of safely
governing the transport of dangerous containing the goods when used in
goods transport, whether it is carrying liquids or
solids.
61
Table 11 Packing provisions for healthcare waste
Dangerous goods Proper shipping name Packing Packaging examples

UN number instruction
Category A
UN 2814 INFECTIOUS SUBSTANCE, AFFECTING HUMANS P620 UN approved three part
UN 2900 INFECTIOUS SUBSTANCE, AFFECTING ANIMALS P620 Packaging for relevant

packaging instruction
UN 3549 MEDICAL WASTE, CATEGORY A, AFFECTING HUMANS, solid P622/LP622
UN 3549 MEDICAL WASTE, CATEGORY A, AFFECTING ANIMALS only, P622/LP622

solid
Category B*
UN 3291 CLINICAL WASTE, UNSPECIFIED, N.O.S. P621 (table Rigid packaging/
12) wheeled bins
IBC620 (waste placed inside

a bag, bin or other
LP621 container)
Medicinal waste**
UN 1851 MEDICINE, LIQUID, TOXIC, N.O.S. LQ/P001 Boxes, drums
UN 3248 MEDICINE, LIQUID, FLAMMABLE, TOXIC, N.O.S. LQ/P001
UN 3249 MEDICINE, SOLID, TOXIC, N.O.S. P002/LQ Two part packaging
Dental amalgam
UN 2025 MERCURY COMPOUND, SOLID, N.O.S. P002 Boxes, drums

LQ (PGII & III)
Aerosols
UN 1950 AEROSOLS P207/LP200/ Boxes

LQ
5.97 Tables 12 and 13 define the common 5.98 Paragraph and chapter references in
packing instructions for healthcare waste. Table 12 are to sections in UNECE’s (2020)
‘Agreement concerning the International
Table 12 Packing instruction P621
Carriage of Dangerous Goods by Road
(ADR)’.
P621 PACKING P621
INSTRUCTION
5.99 Paragraph and chapter references in
This instruction applies to UN No. 3291.
Table 13 are to sections in UNECE’s (2020)
The following packagings are authorised provided the ‘Agreement concerning the International
general provisions of 4.1.1 except 4.1.1.15 and 4.1.3 are met:
Carriage of Dangerous Goods by Road
(1) Rigid, leak-proof packagings meeting the requirements of
Chapter 6.1 for solids, at the packing group II performance
(ADR)’.
level, provided there is sufficient absorbent material
to absorb the entire amount of liquid present and the 5.100 Where a packing instruction is
packaging is capable of retaining liquids.
indicated in Table 11, only packaging that
(2) For packages containing larger quantities of liquid, rigid has been UN-tested and approved (unless
packagings (drums, jerricans and composites) which
conform to the packing group II performance level for otherwise specified) must be used. Such
liquids. packaging can be identified by the UN mark
Additional requirement: applied to the package. An example of a
Packagings intended to contain sharp objects such as broken
mark is shown in Figure 14.
glass and needles must be resistant to puncture and retain
liquids under the performance test conditions in Chapter 6.1. 5.101 If the letter “S” appears in the UN
mark, as shown above, the packaging may
only be used for solids or inner packagings,
62
Table 13 Packing instruction P622
P622 PACKING P622

INSTRUCTION
This instruction applies to UN No. 3549 carried for disposal.
The following packagings are authorised provided the general provisions of 4.1.1 and 4.1.3 are met:
Inner Intermediate Outer packagings

packagings packagings
Metal Metal Boxes

Plastics Plastics
Steel (4A), aluminium (4B), other metal (4N), plywood (4D), fibreboard (4G), plastics,
solid (4H2)
Drums
Steel (1A2), aluminium (1B2), other metal (1N2), plywood (1D), fibre (1G), plastics (1H2)
Jerricans
Steel (3A2), aluminium (3B2), plastics (3H2)
The outer packaging must conform to the packing group I performance level for solids.
Additional requirements:
• Fragile articles must be contained in either a rigid inner packaging or a rigid intermediate packaging
• Inner packagings containing sharp objects such as broken glass and needles must be rigid and resistant to puncture
• The inner, intermediate, and outer packaging must be capable of retaining liquids. Outer packagings that are not capable of
retaining liquids by design must be fitted with a liner or suitable measure of retaining liquid
• The inner packaging and/or the intermediate packaging may be flexible. When flexible packagings are used, they must be
capable of passing the impact resistance test of at least 165 g and the tear resistance test of at least 480 g in both parallel and
perpendicular planes with respect to the length of the bag. The maximum net mass of each flexible inner packaging must be
30 kg
• Each flexible intermediate packaging must contain only one inner packaging
• Inner packagings containing a small amount of free liquid may be included in intermediate packaging provided there is
sufficient absorbent and solidifying material in the inner and intermediate for all liquid content present. Suitable absorbent
material which withstands the temperatures and vibrations liable to occur under normal conditions must be used
• Intermediate packagings must be secured in outer packagings with suitable cushioning and/or absorbent material.
Figure 14 UN mark example for solids or inner packaging
1H2/Y1/S/21/GB/4532
1 st digit identifies ‘H’ indicates Y = packing S = solids Year of GB = Great Identification

type of construction group or inner manufacture Britain of type
container: material: packagings (Authorising approval
1 = 1kg
(that may State)
1 = drum A = steel contain
liquid)
2 = barrel H = plastic
3 = jerrican
4 = box
5 = sack
63
for example bottles that may contain Specific packaging issues

liquids.
5.106 Table 14 addresses most of the
5.102 Most sharps receptacles are type- common considerations with regard to
approved for solids only and must not be transporting healthcare waste.
used for the disposal of liquids. However, it
is recognised in the testing of these Waste medicines
packagings that there may be small
amounts of liquid residue from syringes, 5.107 Dangerous goods must not be
vials etc. and that the packaging must be packed together in the same outer
able to retain these quantities, usually by packaging, or in large packages with
means of some absorbent material. dangerous or other goods, if they react
dangerously with each other.
5.103 Where Intermediate Bulk Containers
(IBCs) are used, they must be inspected 5.108 Waste medicines should, as far as
every five years. Producers and users of possible, be disposed of in their original
containers marked as IBCs must be able to packaging (such as the blister pack or
verify that an IBC older than five years has bottle). This will help to minimise the risk of
been inspected and labelled as approved. a dangerous reaction. External packaging
(typically cardboard or paper) must be
removed and disposed of separately.
Limited quantities
5.104 ADR specifies that some dangerous If solids are still in their original blister
goods in small quantities do not need to be packs or are bagged/bottled, they
packaged in UN-type approved packaging. should be collected and placed in
This is referred to as limited quantity suitable outer packaging for transport
exemptions. (such as fibreboard or plastic boxes). This
will require labelling in accordance with
Note: Such dangerous goods will be ADR – mainly, such packages are likely to
packaged in a small receptacle of no fall under limited quantity provisions.
more than 5 L for liquids or 5 kg for
solids of PGIII, and never more than 1 5.109 A similar procedure can be adopted
L for liquids or 1 kg for solids of PGII, for liquids, provided measures are taken to
several of which may be placed in an minimise the likelihood of breakage of the
outer packaging that may not exceed a primary packaging (such as cushioning/
gross mass of 30 kg in total. absorbent material).
As this is a widely misunderstood 5.110 Where the pills are loose or the
concept, advice must be sought from a liquids container has lost its closure
DGSA if these provisions are planned for (stopper/cap), a suitable receptacle that is
use. compatible with the product should be
used. Once a suitable receptacle is found,
5.105 There is no limited quantity provision the procedures above can be followed.
for clinical waste (UN 3291) or category A
medical waste (UN 3549). Batteries including those used for
implants and medical devices
5.111 Where healthcare facilities provide
recycling bins for batteries, they will be
required to comply with the requirements
64
Table 14 Specific packaging issues
Specific packaging issues Summary

Clinical waste (UN 3291) P621, see Table 12, addresses boxes and drums whilst LP621/IBC620 is for large packaging such as
wheelie bins.
Community nurses collecting small amounts of clinical waste in their vehicles should ensure
they use a rigid, secure, and leak-proof receptacle, in which bags can be placed (see paragraphs
6.16–6.32 on community healthcare).
Category A clinical waste Occasionally, waste from the treatment of a patient meets Category A criteria (for example an
infectious substance which is carried in a form that, when exposure to it occurs, is capable of
causing permanent disability, life-threatening or fatal disease in otherwise healthy humans or
animals). Indicative examples of substances that meet these criteria are given in A1.1: Category
A Pathogen List. This list details which cultures can be classified as infectious substances of
Category B when originating from diagnostic or clinical purposes.
To prevent over-classification of Category A waste, it is important to note that some diseases/

infections on the A1.1: Category A Pathogen List are only applicable when in culture form.
When not in cultured form these wastes are to be classified and transported as clinical waste
(UN 3291).
Wherever possible, the waste should be treated on-site to render it safe (see paragraphs 5.143–
5.173) to transport as non-dangerous goods. From a laboratory the shipment will have to be
classified as UN 2814 and packaged in accordance with P620. Where the waste has come from
the delivery of patient care it will be classified as UN 3549 and packaged in accordance with
P622 (Table 13).
To move Category A waste, ensure that a DGSA is appointed and consulted.
Sharps packaging Sharps receptacles are tested and approved for solids only. They are not approved for the
carriage of liquids. However, most sharps will be contaminated with liquids/fluids. A few
millilitres of liquid are unlikely to present a risk of adverse chemical reaction, and such quantities
in a sharps receptacle are acceptable for transport. However, the pouring of liquid from partially
used vials of liquid or the discharging of syringes into sharps receptacles is not permitted.
Sharps bins should be manufactured to standard BS EN ISO 23907-1 (single use), BS EN ISO 23907-
2 (reusable).
Cleaning receptacles The Carriage Regulations require that no dangerous goods residue must contaminate the
outside of packaging. If any dangerous substances contaminate the inside of a receptacle, the
receptacle, even though nominally empty, must continue to be treated as dangerous goods.
It is important that healthcare waste policies include a cart-cleaning procedure clearly specifying
frequency and monitoring of the cleaning process to avoid the potential for cross-contamination
between sites. Further details can be found in paragraphs 5.128 and 5.140.
Soiled surgical instruments Where healthcare organisations are obliged to carry used medical devices or equipment by road
that are potentially contaminated with or contain infectious substances which are being carried
for disinfection, cleaning, sterilisation, repair or equipment evaluation, the carriage is exempt
from the terms of ADR, providing the following conditions are met:
• The packagings are designed and constructed in such a way that, under normal conditions
of carriage, they cannot break, be punctured, or leak their contents, and the packagings are
designed to meet the construction requirements listed in 6.1.4 or 6.6.4 of ADR
• The packagings meet the general packaging provisions of 4.1.1.1 and 4.1.1.2 of ADR and are
capable of retaining the medical devices when dropped from a height of 1.2 metres
• The packagings are marked “USED MEDICAL DEVICE” or “USED MEDICAL EQUIPMENT”. When
using overpacks, if the mark is not visible, they need to be marked.
This agreement does not apply to:

• medical waste (UN 3291 and UN 3549)
• medical devices or equipment contaminated with or containing infectious substances in
Category A (UN 2814 or UN 2900)
• medical devices or equipment contaminated with or containing other dangerous goods that
meet the definition of another hazard class.
65
of the Hazardous Waste Regulations and Typical UN marking will start:

the Carriage Regulations, which establish
special rules for packaging. • 50H/Y/mm
yy – large rigid plastic
packaging
5.112 Nickel cadmium and lead acid
batteries should be segregated and • 50A/Y/mm
yy – large rigid steel
recycled/disposed of appropriately. packaging
5.113 Used lithium and lithium-ion cells and • 11H2/Y/mm

yy – rigid plastic IBC
batteries (UN 3480, UN 3481, UN 3090 and (Intermediate Bulk Container)
UN 3091) collected and presented for
carriage for disposal between the consumer • 4H2/Y/mm yy – solid plastic boxes
collecting point and the intermediate
processing facility, together with other • 5H4/Y/mm yy – bags
non-lithium cells or batteries (UN 2800 and
• (mm
yy = month and year of
UN 3028), are not subject to the
manufacture)
prohibitions and requirements of ADR
provided they meet these conditions:
5.116 Marking is the application of the UN
• they must be packed in IH2 drums or number and where necessary the proper
4H2 boxes conforming to the packing shipping name onto the package.
group II performance level for solids
5.117 Labelling is the application of the
• not more than 5% of each package
label (commonly referred to as the hazard
must be lithium and lithium-ion
warning diamond) appropriate to the class
batteries
of dangerous goods. The labels must be
• the maximum gross mass of each 100 mm × 100 mm except that when the
package must not exceed 25 kg size of the package requires, the dimensions
may be reduced provided they remain
• the total quantity of packages per clearly visible.
transport unit must not exceed 333 kg
5.118 Table 15 shows the nine classes of
• no other dangerous goods are carried.
dangerous goods. Some additional
5.114 For further information on recycling examples below are given of dangerous
batteries, including the battery compliance goods in each class, which may be
schemes and how to comply with the generated from healthcare, with the
Regulations, refer to the Environment appropriate hazard warning diamond for
Agency’s ‘Waste batteries: producer the primary hazard.
responsibility’ (2018).
Marking and labelling of packaging

5.115 Large packaging also known as
“wheelie bins” should be used, with the
waste contained in a UN-certified plastic
bag which in turn is placed in the bin.
66
Table 15 UN classification and hazard warning diamonds
UN classification Examples of material from Hazard warning diamonds

healthcare premises
Class 1 Explosives Flares

1.4
*
1
Class 2 Gases Compressed Oxygen (UN

1072); CO2 (UN 1013); LPG
(UN 1978); Nitrous oxide (UN
1070); Aerosols (UN 1950) 2
Class 3 Flammable liquids Fuel (UN 1202, UN 1203);

Alcohol, Adhesives, Paints
Class 4.1 Flammable solids
Class 4.2 Spontaneously combustible

This class provides raw
materials for some drugs and
medicines
Class 4.3 Dangerous when wet
DANGEROUS WHEN WET
Class 5.1 Oxidiser Oxygen generator (UN 3356),

some cleaning solutions
Class 5.2 Organic peroxide Disinfectants and laundry

chemicals
Class 6.1 Toxic Poisons, some disinfectants

and drugs
TOXIC
Class 6.2 Infectious substances Infectious waste (UN 3291)

including pathogens
Category A substances (UN
2814/ 2900/ 3549)
Category B substances (UN 6
3373)
Class 7 Radioactive Long half-life solid

radioactive waste
RADIOACTIVE RADIOACTIVE
Contents Contents
Activity Activity
7
8 7
8
8 8
Class 8 Corrosives Bleaches, cleaning materials
CORROSIVE
67
UN classification Examples of material from Hazard warning diamonds

healthcare premises
Class 9 Miscellaneous Batteries, asbestos (UN 2590),

some drugs
Note:
This is not a comprehensive list of UN numbers of Class hazard warning diamonds. A full list of the hazard warning diamonds can
be found in ADR.
5.119 For dangerous goods in limited

quantities, the only mark required is as
illustrated in Figure 15. A DGSA should be
consulted to determine where the use of
limited quantities is appropriate.
Figure 15 Limited quantities markings
OR
Y
M
M
n
n
in
in
io
io
im 10
im 10
m ns
m ns
um 0
um 0
m e
m e
0 im
0 im
di m
di m
10 m d
10 m d
m
m
m
m
en
en
u
u
im
im
si
si
on
on
in
in
M
The marking on the left should be used bulk (for example the carriage of hazardous
for land transport. Some packages infectious waste in bags in a BK2 approved
may have the marking on the right, vehicle or trailer), the full provisions apply
indicating that they are permissible in immediately regardless of load or vehicle
land transport but also meet additional size.
air transport requirements, although
5.122 Where practical, the use of approved
the mark alone does not indicate that air
bulk transport should be encouraged rather
shipments will be permitted.
than the use of large packaging, as it
improves the efficiency of logistics and
5.120 When the limited quantities mark is minimises the environmental impact and
used, there is no requirement for the UN associated carbon impact of waste
number to appear on the package. transport, helping to support the
implementation of the NHS Net Zero Plan
Bulk transport which is discussed in Chapter 2.
5.121 Bulk transport of wastes classified as 5.123 A health and safety assessment
UN 3291 is permitted. The load thresholds should be undertaken prior to the use of
(see Table 15) only apply to waste in bulk transport, as the loading/unloading of
packages, in accordance with the packaging bulk vehicles, and rapid handling of large
instructions. Therefore, if waste is carried in
68
quantities of waste can pose a health and offensive wastes should be stored in larger
safety risk to staff. quantities before transport for treatment,
recovery or disposal is arranged.
This could be achieved by storing larger
quantities of packaged waste material Transport on the road
before it is removed from site, where
space and permitting arrangements 5.130 Dangerous goods in limited quantities
allow. Alternatively, vehicle space can as described in Table 15 are not subject to
be fully utilised by arranging a transport all provisions of the Carriage Regulations
route which has multiple healthcare and do not count towards load thresholds.
collection points.
UN 1851, 3248 and 3249 are usually
5.124 For bulk transport of healthcare transported in limited quantities.
waste, a DGSA must be consulted.
5.131 ADR allocates transport categories
which are linked to packaged dangerous
Transport of offensive wastes load thresholds over which the full
5.125 By definition, offensive wastes are provisions of ADR apply, including the
not classified as dangerous goods, and requirement to appoint a DGSA. For
therefore transport and packaging of such healthcare waste, these thresholds are
wastes need not comply with the indicated in Table 16.
requirements of ADR.
Table 16 Load thresholds
5.126 Unlike dangerous goods, offensive

Transport Substance Quantity
waste can be transported in non-UN- category
approved packaging; for instance, offensive
0 Category A substances (UN 0
waste bags can be disposed of in plastic 2814/2900/3549)
carts which do not have to be yellow in
2 Clinical waste (UN 3291) 333 kg/L
colour.
1 Medicines/chemical wastes PG I 20 kg/L
5.127 Offensive waste and pharmaceutical/ 2 Medicines/chemical wastes PG 333 kg/L
medicinal waste should not be moved in II (UN1851/3248/3249/cytotoxic
drugs)
bins marked and labelled as Class 6.2, UN
3291. The marks/labels should be removed 3 Medicines/chemical wastes PG 1000 kg/L
III (UN1851/3248/3249/cytotoxic
or covered. drugs)
Note: consult ADR for full details

5.128 Waste carts which store offensive
waste bags only need to be cleaned when a
visual inspection after tipping has identified 5.132 Below these thresholds the following
the cart as unclean or malodorous, for apply:
example there is evidence of leaks, spillage • one 2 kg fire extinguisher must be
or contaminated contents. carried on the vehicle
5.129 Offensive wastes may be compacted • general awareness training of all
prior to transport, unless prohibited in the involved in the transport operation
environmental permit, which increases must be provided.
vehicle efficiency by maximising load
capacity. If site storage capacity allows,
69
Above the threshold, the following cases, although waste contractors may
applies: be willing to assist with compilation of
the appropriate documentation, the
• additional vehicle equipment, fire legal duty remains with the consignor.
extinguishers and PPE must be Documentation is likely to be needed
provided to comply with the Hazardous/Special
Waste Regulations, the requirements of
• vehicles must be marked with orange which are detailed in paragraphs 6.84–
plates if the goods are packaged, and 6.142.
if in bulk they must be fitted with
plates described in Schedule one of
the Carriage Regulations 5.136 The Department for Transport may
impose specific conditions on any approved
• formal ADR-approved driver training authorisations to mitigate the risk of
must be provided spillage and contamination during
transport.
• additional operational provisions
as specified in ADR must be Example circumstances which may
incorporated require authorisation are:
• a DGSA must be appointed. • use of a bulk haulage vehicle without
BK2 type approval to clear waste
5.133 Where small quantities of clinical backlogs during an emergency event
waste (UN 3291) are carried in M1 vehicles,
private cars and car-derived vans for • use of non-UN-approved packaging
example (as happens in community nursing when there is a supply shortage
for example), there is no need to carry a
2 kg fire extinguisher.
Carriage on ships in UK waters
5.134 Bags of waste up to 15 kg must not 5.137 When transporting dangerous goods
be placed directly into any vehicle, including including waste materials by sea, the
a car (derogation 17 of ADR). They must be International Maritime Dangerous Goods
placed in a rigid, secure and leak-proof (IMDG) code must be followed. This code
outer packaging duly approved for the was developed as a uniform international
purpose. Community practitioners must be code for the transport of dangerous goods
trained on the transportation of waste, as by sea covering such matters as packing,
specified in ADR Chapter 3. container traffic and stowage, with
particular reference to the segregation of
Documentation incompatible substances.
5.135 Authorisations must be acquired from 5.138 Dangerous goods for a sea passage
the Department for Transport for the must be declared on a dangerous goods
transport of dangerous goods in packaging note to the shipping line and be
which is not UN-approved. These are only accompanied by an SW28 Competent
approved in extenuating circumstances. Authority Approval for each load. The
documents described in the compliance
For wastes consigned in limited section of Chapter 6 meet the requirements
quantities or moved by a healthcare of the IMDG code, provided the transport
worker from a private home, transport information is included. This will apply to
documentation is not required. In other shipments from Northern Ireland, the Isle of
70
Wight, the Scottish Isles and other locations 5.142 Road derogation 11 of ADR states
outside of the UK mainland. that Class 2 to 6, 8 or 9 materials can be
transported between one part of a private
premises and another part of the premises
On-site transport within the immediate vicinity, even when
5.139 On roads to which the public do not separated by road, without having to meet
have access, dedicated trucks, trolleys, tugs the Carriage Regulation requirements.
or wheeled containers may be needed to
transport waste receptacles to storage For example, when dangerous goods
areas; they should not be used for any other are transported between two separate
purpose, in order to prevent contamination. buildings at the same hospital, but they
are separated by a road, the Carriage
Service roads need to be designed and Regulations in this instance would not
constructed so that they: apply.
• are easy to clean and drain

Treatment, recovery and disposal
• contain any leakage from damaged
receptacles or containers 5.143 This section focuses on the
established techniques that are used to
• permit easy loading and unloading of render safe clinical waste.
containers
5.144 All treatment and disposal facilities,
• do not offer harbourage for insects regardless of size or type of technology
or vermin used, are required to “render safe” clinical
waste. The requirements of rendering safe
• do not allow particles of waste to depend on the type of waste treated and
become trapped on edges or crevices. on the nature of the contaminants present
in the waste. They will also be subject to
5.140 Containers for on-site transport need detailed control by the relevant
to be steam cleaned or disinfected environmental regulator.
following leakages or spills, and at regular
intervals. If containers are heavily used,
cleaning is likely to be required. The
Rendered safe
effluent water from washing infectious “Rendered safe” is an accepted method
waste containers must be captured. This can or process that has been applied which:
be difficult on-site if there is not a purpose-
built cleaning space. For this reason, a) demonstrates the ability to reduce
washing of infectious carts is often the number of infectious organisms
performed by a specialist contractor. The present in the waste to a level at
healthcare waste procedures need to which no additional precautions are
specify the method and frequency of steam needed to protect workers or the
cleaning or disinfection. public against infection from the
waste
5.141 Internal vehicles (or equipment)
should not be used to transport waste b) destroys anatomical waste such that it
materials on roads to which the public have is no longer generally recognisable
access unless they meet the full provisions
of the Carriage Regulations as appropriate.
71
c) renders all clinical waste (including 5.147 Where these have not been met, the
any equipment and sharps) unusable waste is not considered to have been
and unrecognisable as clinical waste rendered safe. This is applicable if it is
intended that the material is to be
d) destroys the component chemicals of subsequently sent to landfill, in which case
chemical or medicinal and medicinally further treatment would be required.
contaminated waste.
5.148 A detailed explanation of the
“rendered safe” criteria is provided in
5.145 Alternative treatment plants, except Table 17.
those treating anatomical, medicinal or
chemical wastes, should demonstrate the
two criteria (a) and (c) detailed above in Treatment, waste management and
order to demonstrate that the waste is disposal systems
rendered safe. These criteria apply to:
5.149 Treatment and waste management
a. all non-incineration technologies that systems for healthcare waste can take
are used to treat clinical/healthcare several different forms:
waste
• hazardous waste or clinical waste
b. each individual device regardless of incineration
load capacity and permitting status
• conventional/hybrid EfW incineration
c. existing operational devices, as well
as devices being newly installed. • non-burn/low-temperature alternative
treatment
5.146 The additional criteria (b) and (d) will • other emerging technologies
apply if anatomical, chemical or medicinal
wastes are treated. • landfill.
Table 17 Summary of rendered safe criteria
Criteria Summary
A: reduction in pathogen Microbial inactivation is a critical element of the “rendering safe” of certain types of healthcare
numbers waste. There are three critical aspects:
• for infectious waste, the treatment must demonstrate, as a minimum, the Level III criteria
provided by the State and Territorial Association on Alternative Treatment Technologies
(STAATT) or equivalent
• for cultures of pathogenic microorganisms, the Level IV criteria must be achieved (pre-
maceration or shredding is not appropriate for such wastes)
• the ability to achieve these criteria must be demonstrated for the worst-case challenge load,
and in a manner that meets the requirements of any applicable guidance issued by the waste
regulatory agencies.
B: destruction of anatomical Treatment of anatomical waste requires that the waste be rendered unrecognisable in suitable
waste permitted facilities, which at this time means incineration. Sensitive anatomical wastes may be
taken for burial if requested.
C: unusable and This criterion applies to both non-incineration and incineration technologies. The treatment
unrecognisable or incineration must ensure that there is no recognisable clinical waste remaining. This reduces
the likelihood of the waste causing offence. Note that confidential material may need to be
processed separately to meet British Standards for secure disposal, and so should be segregated
from clinical waste streams, and managed/treated/disposed of separately.
D: the rendering safe All pharmaceutically active substances, both hazardous and non-hazardous, present in the
of pharmaceuticals and medicinally contaminated waste, and any waste chemicals, should be destroyed during disposal
chemicals within the waste at a suitably authorised facility. For further information on management of controlled drugs, see
the Controlled Drugs (Supervision of Management and Use) Regulations 2013 and paragraphs
6.16–6.32.
72
5.150 Whilst not strictly considered 5.155 The list below is not exhaustive, and
treatment, landfill disposal for offensive not all techniques may be in use or common
EWC 18 01 04 wastes remains a disposal in the UK at time of reading. New
option for some healthcare wastes specified technologies are continuously evolving and
in the offensive waste section. This should being adopted. For more complete
only be used as a last resort, with guidance, see the United Nations
preference given to incineration with Environment Programme’s ‘Compendium of
energy recovery, such as conventional EfW, Technologies for Treatment/Destruction of
as per the waste hierarchy discussed in Healthcare Waste’ (2012) and the WHO’s
paragraphs 3.2 –3.19. ‘Overview of technologies for the treatment
of infectious and sharp waste from health
5.151 While there are a large number of care facilities (2019).
systems available to treat healthcare waste,
they use heat, chemicals, irradiation or
combinations of these methods. The Discharge to sewer
selection of the most appropriate system is 5.156 Discharges of some waste streams to
dependent on: sewer may require the prior agreement of
the statutory responsible bodies. Water
• the type of waste to be treated
UK’s ‘National guidance for healthcare
• staffing requirements waste water discharges’ (2014) provides
additional information on specific waste
• the volume of the waste to be treated streams. Disposing of any waste to the
• initial and continuing operating costs sewer may present a substantially greater
risk of damage to the sewerage
• support capabilities of the supplier. undertakers’ assets than domestic sewage,
and healthcare organisations should first
5.152 Treatment, recovery and disposal seek advice from the sewerage undertaker.
methods need to be reliable and capable of
consistently achieving the required standard 5.157 Some examples of typical sewer
of treatment. For guidance on what is discharges are:
required to comply with an environmental
permit for the treatment of healthcare • body fluids, such as blood and similar
waste, see the Environment Agency’s potentially infectious substances, for
(2021b) guidance ‘Waste storage, example from suction canisters or
segregation and handling appropriate wound drains
measures – Healthcare waste: appropriate • photo-chemicals (X-ray): these are
measures for permitted facilities’, and suitable for recycling, which means
paragraphs 6.108–6.117. that it is poor practice, even if
permitted by a discharge consent, to
5.153 The types of waste which can be
discharge this material to foul sewer.
accepted by different treatment facilities
The approval of the sewerage
will be determined by their permit. Some
undertaker should be sought
permits may not allow laboratory wastes or
other waste streams to be accepted. • discharge of shredded material: it is
essential that the sewerage
undertaker is aware of the presence
Treatment options to render safe
of this material and that its disposal is
5.154 A summary of treatment methods to permitted by the producer’s trade
render safe clinical waste is included in effluent consent
Table 18.
73
Table 18 Treatment methods to render safe
Treatment Description
Chemical disinfection Chemical process with disinfectant such as chlorine or sodium hypochlorite (bleach). Treatment
uses oxidising properties to sterilize wastes prior to permanent disposal. This process may
require additional pre-treatment such as grinding.
Steam autoclaving Steam autoclaving is the most common method of medical waste treatment. It involves utilising
closed chambers that apply heat and pressure over a period of time to reach sterilization. This
process is done in batches, and generally is not utilised for materials that can combust or melt at
low temperatures. Treated material still requires further disposal, typically done through non-
hazardous landfilling.
Auger An auger uses heated oil or steam to sterilize waste which is moved through a screw-shaped
chamber. The oil or steam does not come into contact with the waste, and may be heated
electrically or with a burner.
Gamma irradiation Utilises cobalt, which gives out gamma radiation, to sterilize waste. This method is generally
considered high-cost due to the cobalt use. Not suitable for pathological waste. In the UK, this
technology is typically used to treat equipment prior to use, rather than waste.
Microwave irradiation Steam-based process where steam is generated by microwave energy (2450 MHz at a
wavelength of 12.24 cm) from water contained in the waste. This treatment is an emerging
technology but is rapidly becoming widely utilised. The treatment consists of a chamber where
the waste is heated up to 121ºC. Waste is considered non-hazardous once treated. Suitable to
treat biohazardous, infectious, sharps and sludge. The process is generally considered faster
than autoclave treatment.
Radio frequency irradiation These systems apply low-frequency radio waves to inactivate microbes contained within the
waste. These waves heat the waste from the inside of the materials to their external surfaces.
Frictional treatment This emerging treatment is based on using friction generated by rotor blades and heaters
to achieve required sterilization temperatures. Waste is typically shredded and heated up to
135–150°C for several minutes. Vapours flow through heat exchangers and filters before being
released.
This in an emerging technology which is not yet well established in the UK.
Hazardous or clinical waste Dual chamber incinerators burn waste in the primary combustion chamber above 850°C.
(HCW) incineration Multiple oil or gas burners maintain the temperature in the primary chamber. Vapours produced
in the primary chamber are directed into a secondary chamber which has more burners to
bring the temperature to above the 1100°C required to treat HCW. Flue gas treatment is
recommended to reduce air pollution and may be required by the relevant national legislation.
Incineration can reduce the waste quantity by up to 80% and is unsuitable for inert wastes.
• radioactive waste from nuclear (2015) guidance on the Permitting

medicine diagnostic studies and Regulations and in line with the conclusions
treatments with low concentrations of of the European Commission’s ‘Best
radioactivity with short half-lives: Available Techniques (BAT) Reference
water-miscible waste may be disposed Document for Waste Incineration’ (2019).
of in sewers within permitted levels
from the relevant competent SCOTLAND:
authority.
Facilities in Scotland should refer to
5.158 Seek advice from the sewerage The Waste (Scotland) Regulations 2012,
undertaker before disposing of material to and SEPA guidance for instruction on
the sewage network. Medicines, cytotoxic incinerating waste.
and cytostatic waste should not be disposed
of in sewers. NORTHERN IRELAND:
Facilities in Northern Ireland should refer

Incineration to The Waste Incineration Regulations
5.159 Incineration must be performed in (Northern Ireland) 2003.
compliance with the Environment Agency’s
74
Conventional energy from waste On-site vs off-site treatment

treatment considerations
5.160 Clinical waste can sometimes be 5.165 On-site treatment refers to the
incinerated alongside other waste streams, treatment of waste at the same healthcare
for instance municipal or industrial waste facility at which it is generated, and may
streams in conventional energy from waste include autoclaving in purpose-built
(EfW) facilities. This is only suitable where autoclave facilities before waste is
there are existing local municipal transported off-site. Check whether there
incinerators that have the appropriate are regulatory position statements (RPSs)
permit to accept clinical waste. These sites covering the relevant treatment method.
may be publicly or privately operated. This may include the compaction and baling
of non-clinical wastes.
5.161 EfW facilities operate by incinerating
the material, producing gas and ash. Many Managers of on-site waste treatment
EfW facilities do not have a secondary and disposal facilities need to work to
high-temperature chamber, and thus audited procedures which take into
generally do not burn at high enough account the risks to operators as well as
temperatures to render cytotoxic or prion- to other people on the site, as well as
contaminated waste fully safe. Once the need to maintain standards of waste
incinerated, ash is collected for aggregate treatment.
production or disposal, and exhaust gases
are cleaned through physical and chemical
systems. 5.166 Adopting on-site treatment can help
healthcare organisations to reduce reliance
5.162 Offensive waste is increasingly on third-party capacity.
accepted for treatment at EfW facilities and
is a good way of moving the waste stream 5.167 On-site treatment may also allow
up the waste hierarchy and away from healthcare organisations to have more
landfill disposal, which in turn generates control over their own waste management
energy. systems, and supports the proximity
principle set out in paragraphs 3.20–3.29.
5.163 Other permitted recovery options
may also be suitable. If there are permitted 5.168 Dependent on the assessment of
recycling facilities available which can quantities of waste and specific treatment,
accept offensive waste, this should be given on-site facilities may support net zero
preference over EfW or other recovery carbon by reducing emissions associated
options. with haulage. It can also help healthcare
organisations take more control of direct
5.164 Waste must be correctly segregated emissions from treatment.
to help ensure that it is sent to the most
appropriate form of treatment. More 5.169 When assessing options for on-site
information on classification and treatment, facility managers should assess:
segregation is included in paragraphs 5.24– • the quantity and type of waste
5.61 and on offensive waste in paragraphs produced
5.224–5.237, regarding how to correctly
identify and segregate each waste type. • the layout of the facility and the
amount of space available
75
• local constraints, for example planning This waste requires disposal in suitably
permission, environmentally sensitive licensed facilities, normally by incineration.
receptors. Appropriate packaging is required for
radioactive waste in line with transport
5.170 In exceptional circumstances, for requirements. Radioactive materials and
example an autoclave malfunction, waste waste should only be handled by trained
that is normally autoclaved, such as professionals.
microbiological cultures and other
infectious waste classified as Category A 5.175 This section covers the management
infectious substances in ADR, should be of two main types of radioactive waste:
packaged for carriage and transferred to an low-level radioactive waste; and solid
incinerator as soon as possible. radioactive waste produced from healthcare
activity where routinely used, disposable
5.171 All on-site treatment facilities are solid items become contaminated with small
likely to require an environmental permit or amounts of radioactivity. It does not cover
a valid exemption from the regulator as the management and disposal of aqueous
detailed in paragraphs 6.84–6.142. This radioactive waste or spent sealed sources.
includes facilities that only treat waste
produced on site. 5.176 The difference between the two
types of radioactive waste is:
5.172 Off-site treatment refers to the
treatment of wastes at an authorised facility • low level radioactive waste is shorter
separate from the site at which they were half-life waste that can be subjected
produced. This may include off-site to decay in storage on the premises
incinerators or alternative treatment until it is essentially non-active, and
facilities. These facilities are typically then disposed of within the usual
operated by private contractors in the UK. waste stream for that type of waste
• solid radioactive waste is waste that
5.173 When assessing off-site treatment
cannot be subject to decay in storage
and management facilities, the following
on site and will need to be
factors should be considered:
transported off-site to a suitably
• the cost of sending waste to this licensed disposal facility in full
facility compared with the cost of compliance with the transport
on-site treatment regulations.
• the operator’s track record
Radioactive healthcare wastes
• whether on-site treatment is feasible
on site, based on floorspace, layout, 5.177 Common radioactive healthcare
permitting, local constraints, cost and wastes may include:
other relevant factors • syringes and needles used to prepare
• what alternative arrangements are and administer diagnostic and
possible, and whether these can be therapeutic radiopharmaceuticals
adopted in the event of an • PPE used by staff handling such
emergency. material
• other disposable equipment used in
Radioactive waste nuclear medicine procedures.
5.174 Radioactive healthcare waste is waste
contaminated with low-level radioisotopes.
76
5.178 Some radioactive wastes may be 5.185 If an organisation is regularly involved

referred to as low-level radioactive waste in the transport of radioactive materials, a
(LLW) or very low-level radioactive waste DGSA must be appointed who has specialist
(VLLW). knowledge of Class 7 transport.
5.179 Radioactive waste generated from 5.186 The Ionising Radiations Regulations
healthcare includes radionuclides used in set out the responsibilities of employers for
therapeutic and diagnostic medicine. This the radiation safety of staff and for
waste is considered to be LLW and typically minimising the risk of harm when they are
falls into one of three categories: exposed to ionising radiation, including the
requirement to ensure that doses are as low
• long half-life as reasonably practicable.
• radioiodines
5.187 Employers must notify the HSE of
• other beta/gamma emitters. their intention to work with ionising
radiation at least 28 days prior to the
5.180 Further guidance and information on commencement of work. Any site wishing
thresholds is available in the Department to use radioactive materials must be
for Business, Energy & Industrial Strategy’s permitted to hold, accumulate and dispose
‘Scope of and exemptions from the of radioactive materials.
radioactive substances legislation in
England, Wales and Northern Ireland: NORTHERN IRELAND:
Guidance document (2018).
The Ionising Radiations Regulations and
Legislative background and key staff its amendments apply in England, Wales,
and Scotland. For Northern Ireland,
5.181 Facilities handling radioactive material see the Ionising Radiations Regulations
must comply with the Environmental (Northern Ireland) (2017).
Permitting Regulations as set out in Table 5
– ‘Summary of waste and environmental
5.188 The 2018 Ionising Radiation (Medical
legislation’ in Chapter 4.
Exposure) (Amendment) Regulations
5.182 To comply with legislation, a (IR(ME)R) set out the basic safety standards
radioactive waste adviser (RWA) must be for the radiation safety of patients, to
appointed to advise on the application of ensure that their exposures are justified and
best available techniques for the optimised.
accumulation, management and disposal of
5.189 Any healthcare organisation exposing
radioactive waste.
patients to ionising radiation must appoint
5.183 The RWAs will work with a suitably qualified and experienced
environmental regulators including the medical physics expert (MPE). MPEs will be
Environment Agency, SEPA, NIEA and NRW involved in the day-to-day use of
to ensure that radioactive wastes radioactive materials and are important for
generated, stored and disposed do not compliance with IR(ME)R and all of the
exceed permitted levels. relevant regulations.
5.184 Transport of radioactive materials 5.190 Any employer working with ionising
must comply with the Carriage of radiation must consult with a suitable
Dangerous Goods regulations as described radiation protection adviser (RPA) to advise
in paragraphs 5.78–5.142. on compliance. The role of an RPA is
advisory, and it is the responsibility of the
77
healthcare organisation to ensure to allow demonstration of compliance with

compliance. The RPA should work with relevant environmental permits.
healthcare staff and a DGSA to ensure the
safe management of radioactive materials, 5.195 All containers of radioactive waste
including waste. Further details are set out must be clearly labelled as radioactive –
in paragraphs 5.78–5.142. marked with the word “Radioactive”, with
the ionising radiation symbol (trefoil) with a
Specialist advisers appointed by label indicating the radionuclides in the
healthcare organisations and key container, and the area/facility of origin.
personnel from all areas producing
5.196 Radioactive wastes should be stored
radioactive wastes should be engaged
separately from other waste streams, in
in the development of a site-specific
secure, locked locations, which meet the
radioactive waste management plan and
requirements of any relevant environmental
identify the best options to minimise the
permits/authorisations. Records of
generation of radioactive waste in order
radioactive waste generation, storage,
to minimise the impact of discharges on
removal and disposal should be kept,
people and the environment.
allowing demonstration of permit
compliance.
5.191 An RWA will also advise on the
application of best available techniques 5.197 Radioactive material and radioactive
(BAT) and best practicable means (BPM), waste must not be moved to other
which is a requirement of any permit/ departments or premises unless it is allowed
authorisation for the accumulation, under the conditions of the facility permit.
disposal, or management of radioactive
waste, the main aim of which is to identify
the best options to minimise the generation Accumulation and decay storage of low-
of radioactive waste and thus to minimise level radioactive waste
the radiological impact of discharges on 5.198 Standard sharps bins or bags
people and the environment. appropriate to the characteristics of the
waste being collected should be used. Once
5.192 Facilities where radioactive materials
sealed:
are used, including waste storage areas,
should be designed specifically for the • these should be labelled with tape
purpose and should help minimise waste bearing the trefoil symbol and the
generation and the risk of contamination. word “Radioactive”
5.193 Detailed systems of work should be in • a reference number and a description

place to manage the use of radioactive of the contents, including the
materials, and where this occurs in several radionuclide, amount of radioactivity
departments or areas within a facility, there and date should also be recorded in a
should be central oversight of the overall suitable database
use of radioactive materials in the
• after logging, the waste should be
organisation.
stored in a dedicated, appropriately
5.194 All radioactive supplies should be shielded and secure radioactive waste
closely managed and controlled throughout store
their lifecycle with detailed records at all • following a suitable period of storage
stages (ordering, storage before use, use, until decayed, any radioactive symbols
accumulation/storage and disposal of waste)
78
must be removed before disposal of 5.205 Only suitably experienced couriers

the waste via standard waste streams. should transport radioactive materials, and
radioactive packages should only be
5.199 Decay stored waste should be released to appropriately trained drivers.
monitored before final disposal via the
standard waste stream, with suitable 5.206 Responsibilities for the package
records generated. during transportation, including emergency
arrangements, should be agreed between
5.200 Different radionuclides should the consigner and courier before
generally be accumulated in separate bins transportation.
and segregated according to their half-life.
Dental waste
Off-site disposal of solid radioactive waste
5.207 This section deals with waste streams
5.201 Two disposal methods are possible for and considerations which are likely to be
solid radioactive waste: specific to dentistry. Information on other
waste streams is included in paragraphs
• return to supplier where possible, for
5.24–5.61 and further information on
instance generators and spent fuel
dental waste is provided in the British
sources
Dental Association’s ‘BDA advice: Healthcare
• solid waste containing long-lived waste’ (2016).
radionuclides may need disposal
off-site to a suitably permitted/ 5.208 Dental practices must comply with
authorised radioactive waste disposal the same key legislation as hospitals, GP
site. practices and all other healthcare facilities.
This guidance sets out how to classify, store
and handle the wastes generated by dental
Transport of solid radioactive waste facilities.
5.202 Suitable containers for transport of
radioactive materials must be used, and all 5.209 Dental practices will produce a wide
instructions for their use must be followed. range of both hazardous and non-
These may require certification by the hazardous wastes and are likely to produce
appropriate competent authority waste streams not found at other
depending on the amounts of radioactivity healthcare facilities, specifically including:
to be transported. • non-infectious dental amalgam
5.203 Radioactive waste should only be • infectious waste containing dental
prepared for consignment under the amalgam
transport and carriage regulations by
suitably trained staff, as set out in • alginate/gypsum moulds.
Key considerations
5.204 Radioactive waste is classified as Class
7, and the hazard warning labels required 5.210 When deciding whether a saliva-
will vary dependent on the radionuclide contaminated item is an infectious or
and amount of radioactivity present. Staff offensive waste, a risk assessment should be
will need appropriate specialised radiation performed based on the patient and the
detection equipment to assess the status of circumstances.
the package before shipment.
79
5.211 As the disposal of teeth from dental 5.215 Gypsum should be treated as its own
premises is unlikely to cause offence, dental waste stream and should not be mixed with
practitioners may treat this as non- any other wastes. Gypsum can emit
anatomical infectious waste. It is common hydrogen sulphide, which is a toxic odorous
practice for non-amalgam teeth and gas if it comes into contact with
spicules to be placed in the yellow-lidded biodegrading material like organic waste.
sharps receptacle; however, this should be Sending items with a gypsum component to
for just broken or jagged teeth, with whole non-hazardous landfill is prohibited.
non-infectious teeth treated as offensive
waste. 5.216 Gypsum may be sent to a hazardous
waste landfill, provided the landfill has a
5.212 Dental practitioners must ensure that dedicated area for its management, or sent
all waste is treated appropriately, and that to a permitted facility for recovery, which is
teeth containing amalgam are disposed of the preferred option.
as dental amalgam waste. Specialised
containers known as tooth pots, crown pots
and bridge pots may be used to store
Dental amalgam
extracted amalgam-contaminated teeth, 5.217 Dental amalgam is a mixture of
crowns and bridges. For further information metals, consisting of liquid mercury and
see paragraphs 5.217–5.222 on dental powdered alloy containing silver, tin and
amalgam. copper. It is considered hazardous waste
due to its high mercury content of up to
5.213 Dental practices can minimise their 50%:
waste footprint through sustainable
procurement as described in paragraphs • in liquid form it has limited absorption
2.25–2.30. Practices should evaluate each through skin
waste type they produce for hazards and • in vapour form it is extremely toxic,
consider whether they must be treated as absorbed through lungs, which
clinical waste. damages the immune system and is
dangerous to unborn children.
A University of Plymouth study found
that a dental practice could save an 5.218 Due to its unique characteristics,
estimated 0.55 tonnes of CO2 equivalent dental amalgam should be treated as its
(a 16% reduction) by treating the own waste stream, with separate bins for
single-use plastic wrapping from sterile infectious and non-infectious amalgam.
equipment as recyclable instead of
clinical waste (Richardson et al., 2016). 5.219 Amalgam waste may be packed in
accordance with the SDS provided by the
manufacturer, but the package should be
Gypsum marked with UN 2025. For further guidance
on SDSs, see paragraphs 2.40–2.52.
5.214 Gypsum is often used in dentistry to
make moulds and study models. Gypsum 5.220 Dental amalgam bins must be
should not come into direct contact with sealable and made from puncture-resistant
patients. Instead, alginate is used to mould rigid material and must contain a mercury
the patient’s mouth, and the gypsum mould suppressant. Bins must be clearly marked as
is made using this alginate mould. It is dental amalgam and should feature the
therefore very unlikely that gypsum waste hazard symbols relevant to mercury (toxic,
will be infectious. long-term health hazard and environmental
hazard).
80
5.221 If transporting dental amalgam to more expensive waste management

waste, a container certified for transporting handling and treatment of such wastes.
mercury may need to be used as set out in
paragraphs 5.78–5.142. Offensive wastes which are commonly
over-classified as hazardous or infectious
5.222 Substances containing mercury are include:
regulated by the Control of Substances
Hazardous to Health (COSHH) Regulations • PPE – only clinical if contaminated
(2004). with infectious fluids, chemicals or
radiation and
Offensive waste • single-use gowns and other items
5.223 Offensive waste is waste that: that touch patients – as with PPE,
offensive unless hazardous.
• is not clinical waste
• is not infectious, but may contain 5.227 Correctly classifying and segregating
body fluids, secretions or excretions offensive waste is vital to achieving targets
as set out in the NHS Clinical Waste
• is non-hazardous Strategy.
• falls within waste codes 18 01 04 if
from healthcare, 18 02 03 if from Offensive wastes generated by
research, diagnosis or treatment healthcare facilities will fall into one of
involving animals, or 20 01 99 if from two categories:
municipal sources.
• healthcare offensive wastes which
5.224 Most offensive waste is considered would not be generated outside of a
“offensive” due to its potentially healthcare facility:
unpleasant odour and appearance. Some
– single-use instruments (tongue
materials classified as “offensive” may not
depressors, specula)
be readily unpleasant, for instance used PPE
(see Figure 16 for examples of offensive – used gowns
waste).
– used PPE which has not been
5.225 Offensive wastes may be generated contaminated with bodily fluids
both within healthcare facilities and in the
– dressings from non-infectious
wider community.
patients
Offensive waste is non-hazardous. • household and municipal offensive
If an item is known to be infectious, wastes which could be generated
contaminated with chemicals/medicines, outside a healthcare setting:
is radioactive, or is sharp, it is not
offensive waste. – nappies and adult continence
products, colostomy bags, catheters
5.226 Before disposing of an item in the – used personal hygiene products
infectious waste stream, consider whether
the item is hazardous, or in fact just – non-infectious dressings.
unpleasant. The over-classification of
offensive waste as infectious waste can lead
81
Figure 16 Examples of offensive waste
Offensive waste
Used, Used Non- Gloves Non-

non- nappies infectious infectious
infectious dressings swabs and
PPE cotton
5.228 Offensive waste should only be to foul sewer. For further details see
placed in a yellow and black-striped paragraph 5.36.
(“tiger”) bag.
5.229 Sharps are not considered offensive

Handling offensive waste
waste as they could pierce the bag, and so
sharps must always go in a sharps bin. 5.233 By definition, offensive waste is not
hazardous. However, hand washing and
5.230 If there is no good reason to believe ensuring that clothing and PPE are clean
the item is hazardous – ie infectious, after handling it are recommended.
chemically/pharmaceutically/cytotoxically
contaminated or radioactive – do not
dispose of it to a yellow, orange or purple Disposal or recovery of offensive waste
bin/bag or other container for hazardous 5.234 Offensive waste is suitable for
waste. conventional EfW, provided that the site at
which it is intended to be treated is licensed
5.231 As they are non-hazardous, offensive and permitted to do so. Currently, no
wastes do not need to be autoclaved or technologies exist to recycle offensive
pre-treated before being sent for disposal waste, so recovering energy from it using
or recovery. Laboratory wastes which have incineration is the best available method
been autoclaved are however considered under the Waste Hierarchy. Doing so will
offensive waste, as long as they do not also help the NHS achieve its landfill
contain chemicals. diversion targets. Offensive waste must be
correctly classified and segregated to help
5.232 It is typically acceptable to dispose of support this.
liquid offensive wastes such as urine, liquid
faeces and vomit to the sewer. 5.235 Most non-hazardous landfills will
accept offensive waste for disposal;
Landfilling liquids is prohibited under however, this should be used as a last
the Environmental Permitting (England resort. When offensive waste is sent to
and Wales) Regulations (2019), the conventional EfW it be could considered by
Landfill (Scotland) Regulations (2003) the regulator as “recovery” if the facility
and the Landfill Regulations (Northern achieves the required level of efficiency,
Ireland) (2003). Therefore, non- known as R1 value (which is 0.6 for facilities
pharmaceutically active liquids (for operating before 1 January 2009 and 0.65
example intravenous saline bags) should for facilities operating after 31 December
not be placed in the offensive waste 2008). The use of modern EfW facilities with
stream if they still contain free-flowing the higher R1 value is therefore
liquid. These should instead be emptied encouraged.
82
5.236 Offensive waste may be shredded

and further processed into refuse-derived
fuel, in order to make it more suitable for
EfW processes, or suitable as a fuel for
other purposes.
83
6.0 Management approach
6.1 The purpose of this chapter is to management policy and should be

provide an overview of the approach to the consistent with this guidance.
management of healthcare waste. It is not
intended to be a prescriptive guide but is Checklist for a waste management policy
intended to set out the key principles or plan
associated with key management functions.
• definitions for the various waste types
In-house services • employer’s and employee’s
6.2 All healthcare organisations should responsibilities
have a waste management policy or plan,
• education and training requirements
herein called a waste management policy,
and materials
in place. An electronic copy should be
openly available on the organisation’s • waste management strategy
intranet.
– waste avoidance, reuse and recycling
6.3 A waste management policy is (and associated targets)
intended to set out a simple and pragmatic
– waste handling, storage and
approach to be implemented by
transport arrangements
organisations in all circumstances, including
when waste management services, – waste treatment and management
including management or treatment, are routes
delivered in-house.
• continuous improvement and audit
6.4 The waste management policy should requirements
clearly identify the date of commencement
and include a review date, being no more • occupational health and safety
than two years after commencement. measures
• purchasing and green procurement

6.5 The waste management policy should
may also be referenced.
list all the organisation’s facilities that
generate healthcare waste, including any
site at which healthcare is consistently
delivered by registered practitioners, as well
Governance arrangements
as those that generate hazardous wastes. 6.7 A healthcare waste policy requires
waste producers and staff involved in the
6.6 Organisation-specific waste management of waste to accept their
management guidance or training material responsibilities and to take all reasonable
should be included within the waste measures to ensure that the waste is dealt
84
with appropriately from the point of 6.10 The steering group (or other waste
production to the point of final disposal. management governance body) should
include arrangements for ensuring that this
6.8 Effective and active waste HTM is properly implemented, and should
management must be part of everyday establish monitoring tools to identify gaps
practice and be applied consistently across or weaknesses in compliance. This steering
healthcare sites. Good waste management group would strive to improve compliance
and organisational processes are crucial to in managing waste and recommend
prevent the mixing of waste types, ensuring improvement actions.
proper waste segregation, correct
consignment and proper treatment/ 6.11 Typical roles and responsibilities for the
disposal. See Figure 17 for key waste robust management and oversight of waste
manager measures. management are illustrated in Table 19,
with further details contained in the NHS
6.9 Effective governance is crucial in Clinical Waste Strategy.
ensuring that waste is managed in a safe
and sustainable manner. Larger healthcare
organisations should establish an internal Data recording, monitoring and
steering group that has oversight of all reporting
waste management activities and processes, 6.12 Very few healthcare organisations have
to ensure governance procedures are fully a dedicated waste data analyst who is
implemented. Waste management may also trained to collate and accurately report
be governed through existing groups, such waste data. This includes ERIC returns from
as IPC, H&S, etc., provided the necessary NHS Trusts and NHS Foundation Trusts.
level of oversight is provided.
Figure 17 Key waste manager measures
Controls Precautions Responsibilities
• assessing risk
• training and information
• developing appropriate • duty of care in the
• personal hygiene management of waste
policies
• segregation of waste • duty to control polluting
• putting arrangements in place
to manage risks • the use of appropriate emissions to the air
personal protective equipment • duty to control discharges to
• monitoring the way in which
(PPE) sewers
arrangements work
• immunisation
• being aware of legislative
change • appropriate procedures for
handling such waste
• appropriate packaging and
labelling
• suitable transport on-site and
off-site
• clear procedures for dealing
with accidents, incidents and
spillages
• appropriate treatment and
disposal of such waste
85
Table 19 Typical roles and responsibilities
Role Location Responsibilities

Organisation Chairperson Hospitals Ensure governance procedures required in HTM 07-01 are established across
Healthcare the health organisation to avoid non-compliance leading to enforcement
facilities actions by the regulator.
Provide capital resources to implement HTM 07-01 across the healthcare

organisations.
Estate and Facilities Hospitals Ensure the safe and compliant management of waste.
Director Healthcare
Direct and support the establishment and management of on-site waste
facilities
infrastructure and services.
Waste Manager Hospitals Develop and implement waste policies and organisation-specific guidance
Healthcare in line with current legislation; be accountable for implementation of HTM
facilities 07-01.
Promote and provide the structure and resources to allow the effective
segregation of clinical waste.
Collate and report all accurate waste data as required in ERIC and ensure
compliance with duty of care responsibilities.
Steering Group Corporate Develop tools to monitor implementation of HTM 07-01.
Recommend actions with timeline for implementation where gaps are

identified from a compliance perspective.
Dangerous Goods Safety Hospitals Externally sourced third-party or internal staff to advise and undertake
Advisor Healthcare duty of care audits in accordance with current waste legislation.
facilities
Nurses, Doctors, Dentists, Hospitals Compliant segregation of waste at source.

Optometrists, and other Healthcare
Implementation of waste hierarchy.
practitioners and clinicians facilities
Consultants Hospitals Segregate waste at source and assist in the development of strategies for
Healthcare sustainable purchasing.
facilities
Procurement Managers Hospitals Deliver the safe and sustainable selection of health products and waste
Healthcare services.
facilities
Implement sustainable procurement initiatives.
GP Provider (contract Primary Care Account for compliance in relation to the wastes generated at their
holder) premises.
Identified Accountable Primary Care Promote the effective segregation of healthcare waste and individual
Individual responsibilities for waste management. Work with Waste Managers
and regions to appoint managing agents and develop re-procurement
approaches for primary care.
General Practice Clinical Primary Care Responsible for the safe disposal and segregation of clinical waste.
staff
General Practice Non- Primary Care Where needed, support the movement of healthcare waste containers and
Clinical staff coordination with waste contractors.
Pharmacists Primary Care Compliant segregation of waste at source.
Implementation of waste hierarchy.
Pharmacy staff Primary Care Segregate waste at source, and liaise with clinical waste contractors for
collection (and commissioners as required).
Radioactive Waste Adviser Hospitals Advise on the disposal and management of radioactive waste.
Healthcare
facilities
86
6.13 Waste data supports compliance Community healthcare

requirements and addresses responsibility
6.17 Community healthcare can take many
under duty of care requirements. Without
forms and occurs in various environments.
any built-in validation checks and regular
It includes activities undertaken by all
audits of waste data, pro-active data-led
healthcare staff who provide services
decision-making and risk management is
outside of hospitals or healthcare facilities
impacted.
to:
6.14 It is important that all data is recorded • patients in their own homes
in a consistent and accurate manner,
meeting the data quality standard that • residents of care homes without
will be developed by NHSE following nursing care
implementation of the NHS Clinical Waste
• householders who are self-medicating
Strategy.
and self-caring.
6.15 Clear guidelines and definitions should
6.18 Healthcare staff working in the
be provided wherever data is entered. The
community are responsible for the waste
data provided will be utilised to estimate
produced as a result of their activities and
the carbon emissions from waste
should otherwise comply with the duty of
management, allowing the implementation
care requirements set out in paragraphs
of actions that will help the NHS to meet its
6.87–6.92.
net zero waste targets.
6.19 All healthcare organisations have a
6.16 Table 20 summarises the types of data
legal duty to ensure that wastes produced
that should collated and, where applicable,
by the actions of healthcare staff in the
requested from the contractor.
community, for example in a patient’s
home, and classified as hazardous due to an
inherent risk of infection, cytostatic/
Table 20 Key waste data capture requirements
Types of data Justification Frequency of Monitoring

reporting responsibility
Incineration Most expensive treatment option and misclassification Monthly Healthcare organisations
increases carbon emission significantly and Waste Manager
Alternative treatment Less carbon intensive Monthly Healthcare organisations

and Waste Manager
Offensive waste Large volumes generated Monthly Healthcare organisations

and Waste Manager
Confidential waste Compliance with the General Data Protection Monthly Waste Manager
Regulation (transposed into UK law by the Data
Protection Act 2018)
Non-clinical waste to Landfilling cost increase year on year and landfill Monthly Waste Manager
landfill diversion reduces carbon emission
Non-clinical waste Resource conservation Monthly Waste Manager

recycled including food
WEEE The volume of waste is expected to grow exponentially Monthly Waste Manager
Radioactive waste To monitor generation levels Monthly Medical physicist/RWA

To monitor compliance with environmental permits
Landfill diversion To demonstrate progress made Monthly Healthcare organisations
87
cytotoxic, sharp or other hazards, are not pads when they originate from a healthy
placed into the domestic waste stream for population.
disposal.
6.24 There are, however, exceptions to this
Community practitioners should: restriction:
• mixed domestic waste can contain
• formally adopt a method of risk-
small numbers of plasters, dressings
assessing waste with a demonstrable
and incontinence products. Where
audit trail of decisions
similar wastes are produced as a result
• make provision for the appropriate of treatment, these can be double-
segregation and packaging of the bagged and placed in the domestic
different waste streams, set out in waste dustbin with the householder’s
paragraphs 5.24–5.61 permission
• where the quantity produced is less
• implement an uncomplicated method
than 7 kg per collection period.
for undertaking or arranging safe
and legal collection and disposal 6.25 If the waste is classified as hazardous,
of the waste whilst minimising cost the staff handling it should either:
to the organisation, as detailed in
paragraphs 5.78–5.142. • remove that waste from the home
and store it in approved containers.
6.20 Community practitioners carrying Healthcare workers conducting home
waste are required to receive ADR visits should carry suitable containers
awareness training. as part of their equipment if there is
potential for the removal of
6.21 Community healthcare may involve hazardous waste
limited quantities of anatomical waste, for • check that a suitable area for waste
instance from home births or other sources. storage is available in the home,
This should be managed in accordance with where it will not harm residents, and
the guidance set out in Chapter 5. is not accessible to pests and pets;
inform the patient of the relevant
6.22 Further guidance on the sensitive
risks and obtain their informed
handling of pregnancy remains is available
consent; and arrange for the waste to
in the Human Tissue Authority’s ‘Guidance
be removed by the local authority or
on the sensitive handling of pregnancy
an appropriate contractor.
remains’ (2021).
6.26 When assessing whether the
Healthcare worker intervention healthcare waste should be classed as
infectious or not, consideration must be
6.23 When patients are treated at home by given to the medical history of the patient,
a community nurse or healthcare where available, and any clinical signs and
professional, any waste produced as a result symptoms indicating a potential infectious
is considered as healthcare waste. If the risk. The assessment for infectious
waste is non-hazardous, and is properties of the waste must be made at
appropriately bagged and sealed, it is the time the waste is generated.
acceptable for the waste to be disposed of
with household waste. This is usually the 6.27 Classification may need to be reviewed
case with non-infectious dressings, personal and changed as additional information
hygiene products, nappies and incontinence about the patient becomes available; for
88
example if a patient’s condition changes to • advise on local waste management

the extent they demonstrate symptoms of options.
being infectious, the waste may need to be
reclassified. 6.31 Non-infectious body fluids should not
be disposed of in either the offensive waste
6.28 Table 21 provides a generic assessment stream or the domestic waste stream where
that may be used to aid classification of the the likely destination is landfill.
waste.
6.32 Any liquid waste classified as offensive
6.29 Staff should not use a patient’s own following a risk assessment may be disposed
sharps container for sharps waste, and of either:
should carry a UN-approved sharps
container to remove any sharps generated • into the foul sewer at the premises
during home treatment. • by being absorbed onto a cloth or
solidified with absorbent or gelling
6.30 Where the householder is a self- granules before being placed into the
medicating patient who uses injectables bin. There should be no free-flowing
with no healthcare staff involved in the liquid present.
administration, the GP or healthcare staff
should prescribe the householder a sharps 6.33 Hazardous liquids should be placed
bin relevant to the medication being into sealed, leakproof containers and
administered and: removed from the patient’s home for
• provide training in the safe use of the disposal; this is detailed in paragraphs
bin 5.62–5.77.
• show how to correctly seal and label

the bin as detailed in paragraphs
5.78–5.142
Table 21 Generic assessment – likelihood of infection
Containment Proposed general classification Examples Exceptions

Urine, Offensive Urine bags, Gastrointestinal and other infections that are
faeces, incontinence readily transmissible in the community setting,
vomit and pads, single-use such as verocytotoxigenic Escherichia coli (VTEC),
sputum bowls, nappies, campylobacter, salmonella, chickenpox/shingles
non-infectious PPE
Hepatitis B and C, HIV – only if blood is present
(gloves, masks, etc).
(where risk assessment has

indicated that no infection is
present, and no other risk of
infection exists)
Blood, pus Known infectious Dressings from Blood transfusion items

and wound wounds, wound
Dressings contaminated with blood/wound exudates
exudates drains, delivery
assessed not to be infectious
packs
Maternity sanitary waste where screening or
knowledge has confirmed that no infection is
present, and no other risk of infection exists
(unless assessment indicates

no infection present – if no
infection, and no other risk of
infection, then offensive)
89
Primary care Ambulance services

6.34 Primary care services including GP, 6.40 Emergency care practitioners (ECPs),
community pharmacy, dentistry and first responders, rapid response vehicles or
optician services provide the first point of paramedics should follow the guidance on
contact in the healthcare system. They are community healthcare in paragraphs 6.16–
responsible for delivering healthcare and 6.32 in relation to classifying, transporting
health improvements to their local area. and disposing of waste from community
They may also not produce the same waste sources.
streams in the same quantities as other
larger or more specialised healthcare 6.41 Owing to the lack of prior knowledge
facilities. of patients’ medical history, the ability to
classify healthcare waste as non-infectious
6.35 All producers of primary care waste, for emergency care services is more
their employees and service providers have challenging than in most other settings.
a duty of care to ensure all the waste is
being managed in a compliant manner, 6.42 The assessment and subsequent
which is detailed in Chapter 4. processing of the waste must thereafter
comply with legal requirements to
6.36 All clinical waste generated in primary segregate hazardous from non-hazardous
care settings should be classified and waste, whilst ensuring the EWC number
segregated in accordance with the (paragraphs 5.62–5.77) assigned to the
provisions set out in paragraphs 5.24–5.61. waste reflects those permitted for receipt
by the waste treatment contractor.
6.37 Table 22 illustrates good practice for
primary care-related waste arisings. 6.43 All staff should undertake waste
awareness training.
6.38 All waste bags and sharps containers
should adhere to packing and storage
requirements described in paragraphs Waste receptacles and storage
5.78–5.142. 6.44 When infectious waste is being
transported in vehicles prior to treatment,
6.39 Many of the measures laid out in the waste should be appropriately packed
Appendix 2 can be applied to primary care in safe and secure conditions as summarised
organisations. in paragraphs 5.78–5.142.
Table 22 Best practice examples for primary care
Waste receptacle Best practice

Waste bins • Positioned where they are easily accessible to staff
• Lidded and operated with a foot-pedal if in clinical areas and toilets
• Blue bins should be used for vials and other medicines
• Domestic/recycling bins accessible to staff and patients
• Food waste bins where practical (in staff kitchen areas, or wherever food is prepared and stored)
Waste bags • No more than two-thirds full so the bag can be tied securely
• “Swan necked” (neck of bag twisted, bent in half, and fastened)
• Securely tied using a plastic tie or secure knot
Sharps container • Purple-lidded: cytotoxic and cytostatic medicinally contaminated sharps

• Yellow-lidded: other medicinally contaminated sharps
• Orange-lidded: non-medicinally contaminated sharps
• Reusable sharps containers should be used if feasible
90
6.45 When dealing with anatomical waste 6.48 The ambulance service, due to its
resulting from an amputation, a medical varying patient care activities, has a number
assessment for potential reattachment of options available when disposing of
should be undertaken before classifying waste, as summarised in Table 23.
body parts as waste. Packaging for body
parts and limbs should be strong enough to
resist protrusion of bones. Contract management
6.49 The healthcare waste management
6.46 Waste streams including sharps should sector is heavily reliant on the use of third-
be clearly identifiable and labelled in party contractors to deliver services. This
accordance with the waste classification and can include internal facilities management,
any specific requirements, depending upon waste collection and transport, and waste
the waste management route; for example, treatment and management functions.
waste dropped off at an ambulance service There may be separate contracts for each
site or other healthcare organisation should component of the system as well as
be labelled by the specific NHS ambulance separate contracts for each healthcare
organisation. Waste from ambulances waste type, with specific arrangements in
should not be dropped at GP practices and place for clinical waste. Alternatively, there
should not be dropped at any site which may be integrated contracts where “total”
does not have an agreement to receive such waste management services are provided.
waste.
6.50 In each case it is essential that a robust
6.47 The maximum weight of dangerous approach is taken to the procurement,
goods which can be transported in mobilisation and monitoring of waste
ambulance vehicles is 15 kg when carried contracts, to ensure that best value and
without a fire extinguisher on board, as set high standards are achieved whilst being in
out in the summary of load thresholds (see compliance with regulatory requirements.
Table 16).
Table 23 Ambulance service waste transfer/management options
Service providers Management option Key considerations

Emergency response Transfer the waste to the The hospital is not required to provide this service; it is, however,
including emergency hospitals considered best practice.
ambulance and air
Return waste to First responders generating waste on-site should hand the waste to
ambulance
ambulance station for the attending emergency ambulance to consider the appropriate
collection waste management method.
Where the ambulance organisation drops its waste off at a hospital,

this is classed as waste transfer. Therefore, duty of care applies, see
paragraphs 4.1–4.44 on key legislation and paragraphs 6.86–6.91 on
compliance.
This activity is usually covered under a Non Waste Framework

Directive exemption (NWFD 3), which does not require registration
with the regulator.
ECPs, first responders, and Seek approvals from local Follow the guidance in community healthcare paragraphs 6.16–6.32,
rapid-response vehicles authority in particular for infectious and offensive waste streams.
working in Community
Healthcare
Ambulance transport Hospitals It is less likely that any infectious waste will be produced. Where
services – patient transfer non-clinical waste is generated and has been risk-assessed, this can
be safely disposed of in the black-bag waste or recycling streams at
the hospital, depending upon arrangements.
91
6.51 It is therefore essential that procuring 6.53 Procuring managers should liaise with
managers and waste managers are aware their organisation’s waste/facilities manager
of the types of contractual mechanism and to plan for the award of new service
monitoring requirements needed to do this contracts in advance of the procurement
effectively, from the point of procurement exercise; this should be 12 months or more
through to contract expiry, as set out in in the case of major or long-term contracts,
Figure 18. as the level of complexity and duration of
the procurement phase will be subject to
6.52 Waste management service contracts the scale and type of services being
typically last for between one to five years, procured.
and often include extension and/or renewal
provisions. Procuring managers should give 6.54 It is important that adequate time is
careful consideration to the proposed allowed for any new contractor to mobilise
contract duration; longer contracts typically its services, as there will be lead-in times
achieve better value as they provide more associated with the provision of new
opportunity for the contractor to realise a equipment and resources, for instance
return on investment in new equipment or containers and vehicles. Net zero carbon
infrastructure. However, it is important that targets should be factored into all waste
the commercial provisions in such contracts contracts.
appropriately allocate pricing risk between
the contractor and the healthcare 6.55 All new tenders for NHS contracts
organisations, especially in respect of from 1 April 2022 must include the net zero
clinical waste treatment, where the market (paragraphs 2.10– 2.21) and social value
can be particularly volatile. (paragraphs 2.50–2.52) considerations. This
can provide a mechanism to define,
Figure 18 Principles in preparing for and managing waste contracts
Contracting phases
Procurement Mobilisation Monitoring Expiry

(6 to 12 months) (6 weeks to 6 months) (1 to 5 years) (6 weeks to 6 months)
• Pre qualification / • Mobilisation / • Output specifications • Expiry / exit plan
Contractual mechanisms
expression of transition plan and KPIs / • Handback

interest • Handover protocol performance arrangements
• Invitation to tender / framework • Extension or
request for proposal • Business continuity renewal provisions
• Existing frameworks plans
• Technical and • Contingency plans
commercial • Payment mechanism
evaluation • Governance
arrangements
• Change control
• Technical capability • Contractor • Accuracy of invoices • Reprocurement,

• Financial standing preparedness and billing renewal or
Items to check and monitor
• Track record in • Equipment and • Service standard extension plans

delivery resource compliance • Handover
• Compliance record deployment • Data and reporting arrangements
• Environmental and • Communication records • Asset or condition
H&S performance arrangements • Duty of Care surveys
• Commercial offer • Planned servicing compliance
and best value schedules • Financial, operational
and performance
auditing
Reprocurement, renewal or extension
92
measure and manage net zero and social Managing risk

value outcomes as part of the contract, and
ensure that benefits are realised. See 6.60 Risk management is an essential
‘Applying net zero and social value in the component in safe and sustainable waste
procurement of NHS goods and services’ management.
on the GreenerNHS website. Additional
resources are available to NHS staff via the 6.61 Given the complexities associated with
NHS Central Commercial Function Hub on managing different types of healthcare
the FutureNHS website. waste, there is a wide range of risks that
could materialise if effective control
6.56 Waste management contracts should measures are not in place. Figure 19
include provisions and flexibility to mobilise highlights how different types of
waste contractors to support disasters and/ operational failure can culminate in
or emergency scenarios on an ad-hoc basis, significant service or regulatory risk.
where excessive volumes of waste may be
generated.
Other examples of risks include:
The National Audit Office (NAO) has • c ommercial – arrangements not put
produced a Good practice contract in place to extend, renew or procure
management framework (2016) for new waste management services,
managing a broad range of contracts. resulting in waste not being collected
It is particularly relevant for contracts
where services are delivered over a long training and education – inadequate
•
period of time where customers need to measures in place to ensure that
ensure that service levels and value for the workforce understand the
money are maintained over the duration requirements for safe and sustainable
of the contract. management of healthcare waste,
leading to non-compliance and
6.57 Waste managers should ensure that inaccurate segregation
there is a detailed understanding of the
service standards, KPIs, performance • f inancial – insufficient funds available
frameworks and technical and operational for the management of waste services
requirements set out in the contract and or funds needing to be diverted
should establish robust monitoring from other areas (equipment, staff,
arrangements and procedures to ensure facilities, etc.)
that the contractor delivers services in
• c ompliance – waste duty of care
accordance with such provisions.
requirements are not fully complied
6.58 Standards that encourage the most with, leading to a regulatory action
cost-effective, carbon- and resource- and/or enforcement
efficient means of transport and treatment • e
nvironmental – pollution or
are encouraged, provided that compliance emissions to the local environment
with regulatory requirements is maintained. caused by ineffective or non-
compliant waste management
6.59 Table 24 provides a summary of key
practices.
contractual functions, how they should be
monitored and who should typically be
responsible for monitoring them. It is not 6.62 Estates and Facilities Management
intended to be an exhaustive list of all teams should ensure that an operational
contract management functions.
93
Table 24 Example of key contract monitoring functions
Contractual Monitoring aspects Typical monitoring tools Monitoring

function responsibility
Service levels • Collections schedules • KPIs to establish the required level of Waste manager
(typically set out • Information reporting service (for example no more than 1%
in a schedule) missed collections, 98% of transfer
• Use of appropriate sub-contractors
notes/consignment notes correctly
• Condition and quality of equipment completed)
• Risk assessments and method • Service reports (typically monthly)
statements on number of collections, type, date,
• Duty of care compliance. weight including transfer/consignment
note evidence.
Implementation/ • Schedules of bin and equipment • Bin and equipment delivery and Procuring
mobilisation deliveries to organisation sites installation programme manager/waste
plan • Arrangements for the handling of any • List of sites to be serviced manager
backlog or transitional waste • Programme for first collection of waste
• Supply chain arrangements • List of proposed waste transport,
• Net zero and social value considerations treatment and disposal suppliers (along
• Site-specific issues and logistics. with associated duty of care pack).
Payment • Cost of service per waste type (for • Invoice reconciliation and checking of Finance manager/
mechanism example fee per collection or per tonne supporting evidence. waste manager
of waste collected)
• Performance incentives (additional
payments) and/or penalties
(deductions).
Business • Interaction with organisation and/or • Service levels in the event BCP enacted Waste manager
continuity plans NHS BCPs • Risk register
(BCPs) • List of potential service failure scenarios • Contractor procedures, processes and
and mitigation measures responsibilities.
• Arrangements for returning to normal
service.
Expiry plans • Arrangements for handover to a new • Programme for the handover of Procuring
contractor equipment or resources where manager/waste
• Provision of transitional assistance applicable manager
services • Programme for the final collection of
• Provision of relevant data and wastes
information. • Provision of asset register
• Details of incumbent contractor working
arrangements over the prior 12-month
period.
Figure 19 Example of operational failure escalation
Incorrect Ineffective
segregation due Infectious waste waste contract
to over- backlog leads to missed
classification collections
Insufficient No further Patient services

treatment storage space impacted and
capacity for and reputation
waste backlog enforcement risk damaged
94
risk register is in place for the management how the organisation can improve its
of healthcare waste. management of risk moving forward.
6.63 The potential risks included in the risk 6.67 An example of the headings that
register should be reviewed and updated would typically be included within a
regularly, but no less than once a year, and standard risk register is set out in Table 25.
immediately after any major change to the
way in which services are delivered, for 6.68 When developing a risk register, waste
example a change in waste service managers may need to seek input from the
contractor. following stakeholders, especially where
the implementation of mitigation measures
6.64 If the consequence of a risk would require their involvement:
materialising is deemed to be “significant”,
inclusion within the wider organisational • waste service contractors
risk register should be considered for • facilities management contractors
escalation to management board level.
• procurement specialists
6.65 Monitoring the risk register to
• regulators and/or other government
establish whether the likelihood of risks has
bodies (Defra, EA, HSE, DfT, etc.)
changed should occur monthly and should
be undertaken by waste managers or those • NHS England.
appointed as being responsible for waste
management.
Training
6.66 Where risks have materialised, they 6.69 The healthcare waste management
should be recorded in an issues log that policy must be implemented by a trained
identifies the specific mitigation measures and competent individual.
that will be implemented to respond to and
de-escalate the issue. A lessons-learned 6.70 The safe and sustainable management
process should be undertaken to reflect on of healthcare waste cannot be effective
unless it is applied carefully, consistently
Table 25 Example risk register format
Risk ID Category Description Probability Impact Risk Control Measures Owner Post
level level control
measure
risk
R1 Operational Significant backlog L H M Ensure waste XX L
of waste stored at collection contracts
healthcare premises feature robust
due to waste not service levels, KPIs,
being collected, financial incentives
leading to impacts and penalties,
on patient services enforcing such
and potential standards when
compliance issues required
R2 Commercial Arrangements L H M Commence XX L

not put in place procurement or
to extend, renew renewal process
or procure new 12 months prior
waste management to contract expiry.
services, resulting Ensure adequate
in waste not being handover and
collected mobilisation period
in place
95
and universally by all within the healthcare Healthcare organisations which use
organisation. This requires that all agency and bank staff (“floating” staff
healthcare staff should be aware of the who move between facilities on an
healthcare organisation’s procedures and ad-hoc basis) should prepare guidance
guidance. which sets out the training and handling
requirements specific to the facility.
6.71 Training is a requirement of Chapter
Organisations which regularly share
1.3 of ADR, even for community healthcare
bank staff should consider cooperating,
practitioners who are exempt from other
and aligning their waste management
ADR requirements, and for staff handling
training programmes, to improve
small quantities of waste.
transferability. Such guidance should be
6.72 One of the strategic priorities outlined consistent with this HTM.
in the NHS Clinical Waste Strategy is to
upskill the existing workforce to ensure all 6.77 Operators of waste management
employees understand their role in facilities must also demonstrate the
supporting effective waste management. necessary technical competence for the
relevant permitted activities. In England
6.73 Healthcare organisations must ensure and Wales, this is now assessed on the basis
that waste management training is of either an employee’s individual
delivered to all staff involved in the competence (Certificate of Technical
handling and management of waste. A Competence (CoTC)) or an employee’s
clear and coherent programme should be individual competence coupled with
established to support training for new corporate competence (demonstrated
staff, refresher training and training for through an environmental management
new and emerging issues. system (EMS) or quality management
system (QMS)).
6.74 Training needs vary depending on the
responsibilities and job function. Certain 6.78 Further guidance and information on
staff will require more specific training. legal, financial and professional
These include people who regularly use requirements for operators and managers,
disposable PPE or handle waste using PPE, including extra duties for waste activity
waste management facility operators, operators, can be found on the
drivers, and community and laboratory Environment Agency’s website (EA, 2019a).
staff.
SCOTLAND AND NORTHERN IRELAND:
6.75 Ideally, separate training programmes
should be designed for, and targeted In Scotland and Northern Ireland, the
towards, the job roles identified in Table 26, system for certificates of technical
all of whom have a role to play in competence (CoTC) is used.
sustainable waste management.
In Scotland, other methods of proving
6.76 Those delivering training should have technical competence are also available.
experience in teaching and training and be See SEPA guidance (SEPA, 2021)
familiar with the risks and practices of regarding provision and assessment of
healthcare waste management. Smaller technically competent management at
establishments generating healthcare waste licensed waste management facilities.
may not have this range of expertise
available to them but should still have
access to competent advice on hazardous
waste issues.
96
Table 26 Summary of key competencies for job role
Job function/responsibilities Specific training topics General training topics

Medical doctors/dentists/ • Use of protective equipment • The risks associated
advanced clinical • Waste segregation. with healthcare
practitioners/radiographers waste, its segregation,
handling, storage and
Pharmacists • Disposal of medicines collection
• Ensuring that the origin of the waste is marked on the • Personal hygiene
container.
• Any procedures which
Nursing staff • Waste segregation apply to their particular
Healthcare assistants type of work
• Use of protective equipment.
• Procedures for dealing
Drivers transporting • The Carriage of Dangerous Goods and Use of Transportable with spillages and
healthcare waste, including Pressure Equipment Regulations (as amended) accidents
ambulance staff • Access to a qualified DGSA • Emergency procedures
• Understanding of marks and labels • Appropriate use of
• Knowledge of acceptable load thresholds. protective clothing
• Duty of care
Waste handlers • Understanding of marks and labels requirements.
• Handling bags/containers correctly
• Procedures in case of accidental spillage and how to report an
incident.
Waste managers • Understand legislative requirements

• Waste hierarchy
• Permit compliance and waste exemptions
• Waste reporting
• Access to a qualified DGSA
• Consignment/waste transfer note
• Pre-acceptance audit requirements
• Waste policies and procedures
• Net zero carbon and carbon literacy
• The 5 R’s of sustainable procurement
• Cabinet Office Social Value Model including health specific net
zero and social value guidance
• NHS Net Zero Plan and Net Zero Supplier Roadmap
• Sustainable procurement and carbon literacy.
Cleaners, porters, auxiliary • Safe and appropriate cleaning and disinfection procedures
staff • Understanding of marks and labels
• COSHH• Local training if working in areas using radioactivity.
Infection prevention and • Use of protective equipment

control staff, healthcare • Access to a qualified DGSA
managers and administrative
• COSHH
staff responsible for
implementing regulations • Understanding of marks and labels.
on healthcare waste
management
Finance managers • Sustainable procurement (5 R’s)

• NHS Net Zero Plan
• Sustainable procurement.
Procurement managers • Understanding of producer responsibility

• Circular economy principles
• Sustainable procurement (5 R’s)
• NHS Net Zero Plan
97
Procedures Records
6.79 Where healthcare organisations have 6.82 Full records of all training should be
developed their own training materials, kept, as this will enable managers to
they should: identify members of staff who are not
receiving the appropriate level of training,
• be written in a way which can be and where such training should be focused.
understood by those who need to In certain cases, training records are also
follow them, including those with required to demonstrate technical
English as a second language competence, regulatory compliance and
• use pictures or photos which will assist continued professional development (CPD).
with any language barriers
6.83 All mandatory training should be
• take account of different levels of included as part of the induction
training, knowledge and experience programme for new starters. All employees
should be retrained in procedures and
• be up to date
topics annually or following amendments to
• be available to all staff including the existing process.
part-time, shift, temporary, agency
and contract staff NHS Shared Business Services has
developed a framework agreement
• be available in all areas.
for the delivery of waste management
6.80 Healthcare organisations should training within the UK. The aim is to
ensure that procedures are followed by all ensure that a comprehensive package
staff involved in waste handling activities. of training is available for access by the
Staff at all levels who generate the waste NHS.
need to recognise that they are personally
responsible for complying with agreed local
procedures. Compliance
6.84 Site-based waste management
6.81 The risk assessments required by the activities must comply with the relevant key
Management of Health and Safety at Work legislation identified in paragraphs 4.1–
Regulations and COSHH regulations should 4.44.
identify which staff are involved in the
handling of healthcare waste. Employees 6.85 Effective compliance prevents breaches
should receive information on: in legislation, and ensures that controls are
• the risks to their health and safety, in place to limit impact to the environment,
that is, the details of the substances human health and demand for resources.
hazardous to health to which they are
6.86 For healthcare waste management,
likely to be exposed
the main topics that govern effective
• the significant findings of the risk compliance comprise:
assessment
• duty of care
• any precautions necessary
• waste auditing
• the collective results of any relevant
• environmental permitting and
health surveillance.
licensing requirements
• health and safety.
98
Duty of care
BETWEEN JURISDICTIONS:
6.87 Everyone who produces, imports,
keeps, stores, transports, treats or disposes Any consignments of waste crossing an
of waste must take all reasonable steps to administrative border, for example from
ensure that waste is managed properly one devolved region to another, should
from the point of production to the point be made by the producer of the waste
of final disposal. using both their “home” regulator’s
guidelines and the “destination”
6.88 Producers of waste must follow Defra’s guidelines. This does not apply to “cross-
statutory guidance ‘Waste duty of care: border” movements between Wales and
code of practice’ (Defra, 2018). The England or vice versa.
guidance provides details on waste
producers’ legal requirements and further
resources including key documents for WALES:
waste classification, examples and guidance
A register of hazardous waste
for waste transfer notes and consignment
generation is required and should
notes, and other related legislation.
contain quarterly producer returns
6.89 A checklist of practical measures to provided by waste management
follow are provided in Appendix A1.2 of this contractors, and records of consignment
document, and this is supplementary to notes.
Defra’s duty of care guidance.
6.92 Contractors and waste management
Ensure that wastes are handled by site operator competency and track records
authorised persons; keep records of should be assessed before signing a
waste produced and check the legally contract, as part of duty of care. Ongoing
required paperwork is completed and performance should be tracked, with clear
accurate. performance standards laid out in the
contract.
6.90 Describe waste using:
Compliance with carriage of
• a written description
dangerous goods
• use of the appropriate EWC code(s)
which are set out in paragraphs 5.24– 6.93 It is important that all those involved
5.77 for classification, segregation, in the movement of healthcare waste are
colour coding and storage, with aware of the person providing DGSA
further information on how to classify support. The name and contact number(s)
different types of waste available of the DGSA(s) should be listed in the
from the Environment Agency’s organisation’s waste management policy.
website Further information on transport and
packaging is included in paragraphs 5.78–
• quantities on both waste transfer (for 5.142.
non-hazardous waste only) and
hazardous waste consignment notes.
Waste auditing
6.91 Time-limited permissions, such as 6.94 Waste audits are an essential tool for:
waste carrier licences, should be monitored
to ensure renewals are applied for and • assessing the composition of a waste
granted before the expiry. stream for the purposes of duty of
care
99
• demonstrating compliance with 6.97 Duty of care audits provide detailed

regulatory standards assessment of the performance of internal
management against policy, including
• informing the development of waste waste composition. Such audits provide
management policies and procedures evidence to support pre-acceptance audits,
so that they are better aligned to key covering training, policy assessment and
waste management principles such as waste containment/handling measures.
the circular economy
• monitoring progress towards waste Audit scope and procedure
hierarchy targets and
6.98 Waste audits need to be carried out by
• monitoring the progress of the a nominated person who is responsible for
implementation of strategies and waste management, although this can be
policies including the NHS Clinical conducted with an experienced waste audit
Waste Strategy. contractor or consultant.
6.95 Audits required for compliance 6.99 Audits should only be undertaken by
purposes are: those who are trained in the audit
• “waste pre-acceptance audits”, procedure and who are fully aware of the
undertaken by waste producers to risk and hazards posed. The type and
provide to waste operators and effectiveness of the audit undertaken
depends on the nature of the waste stream
• “waste acceptance audits”, and the purpose of the audit. To audit the
undertaken by waste facility operators entire waste stream, more than one audit
in accordance with waste acceptance method may be required.
procedures.
6.100 A detailed method statement should
6.96 It is good practice to either tailor be produced for each audit, with key
pre-acceptance audits or undertake considerations shown in Figure 20.
additional audits for the purpose of
monitoring progress against organisational 6.101 It is good practice for waste audits to
waste policies and targets. address the elements shown in Table 27 for
Figure 20 Waste audit method statement considerations
Who should undertake the audit
What is included within the audit
How the audit should be undertaken
The method of recording and reporting the

findings of the audit
The management responsibility and

mechanism to act on the findings
Any inherent risks and the control measures

required (for example PPE required)
100
Table 27 Waste audit elements

Information to collect during practice phase of audit
Information to collect during theory phase of audit
Review compliance and performance against set targets for:
Record the segregation, packaging and labelling of:
• classification
• infectious waste
• segregation
• anatomical waste
• packaging
• cytotoxic and cytostatic waste
• waste description
• offensive waste
• paperwork completion and retention
• domestic waste
• storage
• medicinal or pharmaceutical waste
• recycling
• dental amalgam and gypsum (separate)
• movement/transport
• radioactive wastes
• health and safety
• recycling
• final disposal
Record the provisions of bins/waste receptacles: • review bin provisions across the site
• location • net zero and social value
• type
Prepare action plan
• quantity
• capacity Record actions for improvements, with prioritisation to
compliance and health and safety:
• set a target date
• assign responsibility
• if identified bin provisions need to be improved, consult
Chapter 5 and arrange for improvements to be made as
soon as practicable.
the applicable healthcare waste types at the method for the waste is compliant and
healthcare organisation site. appropriate.
6.102 Audits should be conducted in two 6.105 The Chartered Institution of Wastes
phases: Management (CIWM) provides established
guidance (2014) on waste pre-acceptance
1. Desk-based (what do the policies, audits and managing healthcare waste
procedures and training specify for which should be followed by any person
waste segregation, packaging, responsible for carrying out a pre-
labelling, etc.) acceptance audit.
2. Practice (inspection of waste in
containers in use throughout the 6.106 If feasible, non-compulsory waste
facility). audits should be carried out before
implementing or updating waste
management procedures, and at routine
Pre-acceptance waste audits intervals afterwards, in order to monitor
6.103 Permitted waste treatment and compliance with waste segregation
disposal sites in England and Wales must schemes.
obtain pre-acceptance audits from
6.107 After changes are made to waste
producers of waste before they can accept
management policies, audits can be used to
the waste and are required by the producer
monitor and encourage compliance.
at the frequencies demonstrated in
Figure 21.
Permitting and licensing
6.104 Waste pre-acceptance audits are the
assessment of the characteristics of a waste 6.108 Any waste operation or installation
to ensure that the disposal or recovery will require an environmental permit unless
it is an exempt activity.
101
Figure 21 Pre-acceptance audit frequencies
Prior to the delivery of the first batch of waste to a permitted facility

First pre-
acceptance
audit
Sites producing more than 5 tonnes per year

Every 12
months
Dentists / Veterinary practices / Research Labs

Every 2 years
Any other healthcare site producing less than 5 tonnes per year
Every 5 years
6.109 Healthcare organisations should for minimising the risk of pollution to land,
ensure healthcare wastes are sent to waste air and water from the activities covered by
management facilities that are permitted to a permit.
accept and treat/dispose of the waste
intended for them. 6.113 The regulatory authority –
Environment Agency, NRW, SEPA or NIEA
6.110 Operators of such sites must follow – will attend permitted sites to review
the Environment Agency’s technical compliance. In general, the frequency is
guidance, which may form part of the dependent on the environmental risk the
operational techniques within a permit: site poses.
‘How to comply with your environmental
permit: additional guidance for clinical 6.114 For permitted sites in England,
waste (EPR 5.07)’ (Environment Agency, following such visits the operators are
2011a) and ‘Waste storage, segregation and provided with a Compliance Assessment
handling appropriate measures – Healthcare Report (CAR), which will provide comments
waste: appropriate measures for permitted on the inspection and will state if any
facilities’ (Environment Agency, 2021b). aspects of the permit have been breached.
If any breaches were identified, a
6.111 The key aspects of the technical compliance score will be applied to indicate
guidance are summarised in Figure 22. the severity of the breach.
6.112 Operators using environmental 6.115 The regulator may allow for changes
permits must also comply with an EMS, to the operation of a waste activity prior to
which is required to outline the procedures or without a variation to a permit. Local
102
Figure 22 Summary of environmental permitting compliance requirements
Environmental Permit and Environmental Management System

Waste operations to have appropriate Environmental Permit (or exemptions) and Environmental Management System
Management Plans Emission controls, monitoring and validation tests

Permit may require:
Environmental permits may require plans to
further control, mitigate and remediate • additional measures to control and/or monitor emissions to air, water or land
environmental harm such as odour, noise, • validation testing to demonstrate technology is effective at treating healthcare
dust, fire and other emissions waste (emerging technologies).
Waste pre- acceptance and Resource efficiency

waste acceptance Waste tracking and
Operators to apply the waste hierarchy
Operators must obtain audit of waste quarterly waste returns to waste generated on site. For larger
composition from waste producers prior waste sites (waste installations)
to delivery (waste pre-acceptance). Computerised system to track wastes operators must apply efficiency
Upon delivery (or collection if operators accepted and removed from the site. measures to limit use of energy, water
is also a licensed carrier) waste Quarterly returns submitted to the EA and raw materials. For smaller waste
acceptance procedures to be followed to end of April, July, October and January sites it is best practice to apply such
ensure wastes are compliant with permit measures. Permits may require annual
conditions. records on resource usage.
Training
Provide training for staff to be able to comply with conditions of a permit and EMS
enforcement positions (LEPs) are at the • hazardous waste registration with the
discretion of the regulator where changes NRW (for sites in Wales only) if
to operation are deemed justified for the producing more than 500 kg of
short term. LEPs state the additional hazardous waste in any period of
measures an operator must comply with. 12 months (see box after paragraph
4.22).
6.116 The regulator may require an
operator to apply for a variation or revert WALES:
to original permit conditions once an LEP
has expired. Hospital complexes are often occupied
by a number of different organisations
6.117 Healthcare facilities that do not that produce hazardous waste. In Wales,
require an environmental permit must where these organisations have their
ensure that any other relevant licences, own discrete units or areas, they are
registrations and permissions are in place. considered to be separate individual
The waste manager is responsible for premises for the purposes of producer
checking and securing the following, if registration under the Hazardous Waste
required: Regulations.
• waste exemptions and/or operations
under a regulatory position statement
(RPS) can be viewed on the EA Health and safety
website 6.118 Health and safety legislation requires
employers to protect the health, safety and
• obtaining a waste carrier licence from
welfare of their employees, clients, visitors
the Environment Agency if carrying
and the general public. Healthcare
waste off the premises
organisations should review their own and
103
their waste contractor’s approach to health check the extent to which the policy
and safety as part of their responsibility. is complied with
Healthcare organisations should: • check their ability to keep records of

observations of H&S and to provide
• have an appointed health and safety feedback to waste contractors,
representative or advisor and/or especially regarding breaches.
employee representative
• have a health and safety policy and 6.120 Healthcare employers must comply
management system with the COSHH regulations, including
undertaking COSHH risk assessments for the
• maintain a health and safety use of hazardous substances. Such risk
record of the site, such as capturing assessment must address the hazards, risks
information on all accidents and and controls for the wastes generated from
incidents the use of hazardous substances.
• observe general health and safety 6.121 All staff involved in activities relating
compliance. to the handling of healthcare waste must
be made aware of the hazards, risks and
control measures. The staff should read and
Risk assessments understand the risk assessment, and the risk
assessment must be regularly reviewed
6.119 As a minimum, a health and safety
following any accident/incident to ensure it
risk assessment must address the following:
remains effective and compliant.
• hazards – what could cause injury or
illness 6.122 Further information is available from
the HSE, in particular Approved Code of
• risk – how likely is it that a hazard will Practice L5 (HSE, 2013) regarding compliance
occur, such as someone being harmed, with COSHH.
and the consequence of the hazard
arising, such as how serious the injury
will be Staff protection: PPE provision and
vaccinations
• action – what actions will be taken to
eliminate the hazard, or if not 6.123 Healthcare employers must ensure
possible, to mitigate or control the staff that handle healthcare waste have
risk. sufficient and correct PPE. This should be
addressed in a PPE policy, risk assessments
Where using contractors: and method statements.
• request a risk assessment for the 6.124 Healthcare organisations should

carriage of dangerous goods ensure waste contractors also have the
adequate provisions for PPE for their staff.
• request a copy of the H&S policy,
and updated copies following annual 6.125 PPE must be maintained and kept in
reviews good condition, and replacement PPE
should be made available.
• request and review the PPE policy
used by the waste contractor, and 6.126 Appropriate numbers and locations
of collection points, either as waste
104
containers or safe collections for PPE that Reporting of Injuries, Diseases and
can be reused after sanitisation, should be Dangerous Occurrences Regulations
made available, particularly in areas where
PPE is used. PPE use should be based on a (RIDDOR)
local risk assessment, carried out by the
Health and Safety department of the The Reporting of Injuries, Diseases and
relevant healthcare organisation. Dangerous Occurrences Regulations
concerns incidents that contributed to
6.127 Further guidance and information on work-related:
personal protective equipment at work can
be found on the HSE website. • specific injuries outlined by RIDDOR
6.128 Employers must review the • over-seven-day injuries
vaccination needs of staff, which includes
an assessment of the risk from exposure to • injuries to non-workers
pathogens and disease. Staff who handle
infectious waste, including waste • reportable occupational diseases,
management staff, therefore must also be including carpal tunnel syndrome,
considered in any immunisation exposure to biological agents
programme, in particular for blood-borne
viruses. • fatalities
6.129 Hepatitis B vaccinations should be • reportable dangerous occurrences,

offered to staff who may come into contact including collapses, overturning
with infectious waste, and in line with DHSC and failure of lifting equipment,
Green Book chapter 12, ‘Immunisation of explosions or fires causing disruption
healthcare and laboratory staff’ (UK Health to workers for more than 24 hours.
Security Agency, 2020).
6.133 Healthcare facilities and waste
6.130 HIV post-exposure prophylaxis should contractors must keep records of injuries,
also be made available to staff who have diseases and dangerous occurrences
been exposed; further guidance is provided included within the Reporting of Injuries,
by the UK Chief Medical Officers’ Expert Diseases and Dangerous Occurrences
Advisory Group on AIDS (EAGA) ‘Guidance Regulations (2013) (RIDDOR).
on HIV post-exposure prophylaxis’ (DHSC,
2015). 6.134 The HSE must be informed of all
reportable incidents either online or over
6.131 Vaccination should never be regarded the phone.
as a substitute for good practice, although
it does provide additional protection. 6.135 Records of incidents should be used
as a management tool to inform risk
6.132 Guidance on assessing the risk to assessment and help develop improved
healthcare workers of exposure to blood- measures to prevent potential risks.
borne viruses, and action to be taken after
possible infection, are provided on the HSE 6.136 If an incident involves a contractor,
website. healthcare organisations should request a
copy of the contractor’s incident reporting
procedure and details of reported incidents,
accidents and RIDDOR occurrences for the
previous three years to identify trends.
105
6.137 Further information on RIDDOR in 6.145 However, there are certain scenarios
relation to health and social care can be in which excessive volumes of healthcare
found on the HSE website. waste might be produced, to the extent
that existing management systems would
be unable to cope. These could include an
Investigations unforeseen waste contractor failure, or a
6.138 All health and safety incidents should major event that places long-term pressure
be investigated and be compliant with on the NHS, such as a pandemic.
health and safety legislation (see Table 7).
6.139 Investigations are used to establish Business continuity planning

the causes of the incident, review existing 6.146 NHS England have produced a
risk controls and identify action needed if website containing EPRR guidance. This
required, such as improved measures if should be referred to for more detailed
found not to be adequate. guidance and information.
6.140 It is a legal requirement for all sharps 6.147 There are a number of events which
injuries to be investigated under the Health may cause operational disruption. These
and Safety (Sharp Instruments in include local, regional and national issues,
Healthcare) Regulations (2013). supplier failures, and issues which cause
significant and unexpected increases in
6.141 Any investigation must be based on waste generation.
sufficient information, notably:
6.148 Developing a clear and well-
• who was injured
communicated business continuity plan
• where the incident occurred (BCP) is a good way of understanding the
measures that might need to be
• what type of waste, sharp or other implemented in such scenarios.
item caused the injury.
6.149 Where response to a national issue is
6.142 Any lesson learned following an required, it is likely that Emergency
investigation should be applied across the Preparedness and Resilience Response
organisation, rather than just within a (EPRR) protocols will be enacted, along with
location or department only. a single point of contact (SPoC) and
national logistics cell.
Emergency preparedness 6.150 Daily updates would typically be
6.143 Evidence has indicated that requested from affected health
healthcare organisations which are well organisations and the supply chain so that
prepared for unplanned events and the “live” situation is fully understood. It is
emergencies are less likely to suffer serious likely that other stakeholders will also need
service disruption or be exposed to to be engaged or consulted with, which
excessive costs. may include NHS England, DHSC, EA, Defra,
DfT and/or the HSE. Issues may be escalated
6.144 Developing a comprehensive risk to the NHS England region, in accordance
register as defined in paragraphs 6.59–6.67 with the NHS England EPRR Framework,
is helpful in preparing for unforeseen and the relevant healthcare organisation’s
events. A comprehensive risk register will incident response plan.
assist in the production of a well-considered
and robust business continuity plan.
106
The NHS Clinical Waste Strategy will 6.151 The scale of response to a business
help NHS organisations to appropriately disruption event is determined by the
assess and understand the risk to extent to which the issue is local, regional
operations from failures associated with or national, as summarised in Table 28.
clinical waste management services, and
to provide strategies for proportionate
provides further detail on the specific
corrective action to be taken to minimise
technical and operational measures that
the impact of such failure. It is intended
should be included in an organisational BCP,
to provide a clear framework that
including advice on specific storage and
triggers a set of proportionate actions
handling arrangements for certain clinical
and escalations, to allow organisations
waste types.
to respond quickly and effectively to
disruption.
Table 28 Disruption event description and key actions
Scale of Defined as Examples of disruption event Key actions

event
Local Issues that affect a single health Service provider has missed • Manage through service contract
organisation, GP practice, or other less than three (3) consecutive • Notify local resilience team and
body. Local issues are generally collections and/or the frequency of IPC leads
the result of isolated supply chain scheduled collections is reduced.
• Activate organisational BCP
failures.
Treatment facility offline or • Implement regular
unavailable for an undefined communications with service
period. contractors
• Conduct frequent waste backlog
audits
• Gather and record data
Regional Service failures across one or more Multiple treatment facility failures • Escalate to National Logistics Cell
sites in an NHS region that have in any NHS region. function or others
lasted for more than three (3) • Activate organisational BCP
Regional service provider failures,
contiguous scheduled collections or
for instance vehicle/driver/ • Regional communications with
intermittent collections lasting for
container shortfalls. service providers
more than one (1) week affecting
more than one (1) organisation in Shortfall in clinical waste treatment • Monitor corrective actions
a region. These impacts can affect capacity due to unexpected • Activate waste backlog storage
all types of site and include primary increases in waste generation. contingency
and secondary care, mental health
facilities and ambulance sites. Regional severe weather events,
such as snowfall or flooding.
National Issues that cross more than two (2) Critical supplier failure, for example • Review whether a National
adjoining or more than three (3) where services were disrupted Capacity Coordinator is required
unconnected NHS regions. Will vary prior to an organisation going into and take action if necessary
in severity and can be triggered by administration. • National Logistics Cell (or others)
a variety of activities. commence daily data gathering
Major compliance issues caused by
the stockpiling of waste on supplier from NHS and service sectors
sites. • Activate waste backlog storage
contingency
National surge in demand for
clinical waste treatment. • Assess market capacity
• Seek regulatory relief where
Organisations failing to correctly applicable and necessary, such
segregate their waste in line with as RPSs/carriage of dangerous
HTM 07-01. goods authorisations
107
Principles in pandemic waste 6.154 It is also important to consider the

management impact on non-clinical wastes, with specific
consideration given to ways in which
6.153 The response to the COVID-19 packaging and PPE waste can be minimised
pandemic has demonstrated the need for and cross-contamination avoided.
healthcare organisations to be able to
quickly adapt their waste management 6.155 Healthcare organisations should
arrangements, in response to rapid check for any research carried out specific
increases in waste volumes and temporary to the disease or infection, to determine the
changes in the way in which healthcare extent to which waste could serve as a
waste is managed. vector for the disease, as this will likely have
a significant impact on the way in which
During the COVID-19 pandemic the NHS waste services are provided, and potential
produced a waste management standard control measures. This should also include
operating procedure (SOP) to help checking for any pandemic-specific waste
ensure that the collective response to management guidance that may be issued
the delivery of waste management was by the NHS centrally or by any regulator.
consistent across all organisations. In the
event of a pandemic or major incident, 6.156 There are a number of key principles
the NHS website should be checked that should be considered in any response,
to identify whether an SOP has been as summarised in Figure 23.
produced, and organisations should fully
6.157 When responding to an incident, it is
comply with the SOP where this is the
essential that there is regular and accurate
case.
Figure 23 Key principles in BCP response
Data
It is important that good quality data is available and shared quickly and efficiently, providing confidence that data driven decisions are based
on reliable information.
Shared resources Marketplace

The waste sector is complex, with competing variables that can quickly lead to a
National oversight of infrastructure and disruption in the level(s) of service and/or operational continuity. Contractors tend to
service resilience is needed. Visibility on operate autonomously.
the distribution of spare treatment
Understand contractual provisions and implement where appropriate. Know when to
capacity is essential. enforce a contract and when to work with the contractor.
Continuity plans Long term planning Regulatory support

Organisational BCPs should be actively
Acknowledgement of the aims and It is important to understand whether
maintained and updated to enable a
aspirations of the NHS Clinical Waste there is a need for derogation from
quick and agile response.
Strategy in helping to facilitate good existing regulation.
working relationships with the supply
Tailored plans should be developed that To be used as a last resort and only
chain so that service impacts are after other avenues have been
reflect waste sector and marketplace
better understood. explored.
issues
Compliance
Comply with applicable regulation and legislation at all times, unless derogation enacted by the regulator. Maintain detailed and accurate
records of all waste movements. Segregate waste correctly at all times and in accordance with HTM 07-01.
Relationships
Build and maintain good relationships with waste contractors and other NHS organisations. Work collaboratively to solve service issues,
sharing resource, information and best practice where practical.
108
reporting of data so that situational effective in the response to the COVID-19

responses can be based on well-informed pandemic, when the daily central reporting
and reliable information. of waste volumes helped to manage
network capacity by mapping and
6.158 In such a scenario, ensure that waste coordinating infectious waste treatment
volumes and movements are documented capacity against demand (see Figure 24).
on a daily basis if feasible. This proved to be
Figure 24 Key principles in waste management response to pandemic
Pandemic Response Key Principles
Waste generation Classification and Transport and Treatment and

segregation packing disposal
Clinical waste
volumes likely to Simple and Activities to be Logistics and waste
increase – do not pragmatic approach carried out in full treatment demand
forget about other required that can be consultation with may be co-
waste types easily understood DGSA ordinated centrally
and switched on where incident
Consider and off at short notice In accordance with response team
opportunities to HTM 07-01 unless established
minimise in-ward Classify infectious otherwise specified
waste generation and non-infectious in response to Consider
(i.e. reduce waste as it would be specific pandemic opportunities for on-
materials brought at any other time site treatment
on to ward) Likely strain on
Stick to colour support systems, Likely to involve
Maintain accurate coding principles collection and same treatment and
records of volumes transport disposal methods
and types of waste Transportation of infrastructure as other infectious
bulk infectious waste wastes
Prevent cross- is permitted only
contamination of using bulk clinical Check for temporary
PPE and packaging waste bags and changes in
specialist bulk regulation (e.g.
Understand vehicles RPSs) with EA,
transmission routes HSE and DfT
and whether waste Requirements may
management is a vary subject to
vector whether patient is
infected or not
Requirements may vary subject to healthcare setting
109
Appendix 1 – Technical
Note that the pathogen list below is indicative, not exhaustive.
A1.1: Category A pathogen list

UN number and name Microorganism
UN 2814 • Bacillus anthracis (cultures only)
Infectious substance affecting humans • Brucella abortus (cultures only)
• Brucella melitensis (cultures only)
• Brucella suis (cultures only)
• Burkholderia mallei – Pseudomonas mallei – Glanders (cultures only)
• Burkholderia pseudomallei – Pseudomonas pseudomallei (cultures only)
• Chlamydia psittaci – avian strains (cultures only)
• Clostridium botulinum (cultures only)
• Coccidioides immitis (cultures only)
• Coxiella burnetii (cultures only)
• Crimean-Congo haemorrhagic fever virus
• Dengue virus (cultures only)
• Eastern equine encephalitis virus (cultures only)
• Escherichia coli, verotoxigenic (cultures only)
• Ebola virus
• Flexal virus
• Francisella tularensis (cultures only)
• Guanarito virus
• Hantaan virus
• Hantavirus causing haemorrhagic fever with renal syndrome
• Hendra virus
• Hepatitis B virus (cultures only)
• Herpes B virus (cultures only)
• Human immunodeficiency virus (cultures only)
• Highly pathogenic avian influenza virus (cultures only)
• Japanese Encephalitis virus (cultures only)
• Junin virus
• Kyasanur Forest disease virus
• Lassa virus
• Machupo virus
• Marburg virus
• Monkeypox virus
• Mycobacterium tuberculosis (cultures only) ª
• Nipah virus
• Omsk haemorrhagic fever virus
• Poliovirus (cultures only)
• Rabies virus (cultures only)
• Rickettsia prowazekii (cultures only)
• Rickettsia rickettsii (cultures only)
• Rift Valley fever virus (cultures only)
• Russian spring-summer encephalitis virus (cultures only)
• Sabia virus
• Shigella dysenteriae type 1 (cultures only) ª
• Tick-borne encephalitis virus (cultures only)
• Variola virus
• Venezuelan equine encephalitis virus (cultures only)
• West Nile virus (cultures only)
• Yellow fever virus (cultures only)
• Yersinia pestis (cultures only)
110
UN number and name Microorganism

UN 2900 • African swine fever virus (cultures only)
Infectious substance affecting animals only • Avian paramyxovirus Type 1 – Velogenic Newcastle disease virus (cultures
only)
• Classical swine fever virus (cultures only)
• Foot and mouth disease virus (cultures only)
• Lumpy skin disease virus (cultures only)
• Mycoplasma mycoides – Contagious bovine pleuropneumonia (cultures only)
• Peste des petits ruminants virus (cultures only)
• Rinderpest virus (cultures only)
• Sheep-pox virus (cultures only)
• Goatpox virus (cultures only)
• Swine vesicular disease virus (cultures only)
• Vesicular stomatitis virus (cultures only)
ª Nevertheless, when the cultures are intended for diagnostic or clinical purposes, they may be classified as infectious substances
of Category B (carriage on road only)
111
A1.2: Duty of care checklist

Duty of care checklist
Responsibilities for waste pending collection
Containers clearly labelled and secure
Limiting access to waste and their storage areas (from unauthorised personnel and pests)
Vehicles for collection are covered and secured
Wastes accurately described on Waste Transfer Notes/Hazardous Waste Consignment Note
Collate documents
Environmental permits and waste exemptions
(Check EA Public Register and request copies from contractors)
Waste carrier and/or broker registrations
(Check EA Public Register)
Records of enforcement action
(Check EA Public Register and HSE website)
Business documents for organisations involved in the waste supply chain:
ISO accredited management systems (in particular ISO 14001 Environmental Management Systems, ISO 9001 quality management
systems and ISO 45001 health and safety management systems)
Insurance provision. Waste contractors, as a minimum, are to hold public liability insurance and employer’s liability insurance
Hazardous Waste Consignment Notes (retained for two years minimum)
Waste Transfer Notes (retained for two years minimum)
Quarterly Returns
(from waste treatment and/or disposal operators)
Pre-acceptance audits
Training records
Risk assessments (health organisation and the waste contractor)
Compliance with Carriage of Dangerous Goods
Appointed Dangerous Goods Safety Adviser (DGSA)
Vehicles or packages supplied or used by a waste contractor are compliant with the relevant legislation
Correct use of UN number and class hazard label
Ensure drivers have all required authorisations and documentation in place and records maintained
• Authorisation document issued by Department of Transport for waste collected in bags or in non-UN-approved clinical waste
packages
• Dangerous Goods Declaration
• Instructions in writing
Recovery or final disposal
Check the permit allows for the waste types to be accepted
Check the waste activity on the permit matches the expectations of how the waste is reused, recycled, recovered or disposed
Site visit to learn and observe how healthcare waste is handled, treated/disposed of
(Optional, it is best practice to audit sites where possible)
112
A1.3: WM3 hazards

Hazard
C1: Explosive (HP 1)
C2: Oxidizing (HP 2)
C3: Flammable (HP 3)
C4: Irritant (HP 4)
C5: Specific Target Organ Toxicity/Aspiration Toxicity (HP 5)
C6: Acute Toxicity (HP 6)
C7: Carcinogenic (HP 7)
C8: Corrosive (HP 8)
C9: Infectious (HP 9)
C10: Toxic for Reproduction (HP 10)
C11: Mutagenic (HP 11)
C12: Produces toxic gases in contact with water, air or acid (HP 12)
C13: Sensitising (HP 13)
C14: Ecotoxic (HP 14)
C15: Capable of exhibiting a hazardous property listed above not directly displayed by the original waste (HP15)
C16: Persistent Organic Pollutants
113
Appendix 2 – Non-clinical waste and resource
114
management principles
The management of non-clinical waste is vital to achieving and 5. EWC codes for the classification of non-clinical wastes,
the strategic objectives, goals and targets laid out in Chapter and hazards associated with non-clinical waste streams, can
2. Non-clinical wastes may possess hazardous properties, and be found in Technical Guidance WM3 (Environment Agency,
must be handled, stored, treated and disposed of in 2021a).
accordance with the relevant guidance set out in Chapters 4
Waste type Description Waste prevention, resource Waste segregation, storage, Recovery, treatment and disposal Case studies
efficiency and circular economy handling and collection
implementation
Non-hazardous General waste • Switching from single-use items Recyclables and residual general A waste contractor may be appointed to collect The Newcastle
residual waste of the type (such as paper cups) to reusable wastes can be stored in the same and dispose of residual waste. Typically, residual upon Tyne
produced by equivalents (glass or ceramic room but should be stored in waste may be incinerated, landfilled or sent to Hospitals NHS
households. cups) separate designated bins. a materials recovery facility (MRF) to have any Foundation Trust
Often consists • Waste and recycling bins should recyclable content recovered from it. switched to
It is recommended that residual
of food scraps be placed strategically and paired reusable canteen
waste is stored in black bins,
(where not wherever possible. Bins should cutlery, bowls,
although clear/opaque receptacles
processed as be placed in locations where straws and side
may also be used.
a separate they are likely to be needed and plates in 2017,
waste stream), should ideally be placed so that Hazardous wastes (including some saving £80,000
non-recyclable one is always in view deodorants, batteries etc.) and annually, and
plastics, clinical wastes should never be diverting from
• Provide recycled plastic cups
packaging, placed in the black-bag residual landfill:
for use with vending machines
non-infectious waste stream. • 513,600
and/or encourage staff to use
textiles, and disposable
reusable mugs.
small amounts polypropylene
of inorganic bowls
materials, such as
• 490,800
stone.
disposable
Represents polypropylene
waste that is left lids for bowls
once all other • 312,000
efforts have polystyrene
been made to bowls
prevent, reuse,
• 371,000 plastic
recycle or recover
spoons
materials.
• 216,000 plastic
knives
implementation
Organic waste Organic waste, • Ensuring a robust system for Should be collected separately at Macerators are disposal units that allow food In 2014, Cardiff
such as food measuring food waste from source (kitchen and cafeteria) and waste to be flushed down existing drains, leaving and Vale University
waste from difference sources (kitchen waste, kept separate. food preparation and bin areas clean and free Health Board
kitchens, green plate waste, unserved meals), so from hygiene problems. This option allows for introduced
Under the Environment Act, a reduced reliance on waste collection but does separate
landscaping that prevention interventions can
this stream should be collected not allow for any recovery opportunities, so is not collections of
waste from be identified
separately (not mixed) with other preferred under the waste hierarchy, and is not food waste
grounds • Sending back reusable items to streams. permitted in Northern Ireland. for anaerobic
maintenance and suppliers where possible (such as
floral displays cooking oil) The nature of the waste, in digestion.
Organic waste may be sent to a composting or
particular food waste, may give This diverts an
• Utilising “just in time” anaerobic digestion (AD) facility for energy and/
rise to problems with vermin. estimated 0.52
procurement for goods and or fertiliser generation. Organic waste may also
General operational practices will kg of food waste
examining sales patterns, to be treated on-site through several methods. For
reduce the potential for vermin from landfill per
avoid over-purchasing (leading instance, organic waste may be treated on-site
infestations, and other controls in bed per week and
to food products unnecessarily with de-watering technologies, which remove
place to prevent problems include: helps to generate
being thrown away) excess water and so the weight of organic wastes, renewable bio-
• Utilising digital meal ordering • waste should not be stored on before onward treatment and further recovery at energy.
systems in hospitals, enabling site for extended periods, with at an AD site for example. Organic waste may also
healthcare and catering teams to least daily removal of food waste be subject to on-site aerobic digestion, where In 2013 Somerset
adapt food provision to patient recommended a bio-enzymatic formula turns food waste into Partnership NHS
Appendix 2 – Non-clinical waste and resource management principles

needs, manage allergies and • the area around the food waste grey water, and via filters enters the drainage Trust Foundation
diets, and minimise waste storage should be cleaned after system. This option allows for a reduced reliance introduced
every removal and at frequent on waste collection, but depends on local water separate food
• Considering the possibility of
intervals throughout the day governance arrangements; and any further collection, and
entering a “back-of-store”
recovery opportunities, including EfW or fertiliser designated food
surplus food partnership with a • the floor of the loading areas
production, would depend on the units used and/ waste bins. The
local charity so that any surplus should be regularly cleaned
or the Trust’s water treatment facility. tonnage collected
food waste generated could throughout the day and at the
by the contractor
be put to good use. If it is not end of every working day. In-Vessel Composting (IVC) can be used to treat indicates that,
possible for this waste to be • the food waste storage bins wastes that have biosecurity or odour issues and alongside a new
redistributed to people, then should be cleaned regularly facilitate pathogen destruction, such as food dry recycling
consideration could be given for wastes. For IVC to operate successfully, structural
• any waste spillage should be scheme, the food
its use as an ingredient in animal material is needed to be added to the process; this
cleared up, as soon as practically waste scheme
feed is normally green waste or wood chip. A permit
possible. has contributed
• Selecting plant landscaping that is required to use composted material off-site, to an overall
requires low maintenance and Collection of green wastes would and this should be factored into decision-making recycling rate of
produces less waste have to be coordinated to ensure (does the facility have grounds in which to use the between 75% and
that wastes are removed from the compost, or is getting a permit feasible?)
• Working with in-house catering 88% between
site after services are completed. November 2013
staff or contractors to identify Green waste is typically treated as a segregated
opportunities (and contractual waste stream through windrow composting or AD and January 2014.
incentives) to reduce food waste but can also be managed using IVC that utilises
through: this as a bulking agent.
• control of ordering for working
Organic waste is generally not suitable for
lunches
incineration because the moisture content is too
• active management of the high.
quantities cooked in canteens
115
• control of stock ordering

menus that make use of
“leftovers”.
116
implementation
Recyclable Items such as • Waste and recycling bins should It is recommended that dry The preferred option is for this waste stream to East Sussex
waste non-infectious / be placed strategically and paired recyclables are separated at source be collected by the local government authority or Healthcare
non-chemically wherever possible. Bins should be and collected separately. waste contractor for recycling at a permitted and NHS Trust, in
contaminated placed in locations where they are licensed facility. partnership with
Bins for recyclable waste should
glass, including likely to be needed and should Veolia conducted
be clustered, clearly marked, and Mixed recyclables can be sorted and separated at
bottles, jars, ideally be placed so that one is a waste audit of
present in areas of high waste MRFs. Source segregated materials can be sent
glassware, always in view. their key sites
generation and high footfall directly to re-processors for recycling, provided
and non- and introduced
• Sending back reusable items to (waiting rooms, reception, there is little contamination.
contaminated bespoke recycling
suppliers where possible corridors, cafeterias etc).
vials; plastics, points within the
such as PET and • Utilising ‘just in time’ Some recyclables (plastics, ferrous hospitals as well
HDPE bottles, procurement for goods and and non-ferrous cans etc) can be as introducing
food containers, examining sales patterns, to avoid processed on-site via baling and recycling at ward-
bottles, and over-purchasing (leading to food compaction, which can be done level (in staff and
cups; polystyrene products unnecessarily being with machines (typically when common rooms).
packaging, and thrown away) dealing with large quantities of Recycling has
metals such as recyclables). These are used to bind increased by 30%
aluminium, and together the separated material and delivered a
ferrous drink streams and provide compaction. 20% decrease in
cans, food tin Baling reduces transport volume. general waste.
cans, other metal Compaction achieved through
containers such baling is advantageous for
as empty paint hospitals, as it reduces the storage
containers space required. However, baling/
compaction should only be used if
the receiving facilities requirements
can accommodate the material in
this form.
implementation
Recyclable Non- • Reducing the amount of Should be kept separate from non- In many places collected by a local government
waste contaminated packaging used to ship or recyclable wastes to avoid cross- authority or waste contractor for recycling at a
(contd) paper and transport products; for instance, contamination. permitted and licensed facility.
cardboard waste switching from cartonless bottles
Paper and card can be processed Stationery and office paper may be returned to
(packaging or using multi-month packs
via bailing and compaction to the supplier if unused or undamaged.
waste, • Ensuring a returns policy is in reduce storage space requirements,
office paper, place with suppliers for unsold provided the receiving facility’s
newspapers, and damaged goods requirements can accommodate the
magazines etc).
• Storing and reusing cardboard material in this form.
Recyclable in
shipping boxes
most areas. Bales would need to be stored in
• Training staff on how to properly a suitably fire-rated area. They are
handle packaging and avoid typically transported with a forklift
contamination in order to allow truck, which would be required
for reuse, in addition to ensuring to manoeuvre the bales from the
that incoming packaging is central waste storage area to the
segregated for recycling loading dock for removal off-site.
• Bulk buying items such as office

supplies to reduce the amount of
packaging
• Avoiding colour printing
whenever possible
• Setting double-sided printing
as the default option for
photocopiers and staff
computers, and raising awareness
of this with staff to discourage
single-sided printing
• Using single spacing and
narrower margins for less
important documents
• Reusing out-of-date headed
paper and wasted printouts as
scrap/notebooks
• “Unsubscribing” from senders of
junk mail
117
118
Waste type Description Waste prevention, resource Waste segregation, storage, Recovery, treatment and Case studies
efficiency and circular handling and collection disposal
economy implementation
Waste Electronic and • IT equipment (computers, • Sending back reusable WEEE should be stored in a Electronics can be hazardous Whittington Health NHS
Electrical Equipment (WEEE) monitors, printers, items to suppliers where safe, secure area. to the environment and trust, in partnership with
keyboards etc) possible should be returned to the CRT group dispose of around
Care should be taken to
• Specialist equipment • Ensuring a returns policy manufacturer for disposal / 350 PCs, laptops, and mobile
ensure that equipment that
(coagulators, centrifuges, is in place with suppliers recycling where possible (as phones per year.
may be capable of repair
audiometry equipment, for unsold and damaged in the case of certain medical
and reuse is not further These devices have their
dialysis equipment, goods / laboratory electronics) or
damaged in storage. hard drives removed,
cardiology equipment, handed off to a designated
• Investing, where possible, cleared, and shredded (to
microscopes, autoclaves, Compliance schemes government agency or
in high-quality equipment ensure no sensitive data
mobile digital X-ray and waste management specialist contractor.
that is durable and is retained) before being
equipment, oscilloscopes repairable companies that collect WEEE should be sent to refurbished and donated
etc) WEEE may require that it be
• Switching from analogue specialist WEEE recyclers to charities including
• Bulky equipment separated in a certain way.
to digital X-ray systems to ensure environmentally homeless shelters, and
(refrigerators, freezers, to eliminate the stream Waste storage areas friendly and safe disposal. education projects. This
biosafety cabinets, of hazardous fixer, for WEEE will require Simpler / non-laboratory initiative has saved the
televisions, washing developer, and film appropriate firefighting WEEE can be repaired and trust approximately £3-5
machines, fans, methods as water will not / or donated (for instance per device in disposal costs,
• Considering renting
microwaves, cookers etc) be typically used in such in the case of outdated IT totalling around £1400 per
equipment that is used
• Implanted devices environments. equipment). year.
only occasionally rather
(pacemakers) than having to store, Disposal of electronic
• Lighting equipment maintain and calibrate it equipment will need to be in
(fluorescent tubes/bulbs) in the workplace accordance with the Waste
• All other electronics, • Not allowing obsolete Electrical and Electronic
and electrical equipment equipment to take up Equipment Regulations and,
(radios, speakers, space and collect dust. if hazardous, the Hazardous/
monitoring and control The sooner it is recycled, Special Waste Regulations.
equipment such as the quicker that valuable IT equipment can often
thermostats, smoke resources will be available be repaired, or have
detectors and heating for reuse, thus avoiding components replaced.
regulators etc) the processing of more
virgin materials Specialist WEEE
• Allocating space in the equipment should, if
central waste storage area possible, be returned to
for bulky items prior to the manufacturer for
collection/reuse. refurbishment, or specialist
deconstruction and
recycling.
Simple microscopes should

be safe to sell from scrap/
local recycling.
Producers should contact

their waste contractor to
establish the best-practice
disposal route for implanted
devices.
implementation
Waste Batteries • Developing a procurement Batteries should be segregated Batteries can contain chemicals such as lead, NHS Scotland
Electronic policy which explicitly precludes and collected separately. The mercury, or cadmium. If they are disposed of advocates the use
and Electrical purchasing products that contain waste receptable should be clearly to landfill, the chemicals they contain may leak of rechargeable
Equipment toxic materials such as mercury, labelled with the type of waste and into the ground. This can pollute the soil and batteries wherever
(WEEE) PVC, or glutaraldehyde; and the name of the major chemicals, water and potentially harm human health. The possible, as they
(contd) setting progressive targets with any necessary hazard labels preferred option for disposing of batteries would estimate that the
for those which cannot yet be attached to corrosive, flammable, be to return these to the supplier or send them energy required
eliminated. explosive or toxic chemicals. to a specialist recycling facility to recover metals, to manufacture a
• Sending back reusable items to including valuable metals such as nickel, cobalt, single-use battery
The liquid contents of batteries
suppliers where possible. and silver. is approximately
should never be mixed or disposed 50 times greater
• Ordering only from suppliers who of down the drain but should Note that under duty of care and Hazardous than the energy
provide rapid delivery of small be stored in strong leak-proof Waste Regulations mixing prohibition, nickel the battery will
orders and who accept the return containers. cadmium and lead acid batteries would need give out in its
of unopened stock to be segregated and recycled/disposed of
Where Healthcare facilities provide lifetime.
• Provide separate storage appropriately.
recycling bins for batteries, they
receptacles in waste storage will be required to comply with
rooms for batteries the requirements of the Hazardous

Waste Regulations and the Carriage
Regulations, which establish special
rules for packaging.
Gypsum and Gypsum-rich • Limited opportunities given The vast majority of plaster casts These materials, if they enter a normal landfill
plaster casts wastes are likely healthcare need. and models are not infectious and with other waste including residues from clinical
to be produced must not be placed in the clinical waste disposal, may produce hydrogen sulphide
from: waste stream. Gypsum plaster gas. For this reason, it is prohibited from landfill.
• plaster casts casts should not be placed in the
The two main disposal options for non-
and related offensive waste stream either.
contaminated gypsum wastes are:
materials in These should be segregated as a • gypsum recycling
accident and specific 18 01 04 gypsum waste
emergency • hazardous waste landfill
stream.
departments,
Procedures should be put in place to identify and
fracture clinics,
segregate the small proportion that is genuinely
and perhaps
contaminated and poses a risk of infection – this
veterinary
may then be disposed of in the orange bag.
surgeries.
• plaster models
in dental
practices and
similar units in
hospitals. They
may also be
produced by
chiropodists/
119
podiatrists.
120
Waste type Description Waste prevention, resource Waste segregation, storage, handling and collection Recovery, treatment Case
efficiency and circular economy and disposal studies
implementation
Non-clinical chemicals Heavy metals • Developing a procurement Hazardous chemical wastes of different composition should be Less hazardous
contained in policy which explicitly precludes stored separately to avoid unwanted chemical reactions. chemical wastes
medical devices, purchasing products that contain may be diluted and
Waste storage areas for chemicals will require appropriate
such as mercury toxic materials such as mercury, disposed of using
firefighting methods as water will not be typically used in such
in broken PVC, or glutaraldehyde; and sewage/wastewater
environments.
thermometers, setting progressive targets drains. Larger
aerosols, POPs, for those which cannot yet be Care should be taken to ensure that liquid chemical wastes are quantities and more
hand gels, cleaning eliminated. never disposed of down the drain. hazardous chemical
materials, bleaches, • Sending back reusable items to wastes will require
varnishes etc A liquid and chemical resistant sump should be provided in more advanced
suppliers where possible.
areas set aside for washing of bins containing chemical wastes. treatment. Where
• Using minimum concentrations
possible, chemical
of chemicals where possible Chemical waste must be collected in strong leak-proof
wastes should be
containers that resist reaction with the type of chemical it
• Centralised purchasing of returned to the
hosts, labelled accordingly, never mixed with other chemicals,
hazardous chemicals supplier, or passed
and sent to specialized treatment facilities (if available).
• Monitoring of chemical ﬂows on to a licensed
within the health facility from The characteristics of different chemicals should be carefully contractor, or suitable
receipt as raw materials to considered prior to storage and subsequent disposal, taking government body for
disposal as hazardous wastes into account flammability, corrosivity and explosivity. A disposal.
separate zone should be allocated in the central waste storage
• Ordering only from suppliers Large amounts of
area for storage of chemical waste, with further separation
who provide rapid delivery of chemical waste
recommended depending on the hazard class. The central
small orders and who accept the should not be
waste storage area should be equipped with adequate lighting
return of unopened stock buried, because
and ventilation, spillage kits, PPE and first aid equipment.
• Preventing the accumulation they may leak from
of significant quantities of The chemical waste storage zone in the central waste storage their containers,
outdated chemical products by: area should be built with materials that are able to withstand overwhelm the
• Regularly ordering smaller explosion or leakage. Liquid and solid chemical wastes natural attenuation
quantities of product rather should be segregated. For storage of liquid chemicals, it is process provided
than in bulk and all in one go recommended that a chemical-proof sump is incorporated into by the surrounding
the storage system. If this is not possible, then catch-containers waste and soils, and
• Using the oldest batch of a should be placed under the storage containers to collect any contaminate water
product ﬁrst leaked liquids. Packaging used for the storage and off-site sources.
• Using all the contents of each transport of chemical waste should be appropriately labelled,
container indicating the hazardous class, date and point of generation,
• Checking the expiry date of where possible.
all products at the time of Alcohol hand gels that do not contain siloxanes (which cause
delivery. significant damage to plant and equipment used in the
• Provide storage receptacles in sewage treatment process) and which is not prohibited to be
waste storage rooms for unused discharged to the sewer may be rinsed out and the packaging
discarded hazardous chemicals recycled or placed into the domestic waste stream.
for example bleaches, varnishes,
etc.
implementation
Disability aids/ Disability aids/ • Ensuring a returns policy is in Aids should be stored in a Adequate space and equipment for refurbishment Refer to the
walking aids walking aids place for patients to return aids designated weatherproof area should be made available when disability aids/ Walking Aids
at the end of the patient’s care away from hazardous materials walking aids are repaired or refurbished by NHS Reuse How-To
needs. and other wastes. These items organisations. Such as workstations and storage Guide
• Implement an internal do not need to be stored in a bin of tools and equipment.
reuse scheme with in-house unless there is a reason to do so
(for instance if a large quantity of The manufacturer of the device should be
refurbishment or a reuse service contacted to establish whether a “take-back”
contract with suppliers for devices is being organised).
scheme exists for this equipment.
returned aids. Returned aids should be segregated
• Forming relationships with from refurbished devices to retain Used disability aids could also be donated to local
charities/other organisations that resources and value. It is suggested charities which may be accept the devices for
may be able to accept donations separate storage containers or reuse, refurbishment, or recycling.
of disability aids (charities, local areas for aids that have been Many of the components are likely to be
schemes/organisations) returned (before sorting), recyclable, with potential for income. Damaged
• When they have reached the end cleaned and pending further aids should be delivered to a local recycling
of their useful life, these items assessment, suitable for repair facility.
should be handled in accordance or refurbishment, and requiring

with the Waste Hierarchy recovery/treatment/disposal.
• Examine procurement and Refurbished aids should be stored
ordering practices to reduce in pairs.
overordering, and maximise
return and reuse schemes.
• Examine the disability aids used
in the organisation, and see
if there is scope to refurbish/
make them suitable for use in
accordance with the principles of
Circular Economy
121
122
implementation
Textiles Non-infectious • Ensuring a returns policy is in Clean textiles must be: The manufacturer of unused textiles should
textiles (clothes, place with suppliers for unsold • Stored in a designated, clean, be contacted to establish the possibility of
linen, and and damaged goods dust-free, closed cupboard to implementing a take-back or bring-back scheme.
curtains etc) • Forming relationships with prevent airborne contamination, Collection of such wastes by registered charity
charities/other organisations or on a dedicated fully enclosed collection services should also explored.
that may have use for textiles. mobile trolley.
Clothes and textiles that are in • Stored off the floor. Items that are not suitable to be passed onto
good condition can be donated someone else can be recycled and made into new
• Segregated from used/soiled items, for instance padding for chairs and car
to registered charities and reuse
textiles. seats, cleaning cloths and industrial blankets.
organisations.
• If there is exposure of clean
• When the bed linen is restocked
textile to any infectious agent,
daily, any unused linen should be
then it must be disposed of as
placed where it can be used first,
infected linen
to ensure stock rotation.
• Excessive amounts of linen Clean textiles must not be:
should not be taken into an • Stored in areas such as the sluice
isolation room/cohort area as any or in bathrooms.
unused linen must be treated as
• Decanted onto open trolleys
contaminated and disposed of
unless for immediate use.
accordingly.
• Effective management of bed
linen should ensure that there is
minimal or no excess linen left on
the ward each day.
implementation
Bulky waste Items that are • May potentially be repairable Bulky waste items are typically too The disposal of heavily soiled or infectious Barts Health
too large to or recyclable, depending on the large to be stored in bins, so should mattresses should be made through the waste NHS Trust has
be accepted nature of the item. be kept uncontained in a secure contractor. partnered with
by the regular • Sending back reusable items to area where possible. Globechain and
Most bulky items will be recyclable or feature
waste collection suppliers where possible (wooden Premier Sustain
Needs to be stored until collection component parts that are recyclable, for example
(refurbishment pallets, furniture, mattresses, to distribute
can be arranged. Materials such as timber, metal, cardboard, textiles.
waste, furniture, chairs tables, bed frames etc). bulky items which
wooden pallets should be properly
mattresses, bed Non-recyclable items can be sent to conventional are no longer
• Not allowing obsolete equipment stacked where possible to maximise
frames, tables, EfW facilities for energy recovery or to landfill. needed (furniture,
to take up space and collect dust. the ability to reuse them and
chairs) fittings, etc) to
The sooner it is recycled, the minimise safety hazards. local organisations
quicker that valuable resources
which can use
will be available for reuse, thus
them.
avoiding the processing of more
virgin materials. Globechain
• Allocating space in the central requires recipients
waste storage area for bulky to prepare case
items prior to collection/reuse. studies, so Barts

Health NHS Trust
can understand
how these items
are being used,
and Premier
Sustain creates
monthly reports
detailing the
GHG reductions
achieved through
the programme.
123
124
implementation
Depressurised Depressurised • Sending back depressurised According to the British BCGA’s Code of Practice 18 states that empty gas
containers gas cylinders or containers to suppliers where Compressed Gases Association’s containers should be returned to the supplier as
containers possible. (BCGA) Code of Practice 44, soon as possible.
“cylinders are never fully empty,
Aerosol cans may be classified as non-hazardous if
unless a cylinder is new, de-valved,
they are empty and can be sent to metal recyclers.
or following inspection and test
where it has not yet been filled
with a gas.” Therefore, their
storage is considered in-line with
full gas cylinders as described in
this Code of Practice. Gases with
the same hazard category should
be grouped together, with clear
signage used to indicate this.
It is recommended that
depressurised containers are stored
externally in secured compounds or
cages. If this is not possible, then
a dedicated internal storage room
with appropriate signage should be
allocated for this purpose.
It is recommended that full gas

containers are segregated from
empty ones, using labelling to
clearly indicate the ‘cylinder status’.
Empty cylinders should be treated
with the same caution as full ones
(by chaining or clamping them to
prevent them from falling over.
Small cylinders can be stored
horizontally on metal racks.
Appendix 3 – Waste segregation and classification
diagram
For information on
Is it identifying hazards
hazardous? and segregating Dental
Non -Hazardous No Yes
waste, see chapter 6
Uncontaminated Does it contain Infectious gypsum
Gypsum Does it contain Does it contain (18 01 03*, 18 02 02*)
medicines or
(18 01 04, 18 02 03) Yes gypsum No gypsum (casts Yes
hazardous Not exclusive
(from casts)? or dental)?
Infectious
Gypsum
Gypsum
chemicals? to dentistry
No
Yes No
Non -infectious Anatomical Dental Amalgam
Does it contain
(18 01 10*)
(18 01 02, 18 02 03) Yes anatomical
Yes
material?
infectious
Amalgam
Non -
No Does it contain
dental
(18 01 01, 18 02 01) Is it an amalgam?
Yes, from an Infectious waste containing
No separate bin - Yes uncontaminated infectious dental amalgam
Dispose of with sharp? (18 01 03* and 18 01 10*)
used sharps patient
No
Amalgam
Infectious
No
Non cytotoxic / cytostatic Is the item a

medicine waste medicine or non -
(18 01 09, 18 02 08, Yes X-ray fixer & Developer
sharp containing (09 01 01* - 09 01 05*)
20 01 32) Is it x -ray fixer
medicine? Yes
or developer?
No
X-ray
Medicinally contaminated
sharps Is it a sharp
(18 01 01 and 18 01 09) or
(18 02 01 and 18 02 08)
Yes containing No Radioactive Solid waste
medicines? (EWC code depends on properties)
No
No
Can it be
Offensive waste Is it
Yes decayed in
(18 01 04, 18 02 03, radioactive?
20 01 99)
storage? Low -level Radioactive
Yes Is it offensive? waste
Yes
Decay in storage
No
After
Confidential waste Decay
(various EWC codes)
Is it No
Yes Very Low -level Radioactive
confidential?
waste
No
Recyclable waste
(various EWC codes)
Is the item
Yes Does it contain Hazardous anatomical waste
recyclable? (18 01 03* and 18 01 06* / 18 01 07) or
hazardous Yes (infectious and / or (18 02 02* and 18 02 05* / 18 02 06)
anatomical chemically contaminated)

No material?
Domestic waste
(20 03 01) No
No Is it infectious?
Known infectious waste

Yes (no medicines)
No (18 01 03*, 18 02 02*)
Does it have
cytotoxic / Is it a sharp?
Is it a sharp? Yes
cytostatic Used, non medicinally
properties? contaminated sharps
Yes (18 01 03*, 18 02 02*)
No (infectious and
No (infectious and
medically
No Yes No chemically
contaminated)
contaminated)
Cytotoxic / cytostatic waste Cytotoxic / cytostatic sharps Infectious medicinally Infectious and contaminated Infectious and contaminated
(18 01 08*, 18 02 07*, (18 01 03* and 18 01 08* / 20 01 31*) or contaminated sharps with chemicals with medicines
20 01 31*) (18 02 02* and 18 02 07* / 20 01 31*) (18 01 03* and 18 01 09) or
(18 02 02* and 18 02 08)
(18 01 03* and 18 01 06* / 18 01 07) or
(18 02 02* and 18 02 05* / 18 02 06)
(18 01 03* and 18 01 09) or
(18 02 02* and 18 02 08) Hazardous
Appendix 4 – List of case studies
Appendix 4 – List of case studies
• The five R’s of sustainability – Various • Online reuse network – St Mary’s

health organisations Hospital, Isle of Wight
• Sustainable procurement – East • Cost saving through disposal of sharps
Staffordshire Care Commissioning Group – University Hospitals Coventry and
Warwickshire NHS Trust
• Sustainable procurement – Hospitals
Caterers Group & WRAP • Recovery of heat and resources from
healthcare waste – London North West
• Waste reduction – Great Ormond Street University Health organisation
Hospital NHS Foundation Trust
• Dental waste reduction – University of
• Waste reuse – Mid-Essex Hospital Trust Plymouth Health organisation
• Waste reprocessing – Leeds Teaching • Non-clinical waste – Newcastle upon
Hospital Tyne Hospitals NHS Foundation Trust
• Renewable procurement – Skåne region, • Non-clinical waste – Cardiff and Vale
Sweden University Health Board
• On site manufacturing – Automedi, UK • Non-clinical waste – Somerset
• Reuse, refurbishment, and re-purposing Partnership NHS Trust Foundation
– NHS Supply Chain • Food waste recovery – Somerset NHS
• Maximise reduce reuse and recycle Foundation Trust
thorough correct segregation – Various
health organisations including Intensive
Care Unit at St James’s Hospital
125
References
https://www.legislation.gov.uk/
Legislation uksi/2012/811/made
The following list is legislation cited
throughout this document: Controlled Waste (Registration of Carriers
and Seizure of Vehicles) Regulations 1991.
Animal By-Products (Enforcement) https://www.legislation.gov.uk/
(England) Regulations 2013. uksi/1991/1624/contents/made
uksi/2013/2952/contents/made Controlled Waste and Duty of Care
(Amendment) Regulations (Northern
Carriage of Dangerous Goods (Amendment) Ireland) 2014.
Regulations 2019. https://www.legislation.gov.uk/nisr/2014/117/
https://www.legislation.gov.uk/ contents/made
ukdsi/2019/9780111176658
Data Protection Act 2018.
Carriage of Dangerous Goods and Use of https://www.legislation.gov.uk/
Transportable Pressure Equipment ukpga/2018/12/contents/enacted
(Amendment) (EU Exit) Regulations 2020.
https://www.legislation.gov.uk/ Directive 2008/98/EC of the European
uksi/2020/1111/contents/made Parliament and of the Council of 19
November 2008 on waste and repealing
Clean Neighbourhoods and Environment certain Directives Waste Framework
Act 2005. Directive.
https://www.legislation.gov.uk/ https://www.legislation.gov.uk/
ukpga/2005/16/contents eudr/2008/98/contents
Control of Substances Hazardous to Health Environment Act 2021.
(Amendment) Regulations 2004. https://www.legislation.gov.uk/
https://www.legislation.gov.uk/ ukpga/2021/30/contents/enacted
uksi/2004/3386/contents
Environmental Permitting (England and
Controlled Drugs (Supervision of Wales) (Amendment) (EU Exit) Regulations
management and use) Regulations 2013. 2019.
https://www.gov.uk/government/ https://www.legislation.gov.uk/uksi/2019/39/
publications/information-about-controlled- contents
drugs-regulations
Environmental Protection Act 1990.
Controlled Waste (England and Wales) https://www.legislation.gov.uk/
Regulations 2012. ukpga/1990/43/contents
126
References
Environmental Protection (Duty of Care) https://www.legislation.gov.uk/

(Amendment) (Wales) Regulations 2003. uksi/2019/590/contents/made
wsi/2003/1720/contents/made Ionising Radiation (Medical Exposure)
(Amendment) Regulations 2018.
(Scotland) Regulations 2014. uksi/2018/121/contents/made
https://www.legislation.gov.uk/ssi/2014/4/
contents/made Ionising Radiations Regulations (Northern
Ireland) 2017.
Regulations 1991. nisr/2017/229/contents/made
uksi/1991/2839/made Ionising Radiations Regulations 2017.
Hazardous Waste (England and Wales) uksi/2017/1075/contents/made
Regulations 2005.
https://www.legislation.gov.uk/ Landfill Regulations (Northern Ireland)
uksi/2005/894/contents/made 2003.
Health and Safety at Work etc. Act 1974. nisr/2003/496/contents/made
ukpga/1974/37/contents Landfill (Scotland) Regulations 2003.
https://www.legislation.gov.uk/ssi/2003/235/
Health and Safety (Consultation with contents/made
Employees) Regulations 1996.
https://www.legislation.gov.uk/ Management of Health and Safety at Work
uksi/1996/1513/contents/made Regulations 1999.
Health and Safety (Sharp Instruments in uksi/1999/3242/regulation/16/made
Healthcare) Regulations 2013.
https://www.legislation.gov.uk/ Misuse of Drugs (Amendment) (England,
uksi/2013/645/contents/made Wales and Scotland) Regulations 2020.
Health and Social Care Act 2008 Code of uksi/2020/559/contents/made
Practice on the prevention and control of
infections and related guidance. Misuse of Drugs and Misuse of Drugs (Safe
https://assets.publishing.service.gov.uk/ Custody) (Amendment) (England and Wales
government/uploads/system/uploads/ and Scotland) Regulations 2018.
attachment_data/file/449049/Code_of_ https://www.legislation.gov.uk/
practice_280715_acc.pdf uksi/2018/1383/contents/made
International Waste Shipments Producer Responsibility Obligations

(Amendment of Regulation (EC) No (Packaging Waste) (Amendment) (England)
1013/2006 and 1418/2007) Regulations 2021. Regulations 2020.
https://www.legislation.gov.uk/ https://www.legislation.gov.uk/
uksi/2021/785/made uksi/2020/1336/contents/made
International Waste Shipments Producer Responsibility Regulations 2014.

(Amendment) (EU Exit) Regulations 2019. https://www.gov.uk/government/collections/
producer-responsibility-regulations
127
Public Services (Social Value) Act 2012. Waste Incineration Regulations (Northern
https://www.legislation.gov.uk/ Ireland) 2003.
ukpga/2012/3/contents https://www.legislation.gov.uk/
nisr/2003/390/contents/made
Radioactive Substances Act 1993.
https://www.legislation.gov.uk/ Waste and Contaminated Land
ukpga/1993/12/contents (Amendment) Act (Northern Ireland) 2011.
https://www.legislation.gov.uk/nia/2011/5/
Regulation (EC) No 1272/2008 of the contents
European Parliament and of the Council of
16 December 2008 on classification, Waste exemption: NWFD 3 temporary
labelling and packaging of substances and storage of waste at a place controlled by
mixtures, amending and repealing the producer.
Directives 67/548/EEC and 1999/45/EC, and https://www.gov.uk/guidance/waste-
amending Regulation (EC) No 1907/2006. exemption-nwfd-3-temporary-storage-of-
https://www.legislation.gov.uk/ waste-at-a-place-controlled-by-the-
eur/2008/1272/contents# producer
Reporting of Injuries, Diseases and Waste Framework Directive. Directive

Dangerous Occurrences Regulations 2013. 2008/98/EC of the European Parliament and
https://www.legislation.gov.uk/ of the Council of 19 November 2008 on
uksi/2013/1471/contents waste and repealing certain Directives.
Safety Representatives and Safety eudr/2008/98/contents#
Committees Regulations 1977.
uksi/1977/500/contents/made Approved Codes of Practice
The following Approved Codes of Practice
Special Waste Amendment (Scotland) have been cited throughout this document:
Regulations 2004.
https://www.legislation.gov.uk/ssi/2004/112/ Department for Environment, Food & Rural
contents/made Affairs (2018). Statutory guidance: Waste
duty of care code of practice.
Waste (Circular Economy) (Amendment) https://www.gov.uk/government/
Regulations 2020. publications/waste-duty-of-care-code-of-
https://www.legislation.gov.uk/ practice
uksi/2020/904/contents/made
Health and Safety Executive (2013). L5: The
Waste (England and Wales) Regulations Control of Substances Hazardous to Health
2011. Regulations 2002. Approved Code of
https://www.legislation.gov.uk/ Practice and guidance (Sixth edition).
uksi/2011/988/contents/made https://www.hse.gov.uk/pubns/books/l5.htm
Waste (Scotland) Regulations 2012. International Maritime Organisation (2019).
https://www.legislation.gov.uk/ The International Maritime Dangerous
sdsi/2012/9780111016657/contents Goods (IMDG) Code.
https://www.imo.org/en/OurWork/Safety/
Waste and Contaminated Land (Northern
Pages/DangerousGoods-default.aspx
Ireland) Order 1997.
nisi/1997/2778/contents/made
128
References
Waste Duty of Care: Code of Practice https://fgdpscotland.org.uk/wp-content/

(Wales) (2018). uploads/2016/09/WASTE.pdf
https://assets.publishing.service.gov.uk/
government/uploads/system/uploads/ BSi (2020). BS EN ISO 23907-1:2019, Tracked
attachment_data/file/759083/waste-code- Changes. Sharps injury protection.
practice-2018.pdf Requirements and test methods. Single-use
sharps containers. BSOL Standards Online.
Waste Management: The Duty of Care: A
Code of Practice for Northern Ireland. Cabinet Office (2020). Policy paper:
(2016). Legislation.gov.uk. Procurement Policy Note 06/20 – Taking
https://www.daera-ni.gov.uk/sites/default/ account of social value in the award of
files/publications/doe/duty-of-care-code-of- central government contracts.
practice-june2016.pdf https://www.gov.uk/government/
publications/procurement-policy-note-0620-
taking-account-of-social-value-in-the-
International Standards award-of-central-government-contracts
ISO 14001. Environmental management
systems. Requirements with guidance for Care Quality Commission (2015).
use. International Organization for Enforcement policy. Version 1.1.
Standardization. Geneva. 2015 https://www.cqc.org.uk/sites/default/
files/20150209_enforcement_policy_v1-1.pdf
ISO 9001 Quality management systems.
Requirements. International Organization Care Quality Commission (2017).
for Standardization. Geneva. 2015 Enforcement decision tree.
https://www.cqc.org.uk/sites/default/
files/20170217_enforcement_decision_tree.
Health Technical Memoranda pdf
Health Technical Memorandum 02-01. Care Quality Commission (2021). Controlled
Medical gas pipeline systems. drugs accountable officers.
https://www.england.nhs.uk/publication/ https://www.cqc.org.uk/guidance-providers/
nhs-estates-guidance-for-medical-gas- controlled-drugs/controlled-drugs-
pipeline-systems-htm-02-01/ accountable-officers
Health Technical Memorandum 01-04. Chartered Institution of Wastes
Decontamination of linen for health and Management (2014). Pre-acceptance waste
social care. audits: A guidance document for large
https://www.england.nhs.uk/publication/ healthcare waste producers in England.
decontamination-of-linen-for-health-and- CIWM. Northampton.
social-care-htm-01-04/ tinyurl.com/2p9xcyb4
Chartered Institution of Wastes

Guidance, research and other Management (2022). Guidance: Clinical and
resources Healthcare Waste.
The following guidance, research and other https://www.ciwm.co.uk/ciwm/knowledge/
resources have been cited throughout this clinical_waste_and_healthcare_waste_
document: management.aspx?hkey=95e241b6-a82d-
4a99-aae0-a0f49b65d10b
British Dental Association (2016). BDA
advice: Healthcare waste. Department for Business, Energy &
Industrial Strategy (2018). Scope of and
129
exemptions from the radioactive substances Department for Transport (2020). Employing
legislation in England, Wales and Northern a dangerous goods safety adviser.
Ireland: Guidance document. https://www.gov.uk/government/
https://www.gov.uk/government/ publications/carriage-of-dangerous-goods-
publications/guidance-on-the-scope-of-and- guidance-note-19/employing-a-dangerous-
exemptions-from-the-radioactive- goods-safety-adviser
substances-legislation-in-the-uk
Department for Transport (2022).
Department for Environment, Food & Rural Transporting dangerous goods: How to
Affairs (2018a). A Green Future: Our 25 Year transport dangerous goods, including
Plan to Improve the Environment. guidance notes, authorisation notices,
https://assets.publishing.service.gov.uk/ exception notices and multilateral
government/uploads/system/uploads/ agreements.
attachment_data/file/693158/25-year- https://www.gov.uk/government/
environment-plan.pdf collections/transporting-dangerous-goods
Department for Environment, Food & Rural Ellen MacArthur Foundation. What is a
Affairs (2018b). Our waste, our resources: a circular economy?
strategy for England. https://ellenmacarthurfoundation.org/
https://assets.publishing.service.gov.uk/ topics/circular-economy-introduction/
government/uploads/system/uploads/ overview
attachment_data/file/765914/resources-
waste-strategy-dec-2018.pdf Environment Agency (2010). Non-Waste
Framework Directive exemptions.
Department for Environment, Food & Rural https://www.asbestostraininglimited.co.uk/
Affairs (2021). Waste Prevention Programme media/filer_public/1d/de/1ddeb65b-fb96-
for England: Towards a resource efficient 4f6d-acd1-5416e0665e22/nwfd_1_non-
economy, Consultation version. waste_framework_directive_exemptions_-_
https://consult.defra.gov.uk/waste-and- temporary_storage_at_the_place_of_
recycling/waste-prevention-programme-for- production.pdf
england-2021/supporting_documents/
Waste%20Prevention%20Programme%20 Environment Agency (2011a). Clinical waste
for%20England%20%20consultation%20 (EPR 5.07): How to comply with your
document.pdf environmental permit additional guidance,
version 1.1.
Department of Health and Social Care https://assets.publishing.service.gov.uk/
(2015). Guidance: EAGA guidance on HIV government/uploads/system/uploads/
post-exposure prophylaxis. attachment_data/file/296418/geho0710bsvi-
https://www.gov.uk/government/ e-e.pdf
publications/eaga-guidance-on-hiv-post-
exposure-prophylaxis Environment Agency (2011b). Clinical waste:
additional guidance.
Department of Health & Social Care (2019). https://www.gov.uk/government/
Health Infrastructure Plan: A new, strategic publications/clinical-waste-additional-
approach to improving our hospitals and guidance
health infrastructure.
https://assets.publishing.service.gov.uk/ Environment Agency (2014a). Hazardous
government/uploads/system/uploads/ waste: segregation and mixing.
attachment_data/file/835657/health- https://www.gov.uk/guidance/hazardous-
infrastructure-plan.pdf waste-segregation-and-mixing
130
References
Environment Agency (2014b). T28 waste appropriate measures for permitted

exemption: sort and denature controlled facilities – Guidance – GOV.UK.
drugs for disposal. https://www.gov.uk/guidance/healthcare-
https://www.gov.uk/guidance/waste- waste-appropriate-measures-for-permitted-
exemption-t28-sort-and-denature- facilities/waste-storage-segregation-and-
controlled-drugs-for-disposal handling-appropriate-measures
Environment Agency (2015). Environmental Environment Agency (2022a). Environment

permitting guidance: waste incineration. Agency enforcement and sanctions policy.
https://www.gov.uk/government/ https://www.gov.uk/government/
publications/environmental-permitting- publications/environment-agency-
guidance-the-waste-incineration-directive/ enforcement-and-sanctions-policy/
environmental-permitting-guidance-waste- environment-agency-enforcement-and-
incineration sanctions-policy
Environment Agency (2018). Waste Environment Agency (2022b). Hazardous

batteries: producer responsibility. GOV.UK. waste guidance. GOV.UK.
https://www.gov.uk/guidance/waste- https://www.gov.uk/dispose-hazardous-
batteries-producer-responsibility waste
Environment Agency (2019a). Guidance: Environment Agency. Guidance: classify

Legal operator and competence different types of waste.
requirements: environmental permits. https://www.gov.uk/how-to-classify-
https://www.gov.uk/guidance/legal- different-types-of-waste
operator-and-competence-requirements-
environmental-permits#what-a-competent- European Commission (2020). A new
operator-is Circular Economy Action Plan – For a cleaner
and more competitive Europe. eur-lex.
Environment Agency (2019b). Part B europa.eu.
activities: combustion and incineration https://eur-lex.europa.eu/legal-content/EN/
permits. TXT/?qid=1583933814386&uri=COM:2020:98
https://www.gov.uk/guidance/part-b- :FIN
activities-combustion-and-incineration-
permits European Commission (2019). Neuwahl, F.,
Cusano, G., Benavides, J., Holbrook, S. and
Environment Agency (2020). Register or Roudier, S. Best Available Techniques (BAT)
renew waste exemptions (England). Reference Document for Waste Incineration
https://www.gov.uk/guidance/register-your- https://eippcb.jrc.ec.europa.eu/sites/default/
waste-exemptions-environmental-permits files/2020-01/JRC118637_WI_Bref_2019_
published_0.pdf
Environment Agency (2021a) Guidance on
the classification and assessment of waste Health and Safety Executive (2013a).
(1st Edition v1.2.GB) Waste Classification. Enforcement Management Model (EMM)
https://assets.publishing.service.gov.uk/ Operational, version 3.2
government/uploads/system/uploads/ https://www.hse.gov.uk/enforce/emm.pdf
attachment_data/file/1021051/Waste_
classification_technical_guidance_WM3.pdf Health and Safety Executive (2013b). Safe
handling of cytotoxic drugs in the
Environment Agency (2021b). Waste workplace – Health and Social Care. Hse.
storage, segregation and handling gov.uk.
appropriate measures – Healthcare waste:
131
https://www.hse.gov.uk/healthservices/ Innovate UK (2021). Guidance: SBRI: the

safe-use-cytotoxic-drugs.htm Small Business Research Initiative.
https://www.gov.uk/government/collections/
Health and Safety Executive (2015). HSE – sbri-the-small-business-research-initiative.
Enforcement policy statement.
https://www.hse.gov.uk/enforce/ Intergovernmental Organisation for
enforcepolicy.htm International Carriage by Rail (OTIF) (2021).
Regulations concerning the international
Health and Safety Executive (2018). HSG283: carriage of dangerous goods by rail (RID)
Managing infection risks when handling the 2021.
deceased: Guidance for the mortuary, post- https://otif.org/en/?page_id=1105
mortem room and funeral premises, and
during exhumation. International Maritime Organisation (2019).
https://www.hse.gov.uk/pUbns/priced/ International Maritime Dangerous Goods
hsg283.pdf (IMDG) Code.
http://www.imdg.support/imdg-code/
Health and Safety Executive (2022).
Guidance: Personal protective equipment Medicines & Healthcare Products Regulatory
(PPE) at work. Agency (2021). Managing medical devices:
https://www.hse.gov.uk/ppe/index.htm guidance for health and social care
organisations.
Health and Safety Executive (n.d.). Carriage https://www.gov.uk/government/
of Dangerous Goods Manual. publications/managing-medical-devices
https://www.hse.gov.uk/cdg/manual/index.
htm National Audit Office (2016) Good practice
contract management framework.
Health and Safety Executive HSE Books. https://webarchive.nationalarchives.gov.uk/
(2003). Safe working and the prevention of ukgwa/20170207052351/https://www.nao.
infection in clinical laboratories and similar org.uk/wp-content/uploads/2016/12/Good_
facilities practice_contract_management_
https://www.hse.gov.uk/pubns/clinical- framework.pdf
laboratories.pdf
National Audit Office (2016). Good practice
Health and Safety Executive. Guidance: contract management framework.
Blood-borne viruses (BBV). https://www.nao.org.uk/report/good-
https://www.hse.gov.uk/biosafety/blood- practice-contract-management-
borne-viruses/index.htm framework-2-2/
Health and Safety Executive. Guidance: National Services Scotland. (2015). Scottish
RIDDOR in health and social care. Health Technical Note 3: Waste
https://www.hse.gov.uk/healthservices/ Management (SHTN 3).
riddor.htm. https://www.nss.nhs.scot/publications/
waste-management-shtn-3/
Human Tissue Authority (2021). Guidance
on the sensitive handling of pregnancy NHS England (2019a). Guidance: Emergency
remains. Preparedness, Resilience and Response
https://www.hta.gov.uk/guidance- (EPRR).
professionals/regulated-sectors/post- https://www.england.nhs.uk/ourwork/eprr/
mortem/guidance-sensitive-handling-
pregnancy-remains NHS England (2019b). The NHS Long Term
Plan.
132
References
https://www.longtermplan.nhs.uk/ Richardson, J., Grose, J., Manzi, S., Mills, I.,

publication/nhs-long-term-plan/ Moles, D.R., Mukonoweshuro, R., Nasser, M.
and Nichols, A. (2016). “What’s in a bin: A
NHS England (2020a). Delivering a ‘Net case study of dental clinical waste
Zero’ National Health Service. composition and potential greenhouse gas
https://www.england.nhs.uk/greenernhs/ emission savings”. British Dental Journal,
wp-content/uploads/sites/51/2020/10/ 220(2), pp.61–66.
delivering-a-net-zero-national-health-
service.pdf. Rizan, C., Bhutta, M.F., Reed, M. and
Lillywhite, R. (2021). “The carbon footprint
NHS England (2020b). For a greener NHS, of waste streams in a UK hospital”. Journal
A Net Zero NHS. of Cleaner Production, 286, p.125446.
https://www.england.nhs.uk/greenernhs/a- http://wrap.warwick.ac.uk/146279/
net-zero-nhs/
Schulte, A., Maga, D. and Thonemann, N.
NHS England (2020). Net Zero Supplier (2021). “Combining life cycle assessment and
Roadmap. circularity assessment to analyse
https://www.england.nhs.uk/greenernhs/ environmental impacts of the medical
get-involved/suppliers/ remanufacturing of electrophysiology
catheters” Sustainability 13, No. 2: 898.
NHS England. Monitoring and enforcement. https://doi.org/10.3390/su13020898
https://www.england.nhs.uk/licensing-and-
oversight-of-independent-providers/ Scottish Environment Protection Agency
monitoring-and-enforcement/ (2021). Guidance regarding provision and
assessment of technically competent
NHS Supply Chain. (n.d.). Waste and the management at licensed waste
Circular Economy Strategic Pillar. management facilities, version 5.
https://www.supplychain.nhs.uk/ https://www.sepa.org.uk/media/154272/
sustainability/waste-and-the-circular- technically_competent_management_
economy/ licensed_waste_management_facilities.pdf.
NHS Supply Chain. Waste and the circular Scottish Environmental Protection Agency
economy. (2018). Energy from waste guidance.
https://www.supplychain.nhs.uk/ https://www.sepa.org.uk/regulations/waste/
sustainability/waste-and-the-circular- energy-from-waste/
economy/.
Scottish Environmental Protection Agency
Northern Ireland Public Health Agency (2019). Consigning Special Waste Guidance.
(n.d.). Public Health Agency Infection https://www.sepa.org.uk/media/36660/
Control Manual: Waste Management. consigning_special_waste_guidance.pdf
https://www.niinfectioncontrolmanual.net/
waste-management-0 Scottish Environmental Protection Agency
(2022). Register of Waste Carriers and
Office for Nuclear Regulation (2020) ONR Brokers.
Enforcement Policy Statement. https://www2.sepa.org.uk/wastecarriers
https://www.onr.org.uk/documents/
enforcement-policy-statement.pdf Scottish Government (2021). NHS Scotland
Climate Emergency & Sustainability Strategy
Office for Nuclear Regulation (2022). ONR 2022–2026, Consultation Draft.
– Transporting radioactive material. file:///C:/Users/GuyCarson/Downloads/
https://www.onr.org.uk/transport/ consultation-draft-nhs-scotland-climate-
133
emergency-sustainability- https://gov.wales/sites/default/files/
strategy-2022-2026.pdf publications/2021-03/beyond-recycling-
strategy-document.pdf
UK Health Security Agency and Department
of Health & Social Care (2021). The Green Welsh Assembly Government (2021). NHS
Book: Immunisation against infectious Wales Decarbonisation Strategic Delivery
disease. Plan 2021–2030.
https://www.gov.uk/government/collections/ https://gov.wales/sites/default/files/
immunisation-against-infectious-disease- publications/2021-03/nhs-wales-
the-green-book decarbonisation-strategic-delivery-plan.pdf
United Nations Economic Commission for World Health Organization (2010).

Europe (UNECE) (2020). Agreement Guidelines for medicine donations.
concerning the International Carriage of https://www.who.int/publications/i/
Dangerous Goods by Road (ADR). item/978924150198-9
https://unece.org/transportdangerous-
goods/adr-2021-files World Health Organization. (2019).
Overview of technologies for the treatment
United Nations Environment Programme of infectious and sharp waste from health
(2012). Compendium of Technologies for care facilities.
Treatment / Destruction of Healthcare https://apps.who.int/iris/
Waste | International Environmental handle/10665/328146
Technology Centre.
https://www.unep.org/ietc/resources/report/
compendium-technologies-treatment- Useful websites
destruction-healthcare-waste FutureNHS is a platform from the NHS,
helping the health and social care sector
Vehicle Certification Agency. (2021). connect and collaborate.
Dangerous Goods Packaging and Packaging https://future.nhs.uk/
Approvals Database.
https://www.vehicle-certification-agency. UK Research and Innovation is a non-
gov.uk/dangerous-goods/dangerous-goods- departmental public body sponsored by the
packaging/packaging-approvals-database/ Department for Business, Energy and
Industrial Strategy (BEIS).
Water UK (2014). National guidance for https://www.ukri.org/
healthcare waste water discharges.
https://www.water.org.uk/guidance/ Warp It: a reuse network, their mission is to
national-guidance-for-healthcare-waste- provide a place where organisations keep
water-discharges/ their equipment, assets and “stuff”
circulating to reduce spend, waste and
Welsh Assembly Government (2021). Beyond supply chain environmental impacts.
Recycling: A strategy to make the circular https://www.warp-it.co.uk/
economy in Wales a reality.
134
References
Abbreviations used in this EWC European Waste Catalogue

document FHT Frictional Heat Treatment
AD Anaerobic digestion FTE Full-Time Equivalent
BAT Best Available Techniques GHG Greenhouse gases
BBV Blood borne viruses HBN Health Building Note
BCGA British compressed gases HCW Health Care Waste
association HDPE High-density polyethylene
BCP Business Continuity Plan HP Hazardous Property
BPM Best Practicable Means HSE Health and Safety Executive
CAR Compliance Assessment Report HSENI Health and Safety Executive
CEAP Circular Economy Action Plan Northern Ireland
CIWM Chartered Institution of Wastes HTM Health Technical Memorandum
Management IBC Intermediate Bulk Container
COSHH Control of Substances Hazardous IMDG International Maritime
to Health Dangerous Goods
CoTC Certificate of technical IPC Infection Prevention and Control
competence
IVC In vessel composting
CPD Continued professional
development KPI Key Performance Indicator
DDT Dichlorodiphenyltrichloroethane LEP Local Enforcement Position
Defra Department for Environment, LoW List of Waste

Food and Rural Affairs MPE Medical Physics Expert
DfT Department for Transport MRF Materials Recovery Facility
DGSA Dangerous goods safety adviser NAO National Audit Office
DHSC Department of Health and NIEA Northern Ireland Environment
Social Care Agency
EA Environment Agency NRW Natural Resources Wales
EAGA Expert Advisory Group on Aids OEP Office of Environmental
ECP Emergency Care Practitioners Protection
EfW Energy from Waste PET Polyethylene terephthalate
EMS Environmental Management POPs Persistent Organic Pollutants

System PPE Personal protective equipment
EoW End of Waste PPN Procurement Policy Note
EPRR Emergency Preparedness and PVC Polyvinyl chloride
Resilience Response
QMS Quality Management System
ERIC Estates Return Information
Collection
135
RIDDOR Reporting of Injuries, Diseases

and Dangerous Occurrences
Regulations
RPA Radiation Protection Adviser
RPS Regulatory position statement
RWA Radioactive Waste Adviser
SDS Safety Data Sheets
SEPA Scottish Environment Protection
Agency
SHTN Scottish Health Technical Note
SOP Standard Operating Procedure
SPoC Single Point of Contact
STAATT State and Territorial Association
on Alternative Treatment
Technologies
UKRI UK Research and Innovation
VCA Vehicle Certification Agency
WEEE Waste Electrical and Electronic
Equipment
136
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Health Technical Memorandum

About Health Technical • “Must” is used when indicating

Project derogations from the While it is recognised that derogation is

This guidance is a best practice guide not Key changes:

management systems, reduce costs and • there is a drive to develop in-house

The following individuals and organisations have contributed to the development,

Chris Davies, Southport and Ormskirk Trust NHS Trust

Dan Jacobs, Technical Author, Mott MacDonald Ltd

David McCabrey, Principal Engineer, NHS Northern Ireland

David McNeill, Principal Engineer, NHS Scotland

David Wilson, Principal Engineer, NHS Northern Ireland

Fiona Daly, National Deputy Director of Estates, NHS England

Grace Peel, Technical Author, Mott MacDonald Ltd

Guy Carson, Publishing and Editorial, Archus Ltd

Helen North, Head of Frameworks and Engagement, Dangerous Goods Division,

Jock Graham, typesetting and editorial services

John Prendergast, Senior Editor, Archus Ltd

Keith White, Dangerous Goods Packaging Lead, Vehicle Certification Agency

Lenora Bond, Facilities Services Manager, NHS Property Services Ltd

Michael Rope, Head of Technical Guidance, NHS England

Nick Wilson, Technical Author, Mott MacDonald Ltd

Paul Chivers, NHS England

Paul Fernee, Team Leader – Hazardous Waste Transfer, Environment Agency

Richard Davies, Service Assurance Manager, NHS Property Services Ltd

Samantha Stanhope, Head of Sustainability, University Hospitals of Leicester NHS Trust

Sarah Griffiths, Technical Author, Mott MacDonald Ltd

Susan Grant, Principal Architect, NHS Scotland

Sushant Daga, Technical Author, Mott MacDonald Ltd

1.1 Health Technical Memorandum (HTM) • clinical waste

Who should use this individuals involved in or having specific

Typical NHS organisation role Relevant sections

1.13 Critically, this guidance is intended to Changes since the previous

importance of waste minimisation through delivery of healthcare waste services. These

1.18 In addition, a new Chapter 6 focuses • Chapter 12 “Immunisation of

• international waste shipments. 1.23 Healthcare provision is a significant

2.0 Strategic objectives

2.1 The purpose of this chapter is to

Strategic priority Summary What can be done

Strategic priority Summary What can be done

2.6 Six targets have been established to

100% of NHS trusts and foundation trusts to have a

50% reduction in the carbon

2.8 The NHS Clinical Waste Strategy

Figure 2 Clinical waste segregation targets

Improved waste segregation

Better compliance with HTM 07-01

Accurate record keeping and reliable

Offensive waste stream fully

practical, but should be in accordance with Circular economy

Figure 4 Linear economy

Figure 5 Circular economy

Minimal use Design for

Reduced Hiring &

* Based on definition by the Ellen EXEMPLAR SCHEME:

the healthcare sector. The guidance • liaising with suppliers to assess

EU Circular Economy Action Plan and Reuse Targets

All packaging 65% 70%

Plastic 50% 55%

Wood 25% 30%

Paper and cardboard 75% 85%

Figure 6 Five Rs of sustainable procurement

* Based on definition by the Ellen EXEMPLAR SCHEME:

the healthcare sector. The guidance • liaising with suppliers to assess

3.0 Principles of sustainable

2. Operate an effective return scheme

5. Make routine checks to identify need

9. Provide a suitable storage area for Recycling good practice:

The subscription topics and further • Scotland – please refer to SEPA

• Northern Ireland – refer to guidance