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Waste policy

Contents

  1. Introduction
  2. Scope
  3. Purpose
  4. Responsibilities, accountabilities and duties
  5. Procedure implementation
  6. Training implications
  7. Monitoring arrangements
  8. Equality impact assessment screening
  9. Links to any other associated documents
  10. References

1 Introduction

Waste in any form has the potential to cause harm to both people and the environment, and all organisations have a responsibility for ensuring that any waste arising from their activities is handled and disposed of in a responsible manner as defined by the Environmental Protection Act 1990 (section 34) and the Environmental Protection (Duty of Care) Regulations 1991, as amended 2003.

The trust has a duty under the hazardous waste regulations to ensure that hazardous waste is managed appropriately. Section 34(1) of the Environmental Protection Act 1990 imposes a duty of care on any person or organisation who:

  • “imports, produces, carries, keeps, treats or disposes of controlled waste or, as a dealer or broker, has control of such waste”
  • “ensure waste generated by, or on, their premises, is handled and disposed of in accordance with current legislation, and are wholly responsible for such wastes from the point of generation to final disposal”

The duty requires such persons to ensure that there is no unauthorised or harmful deposit, treatment or disposal of the waste, to prevent the escape of the waste from their control or that of any other person, and on the transfer of the waste to ensure that the transfer is only to an authorised person or to a person for authorised transport purposes and that a written description of the waste is also transferred’.

The main legislation which is applicable to waste arising from healthcare organisations is set out below.

All legislation referred to in this policy is correct at the time of writing, the UK exit from the EU may lead to changes in legislation, these will be communicated through the channels outlined in section 6 of this policy. In addition to the above, and in order to fully comply with The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment (Amendment) (EU Exit) Regulations 2020 (opens in new window) requires the trust to appoint a dangerous goods safety advisor (DGSA). Contact details of the DGSA are kept on file by the environmental and waste manager and the laundry and logistics service manager.

The trust recognises and accepts that it must take all reasonable steps to dispose of waste legally in premises operated by the trust. The trust recognises the financial benefits of good waste management practice, which may avoid the potential from prosecution and lead to reduced costs. Therefore the trust will implement a strategy to follow the hierarchy of waste of favour below:

  1. prevention
  2. minimisation
  3. re-use
  4. recycling
  5. energy recovery
  6. landfill

The management of waste is one of the key elements of a strategy for sustainability. All persons working for or on behalf of the trust have a duty to minimise and segregate waste to ensure that it is treated appropriately and lawfully.

2 Scope

This policy shall apply to the management of all waste generated throughout the trust. It shall apply to all trust staff, contractors, volunteers and others who must comply with the policy and any supporting procedures. However, the trust has many differing arrangements in relation to the properties that are occupied by its service users and staff. The accountability for the management of waste may be devolved to the organisation with the overall control of the building. These other host organisations may have their own policies on waste management. Managers of trust services in these buildings should follow any local policies and procedures in addition to those outlined in this policy.

3 Purpose

The purpose of this policy is to ensure that the trust’s activities in relation to waste comply with the law and reduce the impact on the environment whilst balancing these against the economic costs of doing so.

Some of the waste products generated from a healthcare environment can be hazardous to health and correct procedures for handling and disposal need to be followed. To this end the trust will implement standard operating procedures (SOP’s) for the segregation and handling of healthcare waste in line with NHS guidance. This policy is written to provide a clear definition of responsibilities in relation to waste management, the allocation and use of resources and the segregation, recycling and disposal of waste materials. It is not intended to provide instructions on waste handling; these will be covered in locally produced SOP’s.

In accordance with waste guidance, all waste is categorised based on its properties and potential hazard. The means of storage, transport and final disposal will reflect the potential hazard.

All waste will be stored in appropriate designated, secure areas.

Handling procedures will be identified at a local level to minimise manual handling incidents.

Waste producers must ensure that all waste is disposed of correctly in accordance with this policy.

Healthcare waste will be securely stored in approved lockable containers in secure designated waste storage areas outside wards and departments and shall not be mixed with other waste. (It is an offence under the Hazardous Waste Regulations 2005 (as amended 2016) to dispose of non-clinical waste in the clinical waste stream.)

Sharps must only be disposed of in the correct sharps boxes as identified in Health Technical Memorandum (HTM) 07(01): Safe Management of Healthcare Waste.

Healthcare or clinical waste will be segregated to ensure its correct and final disposal, using the national colour coded scheme as defined in Health Technical Memorandum 07 (01).

All healthcare related waste and containers shall be labelled to show the hospital and ward, department or premise producing the waste.

All healthcare related waste will be coded on waste transfer notes (WTN) or consignment notes according to the European waste catalogue (EWC) and the list of wastes and copies retained for the minimum required period of 3 years for consignment notes and 2 years for waste transfer notes.

Waste considered to be of a confidential nature will be handled, stored and sent for final disposal in accordance with the Data Protection Act (2018) (opens in new window) such that confidential information is not disclosed to unauthorised persons and does not enter the public domain. All confidential waste paper must be either shredded to current standards on site or passed to a secure and specialist contractor for shredding.

4 Responsibilities, accountabilities and duties

4.1 Chief executive

The chief executive has overall responsibility for waste management and whilst the responsibility for managing waste is delegated to other officers in the trust, the accountability remains with the chief executive. Where the trust has overall control of a building, the accountability for the management of waste is given to directors, deputy care group directors and some managers.

4.2 Directors, care group directors, deputy care group directors and some managers

Directors, care group directors, deputy care group directors and some managers have a key responsibility for ensuring that there is a proactive approach to the effective management of waste in areas of their control. Their duties include and are not limited to:

  • ensuring that suitable and sufficient arrangements are in place for the management of waste
  • ensure that procedures are in place to operationally manage all aspects of waste management including the minimisation, segregation, handling, storage and disposal of all wastes
  • staff under their control are given suitable information, instruction and training with regard to waste management
  • ensure that all staff under their control are aware of and implement any procedures required for the safe and legal handling and disposal of waste
  • procedures are monitored regularly for effectiveness

4.3 Head of estates and facilities

The head of estates and facilities has the delegated responsibility for the management of waste in the areas within control of the estates and facilities teams.

Duties of the head of estates and facilities includes but is not limited to setting a policy for waste management in accordance with statutory regulations, NHS guidance and best practice.

For areas within the control of estates and facilities includes those duties set out for heads of service in section 4.2: Some of these responsibilities and duties are delegated to nominated officers within the estates and facilities teams. Further responsibilities are delegated to the environmental and waste manager.

4.4 Environmental and waste manager

The environmental and waste manager takes a lead role in ensuring that the trust remains compliant with the law in relation to waste management. Duties include and are not limited to:

  • ensuring that all relevant legislation is identified and communicated to managers and staff as appropriate and in a timely manner to ensure the trust remains compliant with legislation at all times
  • providing advice and guidance on all matters related to the environment and sustainability and to ensure the trust adopts a proactive approach to environmental and waste management
  • auditing of the trusts waste management arrangements

4.5 Infection prevention and control (IPC) and safety team

As part of their audit processes, the IPC and safety teams have a responsibility to report on any poor waste management practices which are identified during the audit process.

4.6 All trust staff

The responsibility for the minimisation and segregation of waste rests with all staff who handle waste. They have a duty under the environmental protection duty of care regulations, to ensure that waste is minimised and segregated ‘as far as is reasonably practicable’ and that any operational procedures are accurately followed in accordance with any guidance which has been provided.

Trust staff who are required to carry out waste minimisation, segregation, handling, storage and disposal must understand their responsibility and perform their work in a safe prescribed manner with due regard for safety and legislative issues as stated in this policy, along with any procedural and other related documents.

Where appropriate, training will be given to individuals who have a specific responsibility for segregation of wastes to enable them to carry out their duties safely and within the law.

5 Procedure or implementation

The trust has many differing arrangements in relation to the properties that are occupied by its service users and staff. The accountability for the management of waste may be the responsibility of the organisation with overall control of the building. However the trust policy on waste management should be applied to all situations as long as it does not conflict with any locally designated policy or procedure. Guidance for trust staff on waste issues is set out in this policy and the references contained therein. Advice from the trusts environmental and waste manager, the trusts safety team or the head of estates and facilities should be sought for any waste related matters.

6 Training implications

Where appropriate, either by legislative requirement or as identified in a risk assessment, information, instruction and training on any associated procedures or equipment will be provided by the trust or external agencies for all trust staff involved in the minimisation, segregation, handling, and movement of waste. This should take place at local induction to a service and when changes to policy or procedure dictate. All trust staff should be made aware at local induction of the key points within this policy along with any local procedures that may accompany this policy. Awareness campaigns will be communicated through the trusts’ intranet site, trust publications, departmental team brief, organised training days and strategically placed posters and information leaflets.

7 Monitoring arrangements

It is the intention of the trust to ensure effective implementation and regular review of this policy in all aspects of resource management and decision-making.

The estates and facilities team will continually monitor progress of waste procedures and systems. This will be done by a number of methods including, but not exclusively:

  • networking with other NHS trusts and organisations
  • communication with the environment agency and use of associated websites
  • regularly reading monthly publications
  • subscription to advisory bodies

Where working practices change, or legislation dictates changes this will be communicated to all relevant staff in a timely manner using the methods specified in sections 5 and 6 of this policy.

7.1 Areas for monitoring

7.1.1 Waste management procedures comply with policy

  • How: Physical checks.
  • Who: Manager or supervisors.
  • Reported to: Head of estates and facilities.
  • Frequency: Minimum of annually.

7.1.2 Appointment of competent contractors

  • How: Review of contract agreements.
  • Who: Environmental and waste manager.
  • Reported to: Health and safety forum.
  • Frequency: Annually.

7.1.3 Cradle to the grave waste audit

  • How: Physical check.
  • Who: Environmental and waste manager.
  • Reported to: Health and safety forum.
  • Frequency: Annually.

7.1.4 Waste management procedures comply with policy

  • How: Regular physical check.
  • Who: Environmental and waste manager, IPC team and Safety team.
  • Reported to: Health and safety forum.
  • Frequency: Ongoing.

7.2 Inspections and audits

Waste from production to final disposal will be monitored by the trust’s environmental and waste manager, identifying the source of any problem that arises in order that appropriate actions can be implemented to correct any non-compliance with this policy or the trust’s statutory duties.

The estates and facilities monitoring team will check on waste segregation at local level and report any problems to the environmental and waste manager. Additionally, the IPC and health and safety teams include checks on waste management on their annual inspections. Where persistent problems are identified the environmental and waste manager will follow up and advise as necessary to ensure trust compliance with procedures and legislation.

The trust is required to apply for certain exemptions and permits to operate the waste compound at St. Catherine’s and as such the environment agency will perform regular audits to ensure the trust is compliant with the terms of these requirements.

7.3 Performance indicators

The environmental and waste manager will monitor figures for waste at a minimum of an annual basis, will review key performance indicators such as the NHS ERIC data on an annual basis and will collate data and prepare a report on waste for the trusts annual report.

8 Equality impact assessment screening

To access the equality impact assessment for this policy, please email rdash.equalityanddiversity@nhs.net to request the document.

8.1 Privacy, dignity and respect

The NHS Constitution states that all patients should feel that their privacy and dignity are respected while they are in hospital. High Quality Care for All (2008), Lord Darzi’s review of the NHS, identifies the need to organise care around the individual, ‘not just clinically but in terms of dignity and respect’.

As a consequence the trust is required to articulate its intent to deliver care with privacy and dignity that treats all service users with respect. Therefore, all procedural documents will be considered, if relevant, to reflect the requirement to treat everyone with privacy, dignity and respect, (when appropriate this should also include how same sex accommodation is provided).

8.2 Mental Capacity Act (2005)

Central to any aspect of care delivered to adults and young people aged 16 years or over will be the consideration of the individuals’ capacity to participate in the decision-making process. Consequently, no intervention should be carried out without either the individual’s informed consent, or the powers included in a legal framework, or by order of the court.

Therefore, the trust is required to make sure that all staff working with individuals who use our service are familiar with the provisions within the Mental Capacity Act (2005). For this reason all procedural documents will be considered, if relevant to reflect the provisions of the Mental Capacity Act (2005) to ensure that the rights of individual are protected and they are supported to make their own decisions where possible and that any decisions made on their behalf when they lack capacity are made in their best interests and least restrictive of their rights and freedoms.

This policy has links with the following policies:

10 References

Document control

  • Version: 7.1
  • Unique reference number: 190.
  • Ratified by: Corporate policies approval group
  • Date ratified: 28 December 2023.
  • Name of originator or author: Environmental and waste manager.
  • Name of responsible individual: Estates and financial sub committee.
  • Date issued: 5 January 2024.
  • Review date: June 2024.
  • Target audience: All staff.

Page last reviewed: December 16, 2024
Next review due: December 16, 2025

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