WASTE MANGEMENT POLICY · staff, prevent unnecessary financial cost to the organisation, and avoid prosecution and damage to its reputation. This policy gives detailed guidance on

WASTE MANAGEMENT POLICY_EF23_March 2019

WASTE MANGEMENT POLICY THIS POLICY SUPERSEDES ALL PREVIOUS POLICIES FOR WASTE MANAGEMENT

MARCH 2019

WASTE MANAGEMENT POLICY_EF23_March 2019

Policy title Waste Management Policy

Policy reference EF23 (Previously RM36)

Policy category Estates and Facilities

Relevant to All Staff

Date published March 2019

Implementation date

March 2019

Date last reviewed February 2019

Next review date April 2022

Policy lead Helen Flynn Head of Facilities Management

Contact details Email: [email protected] Telephone: 02033176773

Accountable director

David Wragg Finance Director

Approved by

(Group):

Health and Safety Committee

Approved by (Committee):

Document history Date Version Summary of amendments

October 2013 1 New Policy

March 2016 2 Minor changes

March 2019 3

Changes to take account of new TFM contract with ISS

Membership of the policy development/ review team

None

Consultation ISS, Estates and Facilities Staff, Infection Control and Prevention Team

WASTE MANAGEMENT POLICY_EF23_March 2019

Contents Page

1 Introduction 1

2 Aims and Objectives 1

3 Scope of the Policy 1

4 Duties and Responsibilities 1

4.1 Chief Executive

4.2 Nominated Director- Associate Director of Estates

4.3 Head of Facilities 4.4 Service Managers and Matrons 4.5 Local Managers 4.6 Employees 4.7 Total Facilities Management (TFM) contractors’ waste porters/caretakers 4.8 TFM nominated Waste Manager 4.9 Health and Safety Manager 4.10 Infection Control Team 4.11 Estates and Capital Project Managers 4.12 The Chief Pharmacist

4.13 Domestic Staff

5 Applicable legislation 6

6 Definitions of Waste 7

7 Principles of Waste Management 7

8 Segregation and Containment of waste 7

9 Community-Generated Waste 10

10 Collection of Waste from Other Organisations 11

11 Waste Transfer and Waste Consignment Notes 11

12 Selection of Waste Contractor 12

13 Site Registration 12

14 Discharge to Drain 12

15 Recycling and Waste Minimisation 12

WASTE MANAGEMENT POLICY_EF23_March 2019

16 Waste Management Site Plans 13

17 Risk Assessments 13

18 Personal Protective Equipment (PPE) 13

19 Staff Training 13

20 Chemical Storage 13

21 Accidents and Incidents 14

22 Waste Management Group 15

23 Waste Audits 15

24 Equality and Diversity 16

25 References 16

26 Appendix 1: Equality Impact Assessment 17

27 Appendix 2: Classification of Waste 18

28 Appendix 3: Waste Compliance and Audit Forms 21

29 Appendix 4: Colour Coding for Waste 28

30 Dissemination and Implementation Arrangements 29

31 Monitoring and Audit Arrangements 29

32 Review of Policy 29

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1. INTRODUCTION 1.1The effective management of waste is essential to any organisation if they are to avoid injury to staff, prevent unnecessary financial cost to the organisation, and avoid prosecution and damage to its reputation. This policy gives detailed guidance on the measures to take in order to manage waste successfully and specifies everyone’s responsibilities for the safe disposal of waste. Waste disposal is a huge burden on the earth’s natural resources. When sent to landfill all the materials, time, energy and money put into producing products in the first place is lost.

1.2 Disposing of waste almost always requires energy and material resources as well as often generating emissions into the environment. Consequently, industry and other significant generators of waste, such as healthcare providers, need to behave in a sustainable manner so as to safeguard the availability of resources for future generations. In this context waste needs to be considered as a potential resource wherever possible and organisations have an important role to play in making this happen, and ensuring that where waste cannot be reduced, reused or recycled it is disposed of in the most sustainable manner. This is called the waste hierarchy with the four Rs:

1. Reduce waste where possible 2. Re-use waste where possible 3. Recycle waste where possible 4. Responsible waste disposal when none of the three steps above are possible

2. AIMS AND OBJECTIVES OF THE POLICY The purpose of this policy is to describe in detail the arrangements in place throughout Camden and Islington Foundation Trust (the Trust) for the correct segregation, storage, collection and disposal of all types of waste. The Trust needs to ensure it has established and is maintaining safe and effective waste management systems and procedures based on the Health Technical Memorandum 07-01 (2013) “Safe Management of Healthcare Waste”, the Health Technical Memorandum 07-05 (2007) “The treatment, recovery, recycling and safe disposal of electrical and electronic equipment” and best practice guidelines encompassed in the EU Waste Framework Directive (2011). The Trust, through this policy, aims to inform and assist staff to apply correct and safe procedures at all times and to ensure their actions comply with current legislation. In this way, it is hoped to avoid injuries to any party coming into contact with waste generated or handled by this organisation.

3. SCOPE OF THE POLICY This policy is concerned with waste generated on any sites/buildings owned or leased by Camden and Islington Foundation Trust, and applies to any tenants of such sites, direct employees, the Total Facilities Management (TFM) Contractor and any contractor who handles waste or generates waste on our estate in the course of their activities, such as building contractors. It also encompasses clinical waste generated in service users’ homes, as a result of care activities carried out by FT staff.

4. DUTIES AND RESPONSIBILITIES 4.1. Chief Executive The Chief Executive is ultimately responsible for the implementation of this policy within the Trust; however Service Managers and local managers have been delegated the responsibility for implementing the policy, and monitoring compliance, within their area(s) of control.

4.2 Associate Director for Estates & Facilities The Associate Director for Estates & Facilities is the delegated person responsible for waste management within the Trust, and is responsible to the Chief Executive for ensuring systems have been established to ensure that waste is effectively managed.

4.3 Head of Facilities

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The Head of Facilities is responsible for ensuring that processes are in place to monitor compliance with this policy and that any non-conformance is acted upon and are responsible for updating and reviewing the Trust Waste Management Policy, and interpreting and advising the Trust on changes in legislation. 4.4 Divisional Managers Divisional Managers oversee the objectives set for their Service Managers and Matrons and encompassed in these are health and safety responsibilities, within which falls the safe handling of waste. 4.5 Service Managers/ Matrons Service Managers and Matrons have been delegated the responsibility for implementing this policy within their areas of control by ensuring that:

ward managers have received appropriate training in the safe handling and management of waste in the workplace.

where risk assessments/audits are carried out for waste management within their areas of control, recommendations are implemented

clear objectives are set for Ward/Department Managers concerning waste management and recycling as part of their responsibilities for their ward environment

all untoward incidents involving waste are reported to their line manager or supervisor and a Datix incident report form completed on line.

full correctly sealed and labelled containers and bags are not stored in the treatment room but stored elsewhere in a secure, inaccessible location pending collection by the porters or waste contractors

4.6 Employees

All staff are required to:

dispose of waste safely and only in the correct container/correctly coloured bag.

ensure that the waste hierarchy is applied to all materials before they are considered as waste i.e. re-use items wherever possible-old folders etc., rather than buying new.

attend waste management training, if requested.

keep all waste streams separate and correctly segregated.

ensure as a minimum that all waste containers e.g. sharps bins/clinical waste bags contain the name of the hospital or site, ward or department and date of disposal.

report all untoward incidents involving waste to their line manager or supervisor and complete a Datix incident report form on line.

ensure that sharps boxes are correctly assembled signed and dated including the ward or department name/site information and that they are not over-filled and are stored safely in an appropriate secure/locked area prior to collection.

Employees, whether directly employed or contracted via an agency, engaged in food handling activities have specific responsibilities relating to the disposal of food waste, to ensure it doesn’t encourage pest infestation. Specific guidance is provided in the Trust Food Safety Policy. Cleaning staff who are employed outside the TFM contract who handle waste are required to follow this policy and if they have any doubt about the handling of waste or waste streams they must raise this with their local manager, who may seek advice from the Trust nominated Waste Manager.

Staff with clinical responsibility in the community Are responsible for ensuring that:

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all waste generated by treatment they have carried out at a patient’s home is disposed of appropriately.

all movements of items deemed to be dangerous goods (clinical waste and sharps) are carried in U.N approved packaging correctly marked and labelled and carried in compliance with the regulations.

HTM 07-01 allows for small quantities of clinical waste to be transported by healthcare professionals and it should be consulted if there is any doubt. Bags of waste must not be placed directly into any vehicle, including a car. They must be placed in a rigid, secure and leak-proof outer packaging duly approved for the purpose.” (Department of Health, 2013, p. 94)

I.T. Waste

The IT department is responsible for ensuring that:

IT waste is stored in accordance with the relevant exemptions from the Environmental Permitting Regulations and Trust Information Governance requirements.

cardboard is flat packed by the department prior to being sent for recycling and polystyrene and soft plastics are separated and disposed of as domestic waste.

WEEE (Waste Electrical and Electronic Equipment) is stored in a secure area on an impermeable surface with a sealed drainage system WEEE should have a weather-proof covering (TFM responsibility).

hazardous WEEE is stored separately from non-hazardous WEEE.

all sensitive data or information contained within redundant IT equipment is destroyed prior to the storage and disposal of this waste.

Where IT WEEE is managed directly by the IT department, the above is followed but also it is important that:

waste is moved regularly and promptly.

IT WEEE is stored separately from wider Estates/Trust WEEE.

the procurement and disposal of IT equipment is in accordance with the WEEE regulations and that all redundant IT equipment is disposed of through a registered WEEE compliance scheme/approved contractor.

those who carry any waste on behalf of the Trust are licensed waste carriers under the Waste (England and Wales) Regulations 2011.

paperwork for any waste streams (WEEE, mobile phones, toner cartridges) in the form of Waste Consignment Notes (for hazardous wastes) or Transfer Notes (for non-hazardous waste) is obtained and retained for 3 and 2 years respectively. If there is any uncertainty about the disposal of I.T. equipment and consumables (date sticks etc.) the I.T. department must be contacted.

4.7 Total Facilities Management (TFM) contractor’s waste porters/caretakers Porters/caretakers will ensure that:

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waste is kept segregated on site and put in the correct external containers, which they lock afterwards.

waste is correctly handled for disposal and that the waste is only given to the approved waste contractor, as designated by the TFM Contractor, to carry that category of waste.

any necessary waste transfer notes or waste consignment notes are completed and signed and any customer copy is returned to the correct location for retention (for a minimum of two years).

they refer to Total Facilities Management (TFM) contractor’s Waste Method Statement for further information, or their line manager or the TFM nominated Waste Manager if in any doubt.

4.8 Total Facilities Management (TFM) contractor’s nominated Waste Manager The TFM contractor’s nominated Waste Manager is responsible for:

providing advice, support, induction and training to TFM staff who handle waste, specifically domestic staff, housekeepers, catering staff, porters and caretakers.

carrying out waste audits across all premises and report on the findings to the Trust.

appointing and overseeing the waste contractors.

monitoring waste contractors to ensure they comply at all times with legislation

holding waste transfer notes, for two years and ensuring they are available to the Trust and regulatory authorities on request.

4.9 Health & Safety Manager The Health and Safety Manager is responsible for providing high level health and safety advice and guidance to the organisation.

S/he will provide advice relating to health and safety around waste issues (for example the movement of waste in a manner which is safe and doesn’t have the potential to harm Trust staff).

4.10 Infection Control Team The infection control team provide advice and guidance on infection prevention and avoidance of cross-contamination from healthcare waste within the Trust.

Infection Control will undertake clinical waste audits as part of the yearly Infection Control Environmental Audit programme.

4.11 Estates and Capital Project Managers are responsible for: Contractors Employed by Trust Any person employing a contractor to work on any of Camden and Islington Foundation Trust sites must ensure that before a contractor is employed on site they are aware that they must not use any of the Trust facilities for the disposal of their waste, unless this has been explicitly agreed.

All waste is to be removed from site by the contractor which must be overseen by the Estates Department/TFM contractor’s nominated Waste Manager. Asbestos waste is dealt with under the Trust Asbestos Policy. Project Managers must be assured that contractors are competent in

providing safe and legal waste management services for all wastes produced as a result of

estates maintenance operations including WEEE, construction and demolition waste, fluorescent tubes, waste paints and solvents etc.

ensuring that all estates wastes are safely handled and disposed of and ensuring that estates wastes are securely stored prior to collection by a licensed operator

ensuring that hazardous and non-hazardous wastes are stored separately

ensuring that waste quantities and storage timescales do not exceed those allowed in the waste exemptions

ensuring no liquid wastes are discharged to the foul sewer

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obtaining and retaining consignment notes (hazardous waste) and transfer notes (non-hazardous wastes) for all waste streams that leave the Trust’s control/premises. These must be retained for 3 and 2 years respectively

ensuring that no hazardous wastes are transferred between Trust sites without accompanying consignment notes

ensuring that those who carry any waste from Trust sites are licensed waste carriers under the Waste (England and Wales) Regulations 2011 with evidence obtained

monitoring and keeping records of estate waste levels, costs and recycling rates and where maintenance works exceed £300,000 in value, ensuring Site Waste Management Plans are in place prior to the commencement of works

4.12 Chief Pharmacist The Chief Pharmacist is responsible for:

providing guidance on pharmaceutical matters relevant to waste management

identifying cytostatic and cytotoxic pharmaceuticals when dispensed (through the purple sticker system) and advising wards on appropriate disposal

facilitating the return of unused, faulty, expired or surplus pharmaceuticals to the pharmacy department

ensuring pharmacy waste is stored in accordance with the exemptions in the Environmental Permitting Regulations, in particular exemption T28 for the sorting and denaturing of controlled drugs for disposal at trust pharmacies

the receipt and dispatch of full and empty oxygen cylinders in accordance with Dangerous Goods Safety requirements

providing advice to clinical staff in the event of a spillage or incident involving pharmaceutical wastes.

4.13 Domestic Staff Domestic staff are responsible for:

emptying and cleaning domestic and recycling bins across the Trust sites

ensuring the correct bin bags are placed in the relevant bins

ensuring bin bags for recycling and domestic waste are placed in the correct external waste storage bins to ensure correct subsequent management

reporting any areas showing poor segregation practice (food waste in recycling bins, recycling waste in domestic waste bins) to their supervisor so that the area involved can be advised and training provided

5. APPLICABLE LEGISLATION 5.1. Criminal Liability - The management and disposal of waste is governed by both health &

safety and environmental legislation. Both sets of legislation assign strict duties to employers and to individuals who create or handle waste. A breach of the legislation is increasingly likely to result in a criminal prosecution of both the employer and of any identifiable individual who has committed an offence.

5.2. Health and Safety Legislation - An employer, through individual managers, is legally

responsible for providing:

the necessary resources for correct and effective waste management.

written assessments of any significant risk to health or safety associated with waste generation, management and disposal.

safe systems of work for staff generating, handling, storing or transporting waste.

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appropriate information and training for all relevant staff.

regular monitoring and periodic review of the system so that deficiencies are corrected within a reasonable timescale and the system continuously refined and improved in the light of experience.

5.3. Individual employees - are required to:

take reasonable care of themselves and others who may be affected by their acts or omissions.

co-operate in matters of health and safety associated with waste handling.

correctly use any personal protective equipment and any other work equipment designated for the task.

correctly apply the information and training, previously received.

report any perceived hazards in their working environment, or deficiencies in the safe system of work, related to waste, to their manager.

Under the Environmental Protection Act 1990 everyone concerned with waste has a 'Duty of Care' to:

only receive waste if properly authorised to do so, and only from an authorised person.

keep waste securely contained, and prevent its escape or unauthorised removal.

ensure it is adequately contained and packed for safe transport.

label the waste clearly to identify its contents and point of origin.

transfer the waste only to a licensed contractor authorised to transport that type of waste.

describe the waste (on the appropriate forms) in sufficient detail that subsequent carriers and disposers can deal with it safely.

take reasonable steps to check that those providing or removing waste are acting properly and within the law (TFM contractor).

the Trust must also ensure its TFM provider complies with a range of waste management regulations and guidance which govern the correct method of disposal of waste and the keeping of adequate written records regarding the disposal of the waste.

The Waste (England and Wales) Regulations 2011introduced the concept of the waste hierarchy into legislation. From 1 January 2015, waste collection authorities have to collect waste paper, metal, plastic and glass separately. It also imposes a duty on waste collection authorities, from that date, when making arrangements for the collection of such waste, to ensure that those arrangements are by way of separate collection. This will have an impact on this Trust in that segregation of waste at source will become legally binding.

6. DEFINITION OF WASTE “Any substance or object the holder discards, intends to discard or is required to discard" is WASTE under the Waste Framework Directive (European Directive (WFD) 2006/12/EC. Classes of Waste:

6.1. Controlled Waste – General waste comes under the category of “Controlled” waste in the

Controlled Waste Regulations 1992 SI 588 (Controlled Waste regulations) and will be listed in the European Waste Catalogue (EWC). Waste from this Trust would be classed as commercial waste under the regulations. This waste stream consists of non-hazardous wastes including paper, some packaging materials, some metals and some food waste. The waste is carried by a licensed waste carrier who will take it to a transfer station.

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6.2. Hazardous Waste – Waste is classed as hazardous if it dangerous to people, the environment

or animals. Waste is also classified as hazardous if it is covered under the Hazardous Waste Regulations 2005 SI 894 (Hazardous Waste Regs) and will be listed in the European Waste Catalogue (EWC). Typical examples of hazardous waste include things such as lead acid batteries, fluorescent tubes or clinical waste which has been designated as infectious waste. Non-infectious clinical waste can be disposed of as controlled waste. The hazardous nature of the waste will determine where its final destination will be. Some hazardous waste can go to land-fill following treatment. Others may have to be incinerated with the level of incineration being determined by the hazardous properties of the waste.

7. PRINCIPLES OF WASTE MANAGEMENT-The Waste Hierarchy Waste is segregated into the classes as specified above. Each category will then be disposed of via identified separate waste streams. The Waste (England and Wales) Regulations 2011 place a specific requirement on all organisations to utilise the waste hierarchy when dealing with waste. The following steps should always be considered in descending order: 7.1. Reduce the amount of waste produced by using less material in design and manufacture.

Keeping products for longer or using less hazardous materials. 7.2. Re-use waste items as and when appropriate, by checking, cleaning, repairing, refurbishing, whole items or spare parts. 7.3. Recycle, turning waste into a new substance or product. 7.4. Recovery which includes anaerobic digestion, incineration with energy recovery, gasification and pyrolysis which produce energy (fuels, heat and power) and materials from waste. 7.5. Disposal includes landfill and incineration without energy recovery.

8. SEGREGATION AND CONTAINMENT OF WASTE Each waste stream requires a different method of disposal. Therefore it is of paramount importance that each waste stream is segregated from the others at source, and remains separate throughout the process of containment, collection and disposal. Mixing wastes, even in small quantities is not acceptable as this will mean the waste transfer or consignment note will have the wrong information on it and will result in a range of non-compliances with legislation. This section describes each type, and each sub-category of waste and the means by which it is contained and kept separate from the rest.

8.1. Controlled Waste or municipal waste is defined in 6.1. This type of waste is disposed of in

black bags and typically is turned into RDF (Refuse Derived Fuel - Refuse Derived Fuel which mechanically sorts black bags waste and compacts it into pellets which are then shipped to the continent to be used as fuel in combined heat and power facilities, many of them in Europe where they produce electricity and hot water for communal heating systems in the local area). The parts of this waste that cannot be recycled at present are segregated from the dry mixed recycling. 8.2. Dry Mixed Recycling is municipal waste which can be recycled. This includes paper, cardboard, plastics and metal cans. This waste is taken away by the waste contractor and recycled on our behalf 8.3. Offensive waste, this describes healthcare and similar municipal waste, apart from clinical and

hazardous waste, which may cause offence to people. Examples include nappies, feminine hygiene products, used but uncontaminated PPE (has not been in contact with an infected service user),

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resin casts and incontinence waste. This type of waste is typically disposed of by being sent to a licensed land-fill site for deep land-fill.

8.4. Offensive or Infectious? - When disposing of nappies, feminine hygiene products, used but uncontaminated PPE and incontinence waste a decision has to be made by health care workers whether this waste is offensive or infectious. If it is known that the waste comes from a person who has a known infection which would affect the waste then the waste is clearly infectious. Infectious waste is classed as clinical waste and would be disposed of in an orange bag. This decision should be considered every time this type of waste is disposed of in case the results of tests indicate that the service user’s condition has changed.

8.5. Clinical Waste – is defined as:

“any waste which consists wholly or partly of human or animal tissue, blood or other body fluids, excretions, drugs or other pharmaceutical products, swabs or dressings, or syringes, needles or other sharp instruments, being waste which unless rendered safe may prove hazardous to any person coming into contact with it”; and

“any other waste arising from medical, nursing, dental, veterinary, pharmaceutical or similar practice, investigation, treatment, care, teaching or research, or the collection of blood for transfusion, being waste which may cause infection to any person coming into contact with it”.

Clinical waste is a major component of wastes from many NHS Trusts. Clinical waste bags are coloured orange which denotes that they may be sent for treatment via alternative technology rather than being incinerated. Currently the clinical waste produced by C & I is incinerated rather than going through the disinfection process described above. Therefore clinical waste is not currently sent to landfill. 8.6. Yellow clinical waste bags are for incineration only and will not be used at a hospital or clinic unless specified by Infection Control or the Consultant Microbiologist. 8.7. Clinical waste carts and wheelie bins are all coloured yellow, and clearly labelled and marked

with a bio-hazard sign. Standard 'soft' waste is placed in orange clinical waste plastic bags, whilst rigid yellow plastic boxes are used for sharps. The orange clinical bags are then closed with a plastic tie. The plastic tie comes with a tag that has a code engraved in order to identify C & I as being the producer of that waste. 8.8. Sharps - sharps boxes used within the Trust will have the following colour coded lids:- Yellow coloured lids (with appropriately labelled body of the box) are for all sharps and other

equipment used in conjunction with prescription only medicines.

Purple coloured lids (with appropriately labelled body of the box) are for cytotoxic or cytostatic drugs and equipment contaminated with these drugs. (A list of these drugs is available on the Pharmacy intranet site).

8.9. Pharmaceutical Waste - within wards and departments is divided into two separate waste streams. Those medicine containers which contain more than a dose should be returned to Pharmacy in the box provided for returns.

Medicine containers which contain less than a dose (residue) should be disposed of at ward level into a blue lidded pharmacy box which has a blue labelled body of the box.

Fluid bags and giving sets which have contained prescription only medicines (POM) must also be disposed of in the blue lidded box.

Syringes which have not been fully discharged and contain POMs should be put straight into a yellow lidded sharps box without discharging the contents of the syringe.

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Any establishment which carries out sorting or denaturing of controlled drugs will need to register the site with the Environment Agency for a T28 exemption. The only exception to this is where a Pharmacy is operating within a building which already has an exemption such as a hospital site.

8.11. Controlled Drugs – the disposal of these drugs are covered under the Management of

Medicines Policy on the Trust’s Intranet site.

8.12. Chemical Waste – is waste which is not infectious and contains chemicals or chemical residue.

Examples within a clinical environment include alcohol gel containers, aerosols and waste chemicals.

Chemical containers for disposal should be dealt with differently so contact the TFM helpdesk @ [email protected].

Alcohol hand gel containers disposed in the clinical waste stream.

Another type of container which will probably have at least one hazard symbol is an aerosol. A fully discharged aerosol can be placed in municipal waste but do not put accumulations of these containers in the same bag. Any aerosols which have contained prescription only medicines should be placed in a blue lidded pharmaceutical box.

8.13. Sealing Waste Containers - All waste bags and boxes must be sealed before disposal. When sealing bags, staff should be mindful of the weight of the contents of the bag and to ensure that enough space is left to gather the edges of the bag to seal it. Bags should never be filled more than ¾ full and should be tied with a cable tie. All clinical bags and clinical containers when full and sealed must display the name of the hospital or clinic, ward/department and the date. Sharps and pharmacy containers must be signed by the person sealing them.

8.14. Yellow Waste Containers it is essential that waste carts sited externally to

departments/services are kept locked at all times to prevent the unauthorised removal or accidental loss of any waste bags or boxes. .

8.15. Glass is classed as controlled waste but for health and safety reasons has to be collected

separately from the rest of the controlled waste. The TFM contractor provides orange “glass” solid body containers for glass disposals. Glass containers which have contained pharmaceutical products cannot be recycled and must be disposed of as pharmaceutical waste. 8.16. Batteries can be placed in the batteries tubes receptacles. Once the battery tube is full the TFM contractor should be contacted to replace the full receptacle with an empty one.

8.17. Waste Electrical and Electronic Equipment (WEEE) is A SPECIAL CATEGORY and is

collected by porters/I.T. and then sent away. Electronic and electrical equipment cannot be put in domestic waste (black bags) and any broken/old computers or media such as CD’s should be returned to the I.T. department at St Pancras for cleaning and disposal. NO COMPUTER

REGARDLESS OF AGE CAN BE THROWN OUT IN THE NORMAL WASTE STREAM. 8.18. Other Waste –any waste that is disposed of must not leave site without the appropriate waste documentation being completed. In addition the waste must only be handed to a registered waste contractor that has been approved by the TFM contractor or The Trust. 8.19. Confidential Waste – This is waste containing staff or service user details or potentially sensitive information about the Trust e.g. service user records/information, financial records etc. Currently most confidential waste is kept secure in consoles (Restore datashred consoles).The consoles are emptied to an agreed schedule and destroyed. Contact [email protected] if you need an ad hoc collection.

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9. COMMUNITY-GENERATED WASTE Waste generated away from C & I sites: Healthcare carried out in the community by Trust staff will produce waste and it is essential that this waste is disposed of correctly to ensure that we meet our duty of care

all movements of items deemed to be dangerous goods (clinical waste and sharps) are carried in U.N approved packaging correctly marked and labelled and carried in compliance with the regulations.

HTM 07-01 allows for small quantities of clinical waste to be transported by healthcare professionals and it should be consulted if there is any doubt. Bags of waste must not be placed directly into any vehicle, including a car. They must be placed in a rigid, secure and leak-proof outer packaging duly approved for the purpose.” (Department of Health, 2013, p. 94)

SHARPS USED BY CLINICAL STAFF MUST NEVER BE LEFT IN A SERVICE USER’S HOME. Non-infectious waste (offensive waste) should be disposed of in the domestic waste stream. Staff should not use orange or yellow NHS colour coded bags as this is illegal. Use a black bag for disposing of this type of waste in the domestic waste stream. Sharps must not be placed in household waste stream. Self-medicating Service users should dispose of sharps through their GP. Staff should ensure that they:

a) dispose of sharps immediately after use in a container suitable for transport, use the temporary closure mechanism immediately after use and secure the container in the vehicle to avoid tipping;

b) report any difficulty following a safe system of working. If staff cannot follow a safe system of working, this should be reported to their manager an additional support and facilities provided, for example placing sharps containers inside a robust secondary carrier or container.

10. COLLECTION OF WASTE FROM OTHER ORGANISATIONS Waste that is collected from other organisations that utilise areas and buildings on Trust owned sites is mixed in with our waste streams and disposed of from our waste disposal facility. In order that this situation does not compromise the Trusts’ legal position it is essential that the organisations comply with the C & I’s Waste Management Policy. Such organisations are responsible for ensuring their

staffs are trained and comply with the C & I Waste Policy; this includes the Royal Free, Whittington Health, LCW, Turning Point (CHIP), People Asset Management (Occupational Health provider to the Trust) etc.

11. WASTE TRANSFER AND WASTE CONSIGNMENT NOTES 11.1. Waste Transfer Note (Controlled Waste) – before any Controlled waste leaves a Trust site a waste transfer note must be produced ensuring all the required information is put onto the form. The form must be signed by an authorised Trust/TFM contractor signatory and be given to the waste carrier when they come to collect the waste. For regular collections an annual waste transfer note

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can be set up in advance of the first collection. Waste transfer notes must be retained for two years

following the disposal of the waste. No waste must leave the Trust without a waste transfer note or waste consignment note. 11.2. Waste Consignment Note (Hazardous Waste) – before any hazardous waste is removed from a Trust site a waste consignment note must be completed ensuring all relevant information is put onto the form. This form cannot be completed annually but must be completed for each load. Waste consignment notes must be retained for three years following the disposal of the waste.

No waste must leave the Trust without a waste consignment note or waste transfer note. 11.3. Producer Returns – is information that waste contractors send to the Trust advising how much waste has been taken from site over a given period (normally monthly). It is important to maintain a database of these returns for three years from the time the information is received so that waste production levels can be monitored and there is an audit trail of where the waste has been disposed of. 11.4. Waste Transfer – transferring waste between sites within the Trust is not permitted as the Trust does not have a waste transfer license. Waste should only be consigned to a licensed waste contractor from the site it was produced on. The Trust is not registered as a waste transfer station and cannot accept waste brought onto any of the sites. This prohibition includes vehicles bringing back waste or unused pharmaceuticals from other sites, accepting sharps boxes or pharmaceuticals from the public or staff bringing in waste from home.

12. SELECTION OF WASTE CONTRACTORS All persons who are subcontracted by the TFM contractor to remove waste from any Trust site must comply with the following minimum requirements be:-

registered with the Environment Agency as a waste carrier

use the correct waste transfer or waste consignment notes for the type of waste.

provide the Trust/TFM contractor with “producer returns” at agreed intervals to enable the Trust to monitor how much waste is being produced and how much is being taken away for disposal.

13. SITE REGISTRATION The Hazardous Waste Regulations 2005 require that most sites which produce hazardous waste are registered with the Environment Agency on an annual basis by the respective Estates and Facilities Department. The exceptions are those sites which produce less than 500kg per year. Each site is given a unique registration number which must be quoted on every waste consignment note.

14. DISCHARGE TO DRAIN Although not always thought of as waste the things that are put down the drains, through toilets, sluices, sinks, etc., are as much waste as what goes into a bin. Some things that are not allowed to be put down the drain are chemicals such alcohols, xylene, etc. The company which takes away the sewage from our Trust also dictates what is allowed to be put into the sewer system. This information is contained within a document referred to as the Consent to Discharge to Drain. If there is any doubt about what can or cannot be put down a toilet, sluice or drain please ask the departmental manager or the TFM contractor’s nominated waste manager/Estates and Facilities Management.

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15. RECYCLING AND WASTE MINIMISATION It is essential that the Trust seeks to minimise waste production as a means of reducing costs. Every piece of waste costs the Trust to buy it in its original form and if benefit is not derived from it then financial losses occur. Even when benefit has occurred there are still opportunities for an organisation to gain further income by separating out waste streams and sending waste for recycling rather than final disposal. The Trust already carries out recycling of many waste streams and further improvements are on-going.

16. WASTE MANAGEMENT SITE PLANS The Site Waste Management Plans Regulations 2008 requires the Trust to produce a Site Waste Management Plan (SWMP) before the construction phase begins on any construction project valued at over £300 000. The purpose of the regulations is to promote the economic use of construction materials and methods so that waste is minimised and any waste that is produced can be reused, recycled or recovered. Additionally the regulations seek to reduce fly tipping by restricting the opportunities available for the illegal disposal of waste. This is the responsibility of the Trust Estates Department (Trust owned sites) and the Capital Programme Manager.

17. RISK ASSESSMENTS - THE STATUTORY REQUIREMENTS 17.1. The Management of Health and Safety at Work Regulations 1999 require that all 'significant'

risks are assessed and the risks, together with details of the persons at risk, and the control measures required to manage those risks, are recorded in writing, and amended as necessary in response to changes or new information. 17.2. The Control of Substances Hazardous to Health Regulations 2002 requires the same, in

relation to chemical risks and infection risks and this includes the risks posed by waste materials. Both also require the training of staff and provision of information in relation to those risks. 17.3. The Use of Generic Risk Assessments should be adopted where ever required but the generic

assessments should be reviewed to ensure that any ward/department specific risks are covered by the Risk Assessment.

18. PERSONAL PROTECTIVE EQUIPMENT Clinical staff will follow normal control of infection guidelines during the generation and disposal of clinical waste on the ward or department, which will include protective clothing suitable for the infection risk involved and hand washing

19. STAFF TRAINING REQUIREMENTS 19.1. Ward/Departmental Inductions for New Staff - it is essential that waste disposal procedures are included as early as possible, in the ward or department based induction process for new staff

and new staff are given access to this policy. 19.2. Clinical Staff - training sessions in the safe and correct disposal of waste and an introduction to environmental issues are included in the Trust induction training programme 19.3. The TFM contractor’s Portering/Domestic/Caretaking/Maintenance Staff – these staff

have a very important role to play in collecting, transporting, storage of waste. They will require specific training to enable them to ensure correct segregation of waste during collection, storage at the point of disposal along with ensuring the paperwork is correct when the waste is handed over to the waste contractor.

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20. CHEMICAL STORAGE 20.1. All chemicals, regardless of the hazards they pose need to be stored and handled in a manner which minimises the risk of spillage. Chemicals should not be stored with other chemicals which they will react with e.g. acids should not be stored with alkalis and oxidising agents should not be stored with flammable chemicals. 20.2. Information on the hazards associated with chemicals can be found on the material safety data sheet which is available free from the manufacturer or supplier. All stored liquids should be stored inside a bund (an outer wall or container designed to retain the contents of an inner tank in the event of leakage or spillage) which is capable of holding 110% of the liquid stored. Spillage procedures should be established for stored chemicals/substances and this should form part of the COSHH assessment. As part of the assessment, sufficient absorbing and clean up materials should be available to cope with any spillages.

21. ACCIDENTS AND INCIDENTS 21.1. General - whilst every effort should be made to avoid loss or spillage of any kind, it is

important that a clear procedure and a ready supply of the necessary equipment is in place and is used whenever such an event occurs. Information and training for staff must be provided prior to such an eventuality.

21.2. Spillage Procedures - The aim of any spillage procedure is to: Contain the spillage to limit the escape.

Protect staff, service users and visitors.

Protect the environment.

Restore the area to normal as quickly as possible.

Minimise the effect of the spillage on normal service provision. 21.3. Clinical Waste - The main risk is that of cross infection, and the procedure consists of donning protective clothing consistent with the risk, in most cases disposable gloves and apron if appropriate, and placing the waste items into the appropriate orange bag, or into a sharps box, in the case of needles, blades or other sharp items, taking special care not to receive a sharps injury. Sharps must not be retrieved by hand. Please see Infection Control policy on the Trust Intranet site for detailed guidance. 21.4. Spilt blood or body fluids - Please see Infection Control policy on the Trust Intranet site. 21.5. Other Chemicals - Similar principles apply to any other chemical spillage. The essential steps

are:

find out how to deal with the individual chemical first; this information should be on the COSHH assessment or the manufacturers‟ material safety data sheet.

only tackle the spillage if it is safe to do so and you have the necessary equipment to hand.

contain the spillage to prevent further spread. prevent exposure of other persons in the vicinity. absorb and dispose as quickly as possible. decontaminate the area and return it to normal use.

21.6. Before disposing of spillages or absorbent materials the COSHH assessment should be consulted for the correct method of collection and disposal.

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21.7. Suitable contingency procedures to deal with foreseeable spillages of harmful chemicals should be devised by the users, and included with the COSHH assessment of health risks associated with that chemical or process. 21.8. If in doubt, contact Estates and Facilities on 0203 317 6707. 21.9. Any injury which arises out of waste production, handling or disposal must be reported to the relevant manager or supervisor in the normal way. If there has been a sharps injury from an item contaminated with blood or body fluid the Sharps Injury Policy which is available on the Intranet site should be followed, in full. 21.10. Any other untoward incident, whether it causes injury or not, should be reported via Datix so that its implications can be considered and if appropriate, further preventive measures taken. 21.11. Any injury or untoward incident which arises out of waste production, handling or disposal must be recorded on the Trust accident/incident form Datix via the Intranet in the normal way and submitted via that person's manager or supervisor.

22. WASTE AUDIT ARRANGEMENTS An audit tool (see Appendix 3) based on Safe Management of Healthcare Waste best practice has been established for waste audits to enable a true picture to be established as to how each ward and department is managing waste. These audits will be carried out by Estates & Facilities members of the Trust/TFM contractor’s nominated waste manager in line with the frequencies recommended in the HTM 07-01 Safe Management of Healthcare Waste and local staff will be invited to participate. 22.1. The waste audits are carried out randomly and without prior notification to establish a true picture of how well waste is being managed. 22.2. Each ward and department will be audited at least once annually but follow up visits could be planned depending on the findings of the original waste audit. Included in the schedule will be waste collection services and record keeping. 22.3. Following the audit visit a report will be compiled outlining the areas of non-compliance and the remedial action required. The report will be sent to the ward/department manager along with the Service Manager for that area for information and action. Key themes from the audits will be collated for consideration at the trust Infection Control Committee. 22.4. Periodically the carriers of our waste will request an audit of waste to be carried out on site so that we can satisfy them that what we are stipulating on our waste documentation is in fact what we put into our waste bags. This will require liaison with other Trusts who share our sites, e.g. The Royal Free etc and whose waste we collect, to ensure that they can give us assurance about the contents of their waste containers. 22.5. The Environment Agency views health care waste as a high risk because if it is poorly managed it could have serious consequences for the health of people or for the environment. The Environment Agency carries out waste audits within NHS Trusts and can recommend that changes be made to the manner in which waste is managed and if necessary take enforcement action.

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24. REFERENCES The following documents where used as sources of information when compiling this policy:- Environmental Protection Act 1990

Controlled Waste Regulations 1992

Hazardous waste Regulation 2005

Waste (England & Wales) Regulation 2011

Consolidate European Waste Catalogue

Safe Management of Healthcare Waste HTM 07-01 2013

25. EQUALITY & DIVERSITY In accordance with our equality duties an Equality impact Assessment has been carried out on this policy. There is no evidence to suggest that the policy would have an adverse impact in relation to race, disability, gender, age, sexual orientation, religion and belief or infringe individual’s human rights.

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Appendix 1 Equality Impact Assessment Tool

Yes/No Comments

1. Does the policy/guidance affect one group less or more favourably than another on the basis of:

Race No

Ethnic origins (including gypsies and travellers)

No

Nationality No

Gender No

Culture No

Religion or belief No

Sexual orientation including lesbian, gay and bisexual people

No

Age No

Disability - learning disabilities, physical disability, sensory impairment and mental health problems

No

2. Is there any evidence that some groups are affected differently?

No

3. If you have identified potential discrimination, are any exceptions valid, legal and/or justifiable?

NA

4. Is the impact of the policy/guidance likely to be negative?

No

5. If so can the impact be avoided? N/A

6. What alternatives are there to achieving the policy/guidance without the impact?

N/A

7. Can we reduce the impact by taking different action?

N/A

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Appendix 2 Classifications of Waste WASTE

TYPE

DISPOSAL ROUTE

CONTAINER

COMMENTS

Asbestos All Only to be disposed of by a licensed contractor

Sealed container/bags

Hazardous waste

Batteries All Hoist batteries will be disposed of via the TFM contractor

Hazardous waste

Builders waste Except asbestos or other hazardous materials

then taken off-site by contractor/skip

Skip Hazardous waste

Cardboard All Boxes to be folded flat and then collected and disposed of for recycling.

None Recycling

Chemical Waste from clinics, wards and departments

Alcohol gel containers, aerosols not containing POMs

Single aerosol which has not contained medicines can be disposed of in black bag.

Black or clear bag

Recycling

Clinical waste All except group 3, category A (Appendix 4)

Collected and put into yellow waste carts in the waste compound

Orange bags Hazardous waste for alternative treatment

Confidential waste

All Put into specific confidential waste bags and arrange collection

Specifically marked confidential waste bins

Paper recycled

Controlled drugs

All Chemical destruction and then disposed of with pharmaceutical waste

Blue lidded bins with appropriately labelled body

Hazardous waste for incineration only

Cooking oil From Catering Waste oils are collected and stored in catering until collected by a licensed contractor

Original containers

Recycling

Defective medical equipment

Electrical equipment

Must be decontaminated and then handed to waste porters for transport to the waste compound. For equipment which cannot be decontaminated see below

None Taken by licensed contractor for recycling

Domestic waste ( also known as municipal waste)

All Food waste, dead flowers or anything else biodegradable. Carts taken to waste compound – see also dry mixed recycling

Black bags Controlled waste for landfill

Dry mixed recycling

All recyclables Plastics, paper, cardboard and metal cans

Clear bars Recycling

Electrical and Electronic equipment

All including spare parts (see below)

Given to TFM waste porters and then transported to waste compound. On sites that do

None Taken by WEE licensed contractor for recycling

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not have TFM provision contact the local council for advice

Fluorescent light tubes, sodium lights

All lamps Collected by TFM contractor’s staff and stored until collected by contractor

Purpose made collection unit.

Recycling and disposal

Food waste From Catering Food waste goes through a macerator and then to drain. Where there is no macerator food waste must be double-bagged in a black bag

None Discharged to drain

Furniture Furniture from Trust premises

Furniture to be given to waste porters –and then transported to the waste compound at St Pancras

None Controlled waste for landfill/recycling

Furniture and electrical equipment from Trust owned houses

All If the item is owned by the tenant then they should be encourage to dispose of it themselves via the local authority. Where ownership cannot be established or the item has been left following the end of a tenancy then return to the Trust for disposal

None Controlled waste for landfill or hazardous waste for recycling

Furniture containing electrical components

Beds, chairs, etc

Furniture to be given to TFM waste porters and then transported to the waste compound

None Taken by licensed contractor for recycling

Glass containers which have contained POMs

Only residues remaining in the container

Put into blue lidded pharmaceutical boxes until the fill level is reached and then sealed and given to waste porters. For larger containers dispose of with Pharmaceutical waste

Blue lidded pharmaceutical box with appropriately labelled body

Hazardous waste for incineration only

Glass containers which have more than residues of POMs

Anything more than a residue

Return to Pharmacy Pharmacy box Hazardous waste for incineration only

Glass and crockery

All except POMs

Place into orange boxes and Leave for TFM waste porters

Dedicated orange box

Recycling by SITA

Inkjet and toner cartridges

All Collected on some sites and taken away by licensed contractor

No special requirements

Recycling

Mattresses which are

All Highgate and SPH -Inform waste porters that mattress

No special packaging

Controlled waste

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uncontaminated is to be collected – other sties request mattress supplier to collect

Mattresses contaminated with blood or bodily fluids

All Decontaminate and inform waste porters that a contaminated mattress is to collect – see above

Hazardous waste

Offensive waste - Nappies, incontinence pads, sanitary waste, plaster casts used but uncontaminated PPE

All which is classed as offensive and not infectious.

Yellow bag with black stripe Yellow bag with black stripe. Where offensive waste stream does not exist use a black bag – black bags can only be used in a home setting;

Deep landfill

Paints and empty paint tins

Empty or containing small residues

Place in building waste skip Skip Controlled waste for landfill

Paint Tins Containing more than residues

Chemical waste, give to waste porters

Original containers

Hazardous waste for incineration

Sharps not containing prescription only medicine (POM)

Sharps used during blood testing or other diagnostics not involving the use of POM

Put into sharps bin specifically for this purpose

Yellow lidded sharps bin with appropriately labelled body

Hazardous waste for alternative treatment

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Appendix 3

Waste Management and Compliance Audit Form

Waste Compound Auditor

Date Areas Excluded None

Audit Check List Yes No N/A Comments

1 Waste collection staff have attended training?

2 Waste is collected and transported by dedicated staff?

3 Porters are transferring waste in line with Trust policy and procedures around the site and is the correct PPE being worn?

4 Clinical waste is collected and transported separately?

5 Storage compound is totally enclosed and secure?

6 Storage compound is kept locked when not in use?

7 Waste compound access is restricted to authorised staff only, to prevent unauthorised and unsupervised access to clinical and other waste streams?

8 Storage compound is provided with separate storage for sharps receptacles and waste medicines?

9 Clinical waste bins are locked to prevent unauthorised access?

10 Waste carts are clean?

11 Cytotoxic/Cytostatic waste, anatomical and pharmaceutical waste is consigned separately from other waste streams?

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12 Storage of all Chemicals/Acids/Alkaline etc. is in line with current H&S/COSHH legislation?

13 Storage area for Chemicals/Acids/Alkaline etc. provides the required segregation and is it clearly marked with the appropriate hazard warning signage?

14 Storage compound is provided with clearly labelled areas for waste requiring different treatment/disposal options?

15 Storage compound is clearly marked with warning signs?

16 The waste area is clean with no waste outside bins?

17 Storage compound is sited away from food preparation and general storage areas, and from routes taken by the public?

18 Storage compound is well-lit and ventilated?

29 Storage compound is appropriately drained?

20 Storage compound is secure from entry by animals and free from insect and rodent infestation?

21 Storage compound is provided with wash down facilities?

22 Storage compound is provided with washing facilities for employees?

23 Are waste transfer notes available for all consignments of waste which leave the site?

24 Do waste transfer notes contain enough information to describe and consign the waste correctly?

25 Are waste transfer notes retained for two years?

26 Are items designated under WEE kept separate from other waste streams collected by a waste contractor?

27 Are all waste contractors that take waste from the site registered as waste carriers with the EA?

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WASTE AUDIT REPORT - SIGNIFICANT FINDINGS AND ACTION PLAN

Ward/Department: Auditor:

Date: Areas Excluded:

Good Practice

Theme Issue Action Required Person Responsible Signed on Completion Date of Completion

Waste Segregation

Waste Containers

Storage

Handling

Regulation

_________________________________________________________________________________________________________________________

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WASTE MANAGEMENT AND COMPLIANCE AUDIT PROFORMA

Ward/Dept Auditor

Date Areas Excluded

Ward/Department Audit Check List Yes No N/A Comments

1 The Trusts current edition Clinical Waste posters are displayed in all relevant areas?

2 All waste bins are enclosed where necessary (i.e. solid bins not sack holders)?

3 All the waste bins in the area are foot operated where necessary, lidded and in good working order?

4 All waste bins are clearly visibly clean?

5 Waste bags are tied onto containers/trolleys?

6 Rolls of clean bags are not stored at the bottom of waste bins?

7 All bag colours are in use are appropriate for the location and type of waste in them?

8 There is a clinical - offensive waste stream (Tiger Stripe Bags) and it is being used correctly?

9 There is a clinical - infectious waste stream (Orange Bags) and it is being used correctly?

10 There is a Domestic waste stream (Black Bags) and it is being used correctly?

___________________________________________________________________________________________________________________________________

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11 Waste sacks for disposal are no more than 2/3 full: correctly tied and labelled with the correct information (Hospital, Ward/Dept and Date)?

12 Suction waste is disposed of in a manner which prevents spillage e.g. into a rigid leak proof container or waste solidified with a gelling agent?

13 The sharps bins in use comply with national standards (UN 3291, BS 7320)?

14 All sharps bins have been assembled correctly and signed on assembly?

15 The correct coloured lids and labels are on all sharps boxes?

16 Sharps bins are stored safely out if the reach of children on a flat work surface at waist height or in a bracket (Not on the floor)?

17 All sharps bins are labelled and signed according to the Trusts Waste Policy?

18 Suitable sharps boxes are in use for the sharps waste products?

19 Contents of sharps boxes are compliant (if safe viewing is possible)?

20 Needles and syringes are discarded into a sharps bin as one unit?

21 Sharps bins have not been filled above the fill line?

22 The temporary closure mechanism is used when sharps bins are not in use?

23 Sealed and locked sharps bins are stored in a locked room, cupboard or container, away from public access?

24 All sharps boxes are collected by the waste porters separately from other waste?

25 All pharmaceutical glass containing more than residues is sent back to Pharmacy?

26 All pharmaceutical glass containing residues is disposed of in sharps boxes or blue lidded boxes?

___________________________________________________________________________________________________________________________________

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27 No waste bags are stored on corridors or other areas in full view of service users and visitors?

38 All clinical waste bins in public places are locked to prevent access?

29 Internal storage areas are inaccessible to the public and locked?

30 There is a glass and crockery waste stream and it is being used correctly?

31 Broken glass and crockery is being correctly packaged and disposed of?

32 There is a chemical waste stream and it is being used correctly?

33 The storage of substances and chemicals is in line with legislation?

34 Any other issues regarding handling of waste?

Additional Comments:

I confirm that I have been briefed on the contents of this Waste Audit Report undertaken by the Trust "Waste Compliance Officer". I understand my

responsibility in implementing the recommendations made in the WASTE AUDIT REPORT - SIGNIFICANT FINDINGS AND ACTION PLAN, and will

continue to monitor and maintain the recommendations made in order to provide a safe environment. I have communicated all findings and known

risks to relevant staff & other relevant users of the Ward/Department.

___________________________________________________________________________________________________________________________________

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Person to action the recommendations of this Waste Audit Report:

Name: …………………………………… Position: …………………………………… Date: ……………….. Signature: …………………………………...

Waste Compliance and Audit Assessor:

Name: …………………………………… Position: Waste Compliance Officer Date: ……………….. Signature: ………………………………….....

Review to be Undertaken by Ward/Department Manager: Date: ……………….. Signature: …………………………………....

Review to be Undertaken by Waste Compliance Officer: Date: ………………… Signature: ……………………………………..

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Appendix 4 Colour Coding for Waste

Colour Description

Yellow

Waste which requires disposal by incineration Indicative treatment/disposal required is incineration in a suitably permitted or licensed facility.

Orange

Waste which may be “treated” Indicative treatment/disposal required is to be “rendered safe” in a suitably permitted or licensed facility, usually alternative treatment plants (ATPs). However this waste may also be disposed of by incineration.

Purple

Cytotoxic and cytostatic waste Indicative treatment/disposal required is incineration in a suitably permitted or licensed facility.

Yellow/black

Offensive/hygiene waste* Indicative treatment/disposal required is landfill or municipal incineration/energy from waste at a suitably permitted or licensed facility.

Black

Domestic (municipal) waste Minimum treatment/disposal required is landfill, municipal incineration/energy from waste or other municipal waste treatment process at a suitably permitted or licensed facility. Recyclable components should be removed through segregation. Clear/opaque receptacles may also be used for domestic waste.

Blue

Medicinal/pharmacy waste for incineration1 Indicative treatment/disposal required is incineration in a suitably permitted facility.

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28. Dissemination and Implementation Arrangements This policy will be available to staff on the Trust Intranet. 29. Monitoring and Audit Arrangements Compliance to the guidance in this policy will be undertaken by the Trust Waste Group, the Infection Control Team and the TFM service provider.

30. Review of Policy The policy will be reviewed every 3 years or whenever there is a new piece of legislation or good practice which could be adopted.