Clinical waste advisor Rebecca Waters explains how practice staff should be safely and legally disposing of waste
In 2013, it was reported that the cost to dispose of clinical waste for the National Health Service (NHS) is five to 10 times more than domestic waste. Even though the amount of recycled waste is increasing, with an 18% growth in the NHS between 2007/8 and 2011/12, the cost of clinical waste disposal for the government is still predicted to rise.2 Every clinical setting, including private aesthetic clinics, must have a waste segregation and disposal policy to ensure they are helping to tackle this growth. The principal of ‘waste minimisation’ is key, although not always practical and achievable, and so strategies to recycle and then segregate appropriately need to be put in place. This is where the ‘waste hierarchy’ comes into fruition to help guide all healthcare professionals, including those working within the cosmetic setting, in their responsibilities.
Why is correct waste disposal so important?
Effective waste disposal procedures help to protect both staff and patients from harm. Hazardous waste in particular can contain a variety of pathogens that have the potential to infect anyone they come into contact with, including those that cause HIV and hepatitis B and C. Sharps injuries among professionals can also be avoided by careful handling and disposal of needles. What’s more, safe segregation of waste streams ensures that all waste is disposed of in the safest and most efficient way, protecting the environment from pollution. It is also important to note that clinic owners could be faced with legal ramifications if they do not comply with regulation. Failure to comply with the regulations is a criminal offence subject to an unlimited fine on conviction. In addition to potentially damaging the environment and/or putting people’s health at risk, an incompliant aesthetic clinic could also be suspended or closed and faced with substantial remedial costs before it is able to reopen.3
The waste hierarchy
The UK currently follows the principles of waste management set out by the European Waste Framework Directive, which ensures that all countries within the European Union (EU) are aligned in their strategies and implementation.4 With the UK leaving the EU, it is yet unclear how this will affect businesses’ need to comply with the regulations. However, it is likely that at least the majority of the guidelines will remain in place in order to ensure the safety and efficiency of waste processes. The current waste hierarchy ranks the different waste management choices in order of their environmental impact. The overarching aim is to eliminate the generation of waste in the first instance. When this cannot be practically achieved, the framework below provides the next best order of options available, always keeping the environment in mind.
Prevention: eliminating or reducing waste at the source e.g. minimising the amount of packaging used.
Preparing for reuse: when waste cannot be prevented, where possible it should be directly reused, renewed or treated for reuse.
Recycling or reprocessing: materials that can be reclaimed as a secondary raw material e.g. cardboard.
Other recovery: where none of the above is feasible, the energy content of the waste should be used e.g. offensive waste can be transported to energy-from-waste amenities.
Disposal: this is the last option and stringent segregation mandates should be followed for health and safety reasons and environmental impact.
Assessment, segregation and storage
Any waste created must be assessed by the producer of that waste and segregated according to policy. Any member of staff can take responsibility for this, as long as they are appropriately trained. A lot of the waste produced can be easily categorised, however, sometimes it is not so clear-cut and clinical judgment or the use of documentary evidence may be required. Some staff may err on the side of caution and segregate all waste from cosmetic procedures as infectious, but with proper training and by following the clearly defined framework, they can build confidence in their decisions. This can significantly help to reduce unnecessary processing procedures, which are costly – both financially and environmentally. Figure 1 provides examples of waste items that might be generated in aesthetic clinics, along with their allocated colour-codes, as set out by the Department of Health’s (DoH) best practice waste management guidelines:5
The actual waste container used for each waste stream should also be considered. All sharps must be disposed of in rigid sharps containers that can be securely closed when full. All other waste must be segregated according to its state – rigid containers are needed for all liquid or glass waste and bags are only suitable for hard waste.
The colour-coding system detailed in Figure 1 is universal across the UK and Europe, providing a quick visual indicator to help make the segregation process as convenient and as easy as possible. This element should be integral in staff training and many suppliers provide helpful educational posters that can be positioned around the clinic and near waste containers and bins for reference when required.
Policy, audits and staff training
The DoH’s Health Technical Memorandum (HTM) 07-01: safe management of healthcare waste states that healthcare providers should have access to a waste management policy within their working environment. It provides a list of the minimum requirements that the policy should contain, including the aims and rationale of the policy, legal and statutory obligations, up-to-date waste management contracts, the person responsible for waste procedures and what their duties are, information on safe transportation and specification for the correct use of containers and bags.5
Waste audits are necessary to ensure that the policy is being followed and should be carried out at least every five years5 in aesthetic clinics by a nominated person, who is responsible for waste management and trained in the audit procedure. Alternatively, an experienced waste audit contractor or consultant could conduct the audit.7 The administrative side of waste management is a legal requirement and pivotal in audit checks.8 A staff training protocol is an important part of the policy documentation and it should clearly specify what education is provided for new starters in their induction plan. HTM 07-01 suggests the key areas to focus on are the risks associated with healthcare waste; its segregation, handling, storage and collection; personal hygiene; procedures for spillages and emergencies; and use of protective clothing. Relevant training in the form of written information, photos and verbal instruction will prove effective refreshers for all existing members of staff. While there are no strict guidelines for frequency of training, annual training is recommended by professionals in the field.
All professionals working within a clinic that offers any kind of cosmetic procedure need to understand and comply with his or her responsibility in waste management to ensure staff, patients, and the environment, are protected from harm. Working with an experienced and professional waste management company can support healthcare worker’s responsibility with confidence and peace of mind.
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