{{org_field_logo}}
{{org_field_name}}
Registration Number: {{org_field_registration_no}}
Recycling Policy
1. Purpose
This policy sets out {{org_field_name}}’s arrangements for the safe, lawful and environmentally responsible prevention, segregation, storage, collection, transfer, recycling and disposal of waste arising from the care home.
{{org_field_name}} will manage waste in accordance with its statutory duty of care and the applicable waste hierarchy and will ensure that waste is correctly classified, segregated and transferred only to appropriately authorised persons.
The care home will comply with the requirements for the separate collection of recyclable waste applicable in England, including the separation of dry recyclable materials, food waste and residual waste in accordance with the arrangements made with the care home’s waste collector.
Healthcare waste, including clinical, infectious, offensive, pharmaceutical, cytotoxic or cytostatic waste and sharps, will be assessed and segregated according to its actual classification and risk. Healthcare waste will not be placed automatically into a single clinical-waste stream solely because it arises in a care setting.
Waste-management arrangements will support compliance with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including the requirements relating to safe care and treatment, infection prevention and control, cleanliness, safe premises and equipment, and effective governance.
2. Scope
This policy applies to all employees, volunteers, contractors, and visitors at {{org_field_name}}. It covers the management of recyclable waste, hazardous waste disposal, and best practices for waste reduction within the care home.
3. Legal and Regulatory Framework
{{org_field_name}} will have regard to and comply with all waste-management legislation and regulatory requirements applicable to the service, including:
- Health and Social Care Act 2008.
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including:
- Regulation 12 – Safe care and treatment, including the prevention and control of infection;
- Regulation 15 – Premises and equipment, including requirements for appropriate standards of cleanliness and hygiene and the safe management of domestic, clinical and hazardous waste; and
- Regulation 17 – Good governance, including systems for assessing, monitoring and mitigating risks to health, safety and welfare.
- Health and Social Care Act 2008: Code of Practice on the prevention and control of infections and related guidance, where applicable to the service.
- Environmental Protection Act 1990, including:
- section 34 – the statutory duty of care for controlled waste; and
- the applicable requirements concerning the separate collection and presentation of recyclable waste from relevant non-domestic, commercial and industrial premises.
- Environment Act 2021, particularly the provisions concerning the separate collection of recyclable waste in England.
- The Separation of Waste (England) Regulations 2024.
- The Separation of Waste (England) Regulations 2025.
- The Waste (England and Wales) Regulations 2011, including the requirement to apply the waste hierarchy and applicable requirements for waste transfer information and records.
- The Controlled Waste (England and Wales) Regulations 2012.
- The Hazardous Waste (England and Wales) Regulations 2005, where hazardous waste is produced or held.
- Health Technical Memorandum 07-01: Safe and sustainable management of healthcare waste, as the current national technical guidance for healthcare waste classification, segregation, storage, packaging, transport, treatment and disposal.
- Current Environment Agency, Department for Environment, Food and Rural Affairs, NHS England and Care Quality Commission requirements and guidance applicable to waste management in adult social care.
Where legislation or statutory requirements are amended, the current legal requirement will take precedence over any outdated wording in this policy.
4. Principles of Waste Management and Recycling
{{org_field_name}} will manage waste in accordance with the following principles:
- Apply the waste hierarchy: Waste-management decisions must prioritise, in order:
- prevention;
- preparation for reuse;
- recycling;
- other recovery, including energy recovery where appropriate; and
- disposal as the last option.
- Correct segregation at source: Waste must be placed in the correct waste stream as close as reasonably practicable to the point at which it is produced.
- Separate recyclable waste: Where the statutory workplace recycling requirements apply, dry recyclable materials, food waste and residual waste must be presented separately in accordance with the arrangements made with the authorised waste collector.
- Prevent contamination: Recyclable materials must not be unnecessarily contaminated with food, liquids, clinical waste, hazardous substances or residual waste.
- Correct healthcare-waste classification: Healthcare waste must be classified according to its contents, infectious risk, pharmaceutical or chemical contamination and other hazardous properties before disposal.
- Safe storage: Waste must be contained, labelled where required and stored securely so that it cannot escape, leak, spill, cause injury, attract pests, create offensive odours or be accessed inappropriately.
- Authorised transfer: Waste must only be transferred to a person or organisation legally authorised to transport, receive or manage that category of waste.
- Traceability: Required waste-transfer documentation, hazardous-waste documentation and other records must be completed accurately and retained for the statutory period.
- Infection prevention and control: Waste-handling practices must minimise the risk of infection, contamination, sharps injury and exposure to hazardous substances.
5. Waste Segregation and Recycling Categories
Waste must be assessed and placed into the appropriate waste stream. Staff must follow the colour coding and container requirements specified by the care home’s authorised waste contractor and current healthcare-waste guidance.
Residual Waste
Residual waste is non-recyclable waste that is not clinical, infectious, hazardous, offensive, pharmaceutical, cytotoxic or cytostatic waste and does not require another specialist disposal route.
Residual waste must:
- be kept separate from recyclable waste and food waste;
- be placed in the designated residual-waste receptacle; and
- be transferred in accordance with the arrangements agreed with the authorised waste collector.
Dry Recyclable Materials
The care home must separate applicable dry recyclable materials from residual waste for recycling.
Dry recyclable materials include the applicable recyclable forms of:
- paper;
- card;
- glass;
- metal; and
- plastic.
Only items that meet the applicable recycling specification should enter the recycling stream. Items that are heavily contaminated, contain hazardous residues or are otherwise excluded by legislation or the waste collector must be placed in the appropriate alternative waste stream.
Paper and card must be managed in accordance with the collection arrangements provided by the waste collector. Where the collector co-collects paper and card with other dry recyclables, the collector must be responsible for satisfying any applicable statutory assessment requirements permitting that arrangement.
Food Waste
Food waste must be kept separate from residual waste and dry recyclable materials where the statutory workplace recycling requirements apply.
Food waste includes food preparation waste and uneaten food that falls within the applicable food-waste collection specification.
Food waste must be:
- placed in the designated food-waste container;
- protected from contamination with packaging, clinical waste or other unsuitable material;
- stored so as to minimise pests, leakage and odour; and
- collected through an appropriate waste collection arrangement.
Healthcare Waste
Healthcare waste must not be classified solely according to where it was generated. Staff must consider what the waste contains and whether it is infectious, offensive, medicinally contaminated or otherwise hazardous.
Healthcare waste must be segregated in accordance with current HTM 07-01 requirements and the care home’s waste contractor arrangements.
The following principles apply:
- Infectious clinical waste: Waste known or suspected to contain viable infectious agents, or otherwise classified as infectious clinical waste, must be placed in the appropriate UN-approved infectious-clinical-waste packaging, normally associated with the orange waste stream where required by current guidance.
- Offensive hygiene waste: Non-infectious healthcare waste containing body fluids, secretions or excretions, which is not classified as infectious or otherwise hazardous, must be placed in the designated offensive-waste stream, normally using yellow-and-black striped packaging where required by current guidance. This may include non-infectious incontinence products and other non-infectious hygiene waste where correctly assessed.
- Medicinal or pharmaceutical-contaminated waste: Healthcare waste contaminated with medicines or pharmaceuticals must be segregated into the appropriate pharmaceutical-contaminated waste stream and must not automatically be placed with ordinary infectious waste.
- Cytotoxic or cytostatic waste: Waste contaminated with cytotoxic or cytostatic medicines must be segregated into the designated cytotoxic/cytostatic waste stream, using the required purple identification or container system.
- Unused or waste medicines: Medicines must be disposed of through the appropriate pharmaceutical waste route and must not be placed in general waste, food waste or ordinary recycling.
- Sharps: Needles, lancets and other sharps must be disposed of immediately into the correct UN-approved sharps container appropriate to the contents and contamination. Sharps containers must not be overfilled and must be closed and disposed of in accordance with the manufacturer’s fill line and current waste requirements.
- Anatomical waste: Where generated, anatomical waste must be placed in the appropriate designated container and managed through the specialist waste route required by current guidance.
- PPE: Used PPE must be classified according to contamination and infection risk. PPE must not automatically be treated as yellow-bag clinical waste. Uncontaminated PPE may follow the appropriate residual-waste route, whereas PPE contaminated with infectious material, medicines, chemicals or other hazardous substances must enter the relevant specialist waste stream.
Staff must seek advice from the Registered Manager, infection prevention and control lead or authorised waste contractor if there is uncertainty about classification.
Batteries
Waste batteries must:
- be collected separately from general waste;
- be stored safely to minimise short-circuit, leakage and fire risks; and
- be transferred through an authorised battery recycling or waste-management route.
Waste Electrical and Electronic Equipment
Waste electrical and electronic equipment must be kept separate from general waste and transferred through an authorised WEEE collection, reuse or recycling route.
Equipment containing confidential information must have data securely removed or destroyed before disposal, where applicable.
Lamps and Light Bulbs
Waste lamps and light bulbs must be assessed according to type and managed through the appropriate authorised waste route. Lamps containing hazardous substances must not be disposed of with ordinary residual waste.
Confidential Waste
Paper and other material containing personal, confidential or sensitive information must be:
- placed in a secure confidential-waste receptacle or securely shredded using an approved process;
- protected against unauthorised access before destruction; and
- disposed of through an authorised confidential-waste provider where an external service is used.
Waste-management arrangements must also comply with the organisation’s data-protection and confidentiality procedures.
6. Staff Responsibilities
All Staff
All staff who produce, handle or dispose of waste must:
- follow this policy and local waste-segregation procedures;
- place waste in the correct designated receptacle;
- keep dry recyclable materials, food waste and residual waste separated where required;
- segregate healthcare waste according to its classification and actual contents;
- never place sharps directly into waste bags;
- never deliberately mix clinical, hazardous, pharmaceutical or offensive waste with ordinary recycling or food waste;
- close waste bags and containers safely and in accordance with the relevant procedure;
- report damaged, leaking, overflowing, incorrectly labelled or incorrectly segregated waste containers promptly;
- report waste spills, sharps incidents and other waste-related safety incidents in accordance with the home’s incident-reporting procedures; and
- seek advice where they are unsure how waste should be classified or disposed of.
Housekeeping and Maintenance Staff
Housekeeping and maintenance staff must:
- collect and transport internal waste safely;
- preserve segregation between waste streams during internal collection;
- ensure waste bags and containers are appropriately closed before removal from the point of use;
- ensure external storage areas remain clean, secure and appropriately organised;
- report evidence of pests, leakage, damaged containers, overfilled waste receptacles or incorrect segregation; and
- follow any additional legal requirements relating to batteries, electrical equipment, lamps, chemicals or other hazardous materials handled as part of their duties.
Registered Manager or Delegated Responsible Person
The Registered Manager or delegated competent person must:
- maintain suitable arrangements for the lawful management of all waste generated by the service;
- ensure the care home complies with applicable workplace recycling requirements;
- ensure appropriate waste streams and receptacles are available;
- ensure healthcare waste is classified and segregated in accordance with current legal and technical requirements;
- ensure waste contractors are appropriately authorised for the waste they collect;
- ensure required waste-transfer and hazardous-waste records are obtained, checked and retained;
- ensure staff receive information, instruction and training appropriate to their waste-handling responsibilities;
- monitor waste segregation and storage arrangements;
- investigate identified non-compliance and take corrective action;
- ensure relevant risk assessments are maintained; and
- review waste arrangements when legislation, CQC requirements, national guidance, waste classifications or contractor arrangements change.
7. Waste Collection and Disposal Procedures
Internal Collection
Waste must be removed from care and communal areas at a frequency sufficient to prevent:
- overfilling;
- leakage;
- offensive odours;
- avoidable infection risks;
- attraction of pests;
- obstruction of escape routes; or
- other risks to people using the service, staff or visitors.
Waste segregation must be maintained throughout internal collection and transport.
Healthcare waste must be disposed of as close as reasonably practicable to its point of generation and placed directly into the correct designated waste receptacle.
Waste Containers
Waste containers must:
- be suitable for the waste placed in them;
- be in good condition;
- be clearly identifiable or labelled where required;
- not be filled beyond the manufacturer’s or contractor’s stated limit;
- be closed securely before transfer where required; and
- be replaced promptly where damaged or contaminated.
Healthcare waste bags must be securely closed in accordance with current healthcare-waste requirements and must not be overfilled.
External Waste Storage
Waste awaiting collection must be stored in a designated area that is appropriate to the nature and volume of waste produced.
The storage area must, where relevant:
- be secure against unauthorised access;
- prevent waste from escaping;
- protect waste from animals and pests;
- minimise the risk of leakage, spillage and contamination;
- allow different waste streams to remain segregated;
- permit safe access for staff and authorised waste contractors; and
- be maintained in a clean and orderly condition.
Clinical, hazardous, pharmaceutical and other specialist healthcare waste must remain segregated from general recycling, food waste and residual waste.
External Collection
Waste must only be transferred to an appropriately authorised person or organisation.
Before appointing or continuing to use a waste contractor, {{org_field_name}} must take reasonable steps to confirm that the contractor holds the appropriate Environment Agency registration, permit or other authorisation for the waste being transferred.
Where separate collection requirements apply, the home must present waste to the waste collector in accordance with the agreed collection arrangements.
Dry recyclable waste, food waste and residual waste must not knowingly be mixed in circumstances prohibited by the applicable legislation.
7.1 Waste Documentation and Duty of Care Records
{{org_field_name}} has a statutory duty of care in relation to controlled waste generated or held by the service.
The Registered Manager or delegated responsible person must ensure that:
- waste is described accurately when transferred;
- waste is transferred only to an appropriately authorised person;
- appropriate Waste Transfer Notes or equivalent lawful waste-transfer records are obtained or completed for non-hazardous controlled waste;
- Waste Transfer Notes and associated transfer information are retained for at least two years from the relevant transfer, unless a longer period is required by another applicable legal or contractual requirement;
- hazardous waste movements are accompanied by the documentation required by the Hazardous Waste (England and Wales) Regulations 2005;
- hazardous-waste consignment records required to be retained by the waste producer or holder are kept for at least three years;
- the applicable waste description and waste code are used;
- records identify the waste contractor and relevant authorisation details;
- records are available for inspection by the Environment Agency, local authority, CQC or another authorised body where legally required; and
- any discrepancies between the waste produced and the waste documentation are investigated.
The care home must retain evidence that reasonable checks have been made regarding the authorisation of organisations to which its waste is transferred.
Where electronic waste-transfer or tracking requirements become legally applicable to the care home, {{org_field_name}} will implement the required electronic system by the applicable statutory commencement date.
8. Reducing Waste and Promoting Sustainability
- Paperless Administration: Encourage electronic records and communication where possible.
- Eco-Friendly Procurement:
- Prioritise suppliers offering biodegradable or recyclable materials.
- Reduce reliance on single-use plastics.
- Water and Energy Conservation:
- Implement measures to reduce unnecessary water and electricity usage.
- Encourage energy-saving practices among staff and visitors.
9. Training and Awareness
- Mandatory Staff Training:
- All staff must receive waste management and recycling training during induction.
- Annual refresher training to reinforce best practices.
- Signage and Information:
- Clear signage should be placed near bins to help staff and visitors dispose of waste correctly.
- Posters should highlight what materials can and cannot be recycled.
10. Compliance and Monitoring
The Registered Manager will maintain oversight of compliance with this policy and applicable waste-management requirements.
Monitoring must include, where relevant:
- correct separation of dry recyclable materials, food waste and residual waste;
- correct segregation of infectious, offensive, pharmaceutical, cytotoxic/cytostatic, sharps and other healthcare waste;
- prevention of inappropriate mixing or contamination of waste streams;
- availability and suitability of waste receptacles;
- cleanliness and security of waste-storage areas;
- prevention of overfilled or leaking waste containers;
- correct labelling and closure of healthcare-waste containers;
- current authorisation of waste carriers and contractors;
- availability and accuracy of Waste Transfer Notes;
- availability and accuracy of hazardous-waste consignment documentation;
- compliance with statutory record-retention periods; and
- completion of corrective actions following any waste-management incident or audit finding.
Any non-compliance that could place people at risk, lead to unlawful disposal, cause environmental harm or breach waste-separation requirements must be addressed without avoidable delay.
Significant or recurring failures must be:
- recorded;
- risk assessed;
- investigated;
- escalated to the Registered Manager or provider as appropriate; and
- followed by a documented corrective action.
Waste-related incidents, including sharps injuries, spills, leakage, incorrect segregation or suspected unlawful waste disposal, must also be managed under the organisation’s incident-reporting, infection-prevention and health-and-safety procedures.
Where there is reason to believe that a waste contractor is no longer appropriately authorised or is disposing of waste unlawfully, further transfer of waste to that contractor must cease where necessary to prevent an unlawful transfer, and appropriate advice or notification must be sought from the Environment Agency.
11. Related Policies
- CH12-Safe Care and Treatment Policy
- CH15-Premises and Equipment Policy
- CH17-Infection Prevention and Control Policy
- CH18-Risk Management and Assessment Policy
- CH34-Confidentiality and Data Protection (GDPR) Policy
12. Policy Review
- This policy will be reviewed annually or sooner if changes in waste management legislation, local authority guidance, or CQC regulations occur.
- Amendments will be made to ensure ongoing compliance and sustainability improvements.
Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.