CHW22-Handling and Disposal of Hazardous Substances Policy

Registration Number: {{org_field_registration_no}}

Handling and Disposal of Hazardous Substances Policy

1. Purpose

The purpose of this policy is to ensure that all hazardous substances used, stored, and disposed of within {{org_field_name}} are managed safely and in compliance with the Control of Substances Hazardous to Health (COSHH) Regulations 2002, the Health and Safety at Work Act 1974, and the Regulation and Inspection of Social Care (Wales) Act 2016. This policy sets out procedures for staff to follow to prevent harm to residents, employees, visitors, and the environment while ensuring compliance with Care Inspectorate Wales (CIW) requirements.

2. Scope

This policy applies to:

All staff members, including care staff, housekeeping, maintenance teams, and administrative personnel.
Contractors and suppliers delivering or handling hazardous substances within the care home.
Residents and visitors, ensuring their safety around hazardous substances.
The Registered Manager and Health and Safety Lead, who oversee compliance with hazardous substance regulations.

3. Compliance with CIW Regulations and Legal Framework

Our hazardous substance and hazardous waste management aligns with, and is monitored against, the following legislation and regulatory expectations (as applicable to Wales):

Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999 (risk assessment, safe systems of work).
Control of Substances Hazardous to Health (COSHH) Regulations 2002 (assessment, prevention/control of exposure, information, instruction and training).
Environmental Protection Act 1990 (Section 34 – Duty of Care) and the Waste (England and Wales) Regulations 2011 (duty of care, waste transfer documentation for non-hazardous waste).
The Hazardous Waste (Wales) Regulations 2005 (as amended) (classification of hazardous waste, consignment notes, record keeping, and regulatory controls in Wales).
Natural Resources Wales (NRW) regulatory requirements, including (where applicable) hazardous waste producer registration and completion of hazardous waste consignment notes.
Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations (where transport of dangerous goods is arranged/undertaken).
Regulation and Inspection of Social Care (Wales) Act 2016 and Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, including requirements on providers to have policies that are up to date and operated effectively.
CIW statutory guidance (“Guidance for care home and domiciliary suppliers 2024”), including expectations under Regulation 56 (hygiene/infection control) and Regulation 57 (health and safety) that waste disposal arrangements are safe and compliant.

4. Identifying and Assessing Hazardous Substances

{{org_field_name}} maintains a comprehensive inventory of all hazardous substances used within the care home, including:

Cleaning chemicals (e.g., disinfectants, bleach, sanitizers).
Medical waste (e.g., used sharps, expired medication, bodily fluids).
Personal care products (e.g., aerosols, creams, alcohol-based products).
Maintenance chemicals (e.g., paints, oils, solvents).

A COSHH risk assessment is carried out for each hazardous substance, identifying:

The risks associated with use.
Appropriate handling and storage measures.
The necessary Personal Protective Equipment (PPE).
Correct disposal procedures.

5. Safe Handling and Use of Hazardous Substances

To minimise risks when handling hazardous substances:

Only trained staff are permitted to use hazardous substances.
Staff must read and follow Safety Data Sheets (SDS) for each substance before use.
Appropriate PPE, such as gloves, masks, and aprons, must be worn where required.
Decanting is avoided wherever reasonably practicable. Where decanting is operationally necessary (for example, preparing a diluted cleaning solution), it must only be undertaken by staff who have been trained and deemed competent. Decanting must only be carried out into a clean, compatible container that is correctly labelled with: the product name, relevant hazards/pictograms (where applicable), dilution/strength, date prepared, and the preparer’s initials. Decanting into food or drink containers is strictly prohibited.
Residents and visitors must not have access to hazardous substances unless it is part of their prescribed care plan.

6. Storage of Hazardous Substances

To ensure safe storage:

All hazardous substances must be locked away in designated storage areas.
Storage areas are clearly labelled, ventilated, and kept at appropriate temperatures.
Substances must be kept in original packaging with manufacturer labels intact.
Incompatible substances are stored separately to prevent dangerous reactions.
Weekly inventory checks ensure proper stock levels and detect any issues.

Storage arrangements must also ensure:

Segregation by compatibility (for example, acids kept separate from hypochlorite/bleach; oxidisers stored separately from flammables).
Secondary containment/spill trays are used for liquid chemicals where leakage could cause harm.
Flammables are stored away from ignition sources and, where quantities warrant, stored in an appropriate fire-resistant cabinet.
Hazardous substances are never stored in food preparation areas, resident bedrooms, bathrooms, or in accessible circulation areas (e.g., corridors).
Safety Data Sheets (SDS) are readily accessible to staff at all times (paper COSHH file and/or controlled electronic access), and storage locations are included on the COSHH inventory.

7. Disposal of Hazardous Substances and Waste

We segregate, store, remove and dispose of waste in a manner that protects people and the environment and maintains a clear audit trail from production to final disposal.

7.1 Segregation and containers

Waste is segregated at the point of production into the correct stream (e.g., domestic, offensive/hygiene, clinical/infectious, sharps, medicines, chemical).
Sharps are disposed of immediately into approved sharps containers. Containers are assembled correctly, labelled (location/date), not overfilled, and stored securely pending collection.
Where the service produces pharmaceutical waste (including potentially cytotoxic/cytostatic medicines), it is segregated and handled in accordance with the waste contractor’s acceptance criteria and current healthcare waste guidance.

7.2 Use of authorised contractors

Only registered waste carriers are used and waste is sent only to authorised/permitted facilities. Contractor licences and permits are verified on appointment and at least annually.

7.3 Documentation (Duty of Care audit trail)

For non-hazardous waste, a Waste Transfer Note is obtained and retained in line with duty of care requirements.
For hazardous waste (including hazardous clinical waste where applicable), a Hazardous Waste Consignment Note is completed and retained in accordance with the Hazardous Waste (Wales) Regulations and NRW guidance.

7.4 Medicines disposal

Unused/expired medicines are returned to the supplying pharmacy/approved route in line with our medication procedures. Medicines disposal is undertaken in accordance with the home’s Medication Policy and Procedure, including ordering, recording, handling, disposal and auditing arrangements.

7.5 Record retention

Waste Transfer Notes are retained for a minimum of 2 years.
Hazardous Waste Consignment Notes are retained for a minimum of 3 years.

7.6 Hazardous waste producer registration (where applicable in Wales)

Where the service produces or stores hazardous waste above applicable NRW requirements, we ensure the premises is registered/renewed as required.

8. Records, Monitoring and Evidence of Compliance

The Registered Manager (or delegate) ensures records are complete, accurate and available for inspection. Records include:

COSHH inventory and COSHH risk assessments for each hazardous substance;
Safety Data Sheets (SDS) for all hazardous substances (current versions);
Training and competency records for staff handling hazardous substances and waste;
Cleaning/chemical storage checks and audit findings;
Incident/near miss records related to hazardous substances (including sharps injuries and chemical exposures);
Waste contractor documentation: waste carrier registration checks, permits (where applicable), Waste Transfer Notes and Hazardous Waste Consignment Notes (retained for the required periods).

Audit activity is scheduled and recorded (minimum quarterly for storage/stock controls and at least annually for contractor compliance and documentation checks). Action plans are documented and tracked to completion.

9. Emergency Procedures for Hazardous Substance Incidents

In case of accidental exposure, spillage, or contamination:

The affected area must be evacuated immediately.
The Health and Safety Lead must be notified, and spill containment measures initiated.
Emergency PPE must be used, and cleaning procedures followed per SDS instructions.
Medical assistance must be sought if exposure occurs.
The incident must be recorded and investigated, and corrective measures taken to prevent recurrence.

Where a spill, leak or release could enter drains, watercourses, or cause environmental harm, staff must take immediate steps to prevent discharge where safe to do so (e.g., isolate the source and block access to drains using available spill equipment) and escalate immediately to the Registered Manager. If external notification is required, the Registered Manager will contact the relevant body (for example, emergency services and/or Natural Resources Wales as appropriate).

Where an incident results in serious injury, hospitalisation, or any other reportable criteria, the Registered Manager will ensure appropriate statutory reporting is completed (including RIDDOR where applicable) and that CIW notifications are made where the event meets CIW notification requirements.

10. Training and Staff Responsibilities

All staff receive COSHH training upon induction and annual refresher courses.
Managers ensure compliance through regular audits and risk assessments.
Staff must report concerns related to hazardous substance management immediately.
Training logs are maintained to ensure all employees are up to date with procedures.

11. Continuous Monitoring and Improvement

To ensure ongoing compliance and best practice:

Quarterly audits of hazardous substances are conducted by the Health and Safety Lead.
Annual policy reviews are undertaken to align with regulatory updates.
Feedback from staff and residents is encouraged to improve safety measures.
Incident trend analysis helps identify areas for improvement in handling and disposal procedures.

12. Related Policies

This policy should be read alongside:

CHW16 – Health and Safety at Work Policy
CHW17 – Infection Prevention and Control Policy
CHW18 – Risk Management and Assessment Policy
CHW22 – Handling and Disposal of Hazardous Substances Policy
CHW24 – Management of Accidents, Incidents, and Near Misses Policy

13. Policy Review

This policy will be reviewed annually or sooner if changes in legislation, CIW regulations, or operational needs occur. The Registered Manager and Health and Safety Lead will oversee the review process to ensure compliance.

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}}
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