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The Handling and Disposal of Clinical and Offensive/Hygiene Waste in Care Homes (England) Policy

Background

The aim of a safe disposal system of clinical waste is to ensure that all potentially infectious healthcare waste materials are removed from their point of origin at regular intervals and transported securely to an appropriate point of disposal by incineration. The Environmental Protection Act 1990 makes it the responsibility of the employer to ensure the safe disposal of clinical waste from their premises. Failure to abide by the act can lead to prosecution.

Regulation

{{org_field_name}} understands that, with regard to the disposal of clinical waste and infection control, the following regulations under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 apply.

• Regulation 12: Safe Care and Treatment, includes a requirement for service providers to assess the risk of, and prevent, detect and control the spread of, infections.
• Regulation 15: Premises and Equipment, includes a requirement for premises and equipment to be “clean” and for providers to maintain standards of hygiene appropriate for the purposes for which they are being used.
• Regulation 18: Staffing, includes a requirement for staff employed in the provision of a regulated activity to receive appropriate support and training as necessary to ensure safe practice.

The service understands that having effective infection control policies and procedures in place is an important element in the “five key question test” that is used during CQC inspections to determine a quality rating for the service.

Legislation

The service must adhere to the following health and safety legislation.

• The Health and Safety at Work, etc Act 1974.
• The Reporting of Incidents, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR), which places a duty on the service to report outbreaks of certain diseases as well as accidents such as needle-stick accidents.
• The Control of Substances Hazardous to Health Regulations 2002 (COSHH), which places a duty on the service to ensure that potentially infectious materials are identified as hazards and dealt with accordingly.
• The Public Health Infectious Diseases Regulations 1988 place a duty on employers to adopt safe practices to prevent the spread of infection (especially blood-borne infection).
• The Controlled Waste Regulations (England and Wales) 2012 define “clinical waste” and state that it is classed as a controlled waste and subject to the Environmental Protection Act 1990 which makes it the responsibility of the employer to ensure its safe disposal.
• The Hazardous Waste Regulations 2005 makes it the responsibility of the clinical waste producer to ensure that services contracted to collect clinical waste are properly licensed with the Environment Agency.

The home understands that the Health and Safety (Sharp Instruments in Healthcare) Regulations 2013 (the Sharps Regulations) apply directly to healthcare providers and to providers such as nursing homes. However, the regulations and associated guidance should be considered as best practice in sharps management and may be used to inform policies and procedures in other adult social care settings where relevant.

Guidance

{{org_field_name}} will comply fully with relevant statutory and non-statutory best practice guidance, including:

• Infection Prevention and Control (IPC): Resource for Adult Social Care (March 2022), Department of Health and Social Care
• Infection Prevention and Control in Adult Social Care: Covid-19 Supplement (updated August 2022), Department of Health and Social Care
• Health and Social Care Act 2008: Code of Practice for Health and Adult Social Care on the Prevention and Control of Infections and Related Guidance
• Prevention and Control of Infection in Care Homes: An Information Resource (February 2013), Department of Health and Social Care
• HSG220 (2nd edition) Health and Safety in Care Homes
• WASTE22 (rev1) Managing Offensive/Hygiene Waste Safely (April 2014), HSE
• Environment and Sustainability Health Technical Memorandum 07-01: Safe Management of Healthcare Waste (2013), Department of Health and Social Care
• How CQC Monitors, Inspects and Regulates Adult Social Care Services (November 2021), Care Quality Commission.

Policy Statement

All organisations produce waste and are increasingly required to ensure that they deal with that waste in an environmentally acceptable and safe way that is compliant with the law. It is therefore the policy of {{org_field_name}} to minimise and control any risks caused by waste generated by its activities.

{{org_field_name}} will comply fully with all guidance from the Environment Agency, the Department of Health and Social Care and similar authoritative sources. In particular, with regard to clinical waste and offensive/hygiene waste, the home will comply fully with the Infection Prevention and Control: Resource for Adult Social Care (DHSC, March 2022) which states that:

• waste should be managed to ensure that it does not pose a risk of injury or infection
• waste should also be managed to lessen its environmental impact
• all workers responsible for managing waste should understand how to segregate and store waste before collection or disposal according to the hazard presented by the waste
• systems should be in place to ensure that waste is managed in a safe manner and expensive (infectious) waste streams used only where indicated
• in all cases the outer packaging of products used should be removed and recycled, where appropriate.

The home notes that the guidance recognises several types of waste including recycling, household, offensive or hygiene, infectious, sharps and waste medicines. It states that any assessment of how waste must be segregated and disposed of should include:

• asking who generates, and where waste is generated
• asking whether the waste contains blood or body fluids from a person with a known or suspected infection (eg infectious waste)
• asking whether the waste is assessed as non-infectious but has the potential to offend those who come into contact with it (eg offensive or hygiene waste).

The home is aware that the DHSC guidance refers to the DHSC Health Technical Memorandum (HTM) 07–01 as a useful reference guide to assist with waste management. Although written primarily for healthcare settings, the guidance presents aspects of best practice relevant in a residential adult social care or nursing home setting.

The memorandum further defines what is classed as clinical and hazardous waste, what is classed as offensive hygiene waste, what is classed as “sharps” waste, and what may represent hazardous waste medicines. In {{org_field_name}} all those responsible for waste management should be aware of the memorandum and its contents.

Note:

This particular policy primarily concerns clinical (infectious) and offensive/hygiene waste. Further details and guidance relating to sharps waste and waste medicines are covered in separate policies.

Clinical and Offensive/Hygiene Waste

According to the DHSC Health Technical Memorandum (HTM) 07–01:

• clinical waste is defined as including 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, syringes, needles or other sharp instruments, being waste which unless rendered safe may prove hazardous to any person coming into contact with it
• offensive/hygiene waste is that which is non-infectious and not dangerous for carriage but which may cause offence due to the presence of recognisable healthcare waste items, body fluids or odour, for instance, incontinence pads and other waste produced from human hygiene, sanitary waste, etc (note that incontinence pads are not generally regarded as infectious waste unless the person concerned has a urinary tract infection).

{{org_field_name}} understands that, according to the Environmental Protection Act 1990, any organisation which produces clinical or hazardous waste has a “Duty of Care” to:

• keep the 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 safely
• take reasonable steps to check that those providing or removing waste are acting properly and within the law.

According to the guidance in the Infection Prevention and Control: Resource for Adult Social Care (DHSC, March 2022) and the DHSC waste memorandum, waste should be segregated into appropriate colour coded bags. These colours may vary and should be confirmed with the relevant waste contractor.

Colour codes recommended in the guidance include:

• black — general or household waste
• yellow with black stripe — offensive/hygiene waste
• orange — infectious waste
• yellow — infectious waste contaminated with medicines and/or chemicals.

Note:

These arrangements may vary in different areas and for specific settings according to need. Always check with the authorised waste contractor concerned and follow the local scheme.

All those in the home who have a role in the management and segregation of waste should ensure that staff are aware of the different categories of waste that should be placed in each type of bag.

The home must also comply with a range of waste management regulations and guidance which govern the correct method of disposal of the waste, notifications to the Environment Agency, and the keeping of adequate written records for at least three years after disposal of the waste.

The home expects all staff to adhere to the following policy on the disposal of clinical or offensive/hygiene waste.

1. All clinical waste should be appropriately segregated and disposed of in the appropriately coloured orange or yellow plastic sacks (orange is usually used for waste that has been in contact with a person who has an infectious disease, yellow is typically used for any waste that is contaminated with body fluids, chemicals or medicinal waste, etc).
2. Offensive/hygiene waste should be placed in yellow bags with a black stripe.
3. Non-clinical waste can be safely disposed of in normal black plastic bags.
4. On no account should clinical waste or offensive/hygiene waste be disposed of within standard domestic waste sacks.
5. The home believes that clinical or offensive/hygiene waste bags are best used in pedal type bins with lids wherever possible for ease of use and to prevent unnecessary hand contact. These types of bins will be placed in areas where clinical or offensive/hygiene waste is generated, eg clinical treatment rooms, sluice rooms, service users toilets/bathrooms, etc. Staff should always use the foot operated mechanism when using bins.
6. Sacks should never be filled more than three-quarters full and should be removed and sealed by staff wearing non-sterile gloves.
7. Sealed sacks should be handled by the tied neck only and should be handled with care with the bag held away from the body at arm’s length, where possible. On no account should sacks be thrown or dropped. Waste bags that are torn should be placed inside another bag of the same colour.
8. Each sealed sack should be clearly labelled with the home’s details.
9. Sealed and labelled sacks should be collected by an authorised collector only and, while awaiting collection, full bags should be stored safely and securely away from service users, visitors, the general public, animals and pests.
10. A Waste Transfer Note should be completed and a copy kept in the appropriate records.
11. In {{org_field_name}} full sacks should be stored _________________________.

Hands should always be thoroughly cleaned after handling waste of any kind.

Waste Medication and Pharmaceutical Products

In {{org_field_name}} out-of-date or unused drugs or other waste pharmaceutical products should be disposed of via a licensed waste handler along with other clinical waste. Staff should use the purpose-built secure containers provided by the contracted waste handler.

Out-of-date or unused drugs or other waste pharmaceutical products should never be disposed of with normal waste, down toilets or poured away in sinks.

Sharps

Sharps (used needles and broken glass) should be disposed of in sealed purpose-built sharps containers according to the home’s sharps policy and procedure and collected by authorised sharps collectors.

Under the Hazardous Waste Regulations 2005, sharps that contain waste that is either cytotoxic or cytostatic must be disposed of into a designated cytotoxic/cytostatic plastic container and clearly marked with the appropriate label.

Note:

On no account should sharps be disposed of within standard clinical waste or within standard domestic waste.

The Collection of Clinical and Offensive/Hygiene Waste

Under the Environmental Protection Act 1990 it is the responsibility of the home to ensure that services contracted to collect clinical and offensive/hygiene waste are properly licensed to do so. Failure to do this may lead to prosecution. The carrier must be registered with the Environment Agency to carry the waste specified.

• In {{org_field_name}} the authorised collector is ________________________.

On no account should another collection service be contracted without the express authority of the home management.

Covid-19 Contaminated Waste

The home is aware that the DHSC has published additional guidance following the Covid-19 pandemic. Infection Prevention and Control in Adult Social Care: Covid-19 Supplement (updated August 2022) states that:

• in a care home, waste generated when supporting a person with confirmed Covid-19 should enter the hazardous waste stream (usually an orange bag)
• waste visibly contaminated with respiratory secretions (sputum, mucus) from a person suspected or confirmed to have Covid-19 should be disposed of into foot-operated lidded bins which should be lined with a disposable waste bag.

If there is no access to a hazardous waste stream, such as waste generated in people’s own homes, DHSC state that this should be sealed in a bin liner before disposal into the usual waste stream.

Infection Control Training

New staff receive training in the home’s infection control policy and the disposal of waste as part of their induction.

Staff with specific responsibilities for waste disposal and infection control leads are provided with specialist training.

All staff are provided with regular up to date refresher training.

This policy is regularly reviewed and informed by guidance from the local authority waste management officer (where relevant) and the authorised waste carrier.

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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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