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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Recycling Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} manages waste, recycling and related environmental responsibilities safely, lawfully and responsibly within its domiciliary support service in Wales. The organisation will comply with applicable Welsh waste and recycling legislation, including the Environment (Wales) Act 2016, the Waste Separation Requirements (Wales) Regulations 2023, the Workplace Recycling requirements introduced in Wales from 6 April 2024, the relevant Welsh Government Code of Practice on the separate collection of waste materials for recycling, and any applicable local authority, health board, environmental health and waste contractor requirements.

This policy also supports compliance with the Regulation and Inspection of Social Care (Wales) Act 2016, The Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended, and associated CIW statutory guidance by ensuring that waste-related practice is safe, risk assessed, monitored, appropriately recorded and understood by staff.

We are committed to reducing landfill waste, encouraging staff and service users to adopt sustainable habits, and ensuring compliance with local authority recycling schemes. This policy provides clear guidance on how to recycle efficiently, how to manage different types of waste responsibly, and how staff should support service users in maintaining environmentally friendly households.

Where support is provided in a service user’s own home, staff must recognise that household waste belongs to the service user and must be managed in line with the person’s wishes, mental capacity, assessed needs, personal plan, local authority household waste arrangements and any relevant risk assessment. Staff must encourage and support recycling where this forms part of the agreed support, but must not remove, dispose of or interfere with a service user’s property, documents, medicines or waste without appropriate consent, authorisation and clear recording.

2. Scope

This policy applies to:

• All employees, volunteers, and contractors who work within our home care service.
• Service users and their families who require support with recycling and waste management.
• Third-party suppliers and waste disposal services working in partnership with our organisation.

It covers:

• Separation and recycling of workplace waste produced by the organisation, including paper and card, glass, metal, plastic, cartons and other similar packaging, in line with Welsh workplace recycling requirements.
• Separate collection of food waste from the office or other organisational premises where the legal threshold is met, and good practice monitoring where food waste is below the threshold.
• Appropriate management of small waste electrical and electronic equipment, batteries, printer cartridges, textiles, uniforms and other business waste where these arise.
• Support for service users with domestic household recycling only where this is part of the agreed care and support being provided and is consistent with their personal plan, consent and local authority arrangements.

• Safe disposal of confidential waste, including personal documents and records.
• Appropriate disposal of clinical and hazardous waste (e.g., medical waste, sharps).
• Energy and resource conservation efforts to reduce environmental impact.
• Training and responsibilities of staff in maintaining sustainable practices.

This policy does not authorise staff to make decisions about a service user’s household waste, personal documents, possessions, medicines or confidential information without the service user’s consent or other lawful authority. Where waste management support is required, it must be delivered in a way that promotes dignity, independence, choice, control, safety and personal outcomes. Any regular support with waste or recycling should be reflected in the person’s personal plan where appropriate.

3. Legal and Regulatory Framework

This policy is informed by, and should be read in line with, the following legislation, regulation and guidance where applicable:

• Environment (Wales) Act 2016;
• Waste Separation Requirements (Wales) Regulations 2023;
• Welsh Government Workplace Recycling requirements from 6 April 2024;
• Welsh Government Separate Collection of Waste Materials for Recycling: Code of Practice for Wales;
• Waste (England and Wales) Regulations 2011;
• Environmental Protection Act 1990;
• Data Protection Act 2018 and UK GDPR;
• Health and Safety at Work etc. Act 1974;
• Control of Substances Hazardous to Health Regulations 2002;
• Regulation and Inspection of Social Care (Wales) Act 2016;
• The Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended;
• CIW statutory guidance for service providers and responsible individuals of care home and domiciliary support services.

Where there is any conflict between this policy and current legislation, statutory guidance, local authority requirements, health board requirements or waste contractor instructions, the higher or more specific legal or safety requirement must be followed.

4. Managing Recycling and Waste Disposal Efficiently

4.1 Workplace Recycling and General Waste Procedures

At the organisation’s office, base or any other non-domestic premises used by {{org_field_name}}, waste must be separated in accordance with the Welsh workplace recycling requirements and the relevant Welsh Government Code of Practice. Staff must ensure that the following workplace waste streams are separated and presented correctly for collection where they are produced:

• paper and card;
• glass;
• metal, plastic, cartons and other similar packaging;
• food waste, where the organisation produces 5kg or more of food waste in any seven consecutive days;
• small waste electrical and electronic equipment, batteries and printer cartridges, where these arise;
• textiles, including uniforms or other business textiles, where these arise and are suitable for separate recycling or disposal.

General waste must only be used for items that cannot lawfully or practically be recycled through the organisation’s available recycling arrangements. Recyclable materials must not be deliberately placed in general waste. Staff must use clearly labelled containers and must follow local waste contractor instructions to prevent contamination.

Waste transfer notes, collection arrangements and contractor information must be retained where applicable. The Registered Manager, or delegated person, must check that waste collection arrangements remain suitable and that the organisation’s waste descriptions are accurate.

In service users’ own homes, staff must follow the local authority household recycling arrangements that apply to that address. Staff may support the service user to sort waste and place bins or bags out for collection where this is part of the agreed care and support. Staff must encourage independence and must not make decisions on behalf of the service user unless this is agreed, lawful and recorded.

4.2 Confidential Waste Disposal

As a domiciliary care provider handling sensitive information, we are committed to ensuring the secure disposal of confidential waste. Staff must:

• Never dispose of, shred, remove or alter service user records, care plans, financial documents, correspondence or personal papers unless this has been authorised in line with the Confidentiality and Data Protection Policy, records retention requirements and the service user’s consent or other lawful authority.
• Place organisational confidential waste in the designated secure confidential waste container or follow the approved secure shredding process.
• Use an approved confidential waste contractor where documents are collected for destruction, and ensure that destruction certificates or collection records are retained where applicable.
• Never place confidential information, care records, medication records, rotas containing personal information, staff records or service user information in general waste or open recycling bins.
• Report any actual or suspected data breach immediately to the Registered Manager and follow the Confidentiality and Data Protection Policy.

For service users requiring assistance in managing their personal documents, staff will provide guidance on secure storage and disposal while maintaining their right to privacy.

Where a service user asks staff to help dispose of personal documents, staff must support the person to make their own decision wherever possible. If the documents contain personal, financial, legal or medical information, staff must advise the person to use a secure method of disposal. Staff must not take documents away from the person’s home for disposal unless this has been specifically agreed, risk assessed and recorded.

4.3 Clinical, Offensive/Hygiene, Sharps and Hazardous Waste Management

Some service users may produce waste that requires special handling. This may include clinical waste, offensive/hygiene waste, sharps, contaminated dressings, body fluid waste, continence products, PPE, medication waste, chemical products or other hazardous waste. Staff must follow the person’s care plan, risk assessment, infection prevention and control procedures, local authority or health board arrangements, and any instructions from a district nurse, pharmacist or other relevant professional.

Not all continence products, dressings or hygiene waste are automatically clinical waste. The classification and disposal route must be based on the level of risk, whether the waste is infectious or contaminated, and the arrangements agreed for that service user.

To ensure safe disposal:

• Sharps must only be disposed of in an approved sharps container. Staff must never place sharps in general waste, recycling bags or loose household bins.
• Staff must not recap, bend, break or manually handle used needles or lancets. Any sharps injury must be treated as an incident and reported immediately.
• Clinical waste bags, offensive waste bags or other specialist containers must be used only where these have been provided or agreed by the local authority, health board, community nursing service or waste contractor.
• Waste contaminated with blood, body fluids or potentially infectious material must be handled using appropriate PPE and infection prevention and control procedures.
• Staff must not transport clinical waste, sharps or hazardous waste in their own vehicle unless this has been specifically authorised, risk assessed and arranged in line with legal and organisational requirements.
• Any spillage, unsafe waste storage, missing sharps container, overfilled sharps container or incorrect disposal must be reported to the Registered Manager immediately.

Staff must never mix clinical waste with regular household waste and must report any mismanagement of hazardous waste to the Registered Manager ({{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}) immediately.

4.4 Reducing Single-Use Plastic and Promoting Reusable Alternatives

Our organisation is committed to reducing plastic waste in daily operations. To achieve this, we encourage:

• Using reusable cups, water bottles, and bags instead of single-use plastics.
• Avoiding excessive packaging when purchasing supplies.
• Switching to biodegradable or compostable alternatives where possible.
• Educating service users on reducing plastic dependency in their homes.

Wherever possible, staff should support service users in choosing eco-friendly options, such as reusable shopping bags and refillable household products.

Reusable alternatives must only be used where they are safe, hygienic and appropriate. Staff must not compromise infection prevention and control, food hygiene, medication safety, clinical waste procedures or service user safety in order to reduce single-use items. Where single-use PPE, clinical items or hygiene products are required, they must be used and disposed of correctly.

4.5 Energy and Resource Conservation

In addition to recycling, we promote energy efficiency and resource conservation within our domiciliary care service by:

• Encouraging staff to turn off lights, computers, and appliances when not in use.

• Using energy-efficient lighting and equipment in organisational premises where possible.
• Encouraging service users to consider energy-efficient options in their own homes where appropriate, while recognising that decisions about their home, possessions and utilities remain their own or those of their lawful representative.

• Minimising water wastage by ensuring taps are fully turned off after use.
• Encouraging digital record-keeping to reduce paper waste.

All staff members are expected to lead by example, incorporating sustainability into their daily work practices while encouraging service users to adopt environmentally friendly habits.

4.6 Food Waste and Drain Disposal

At the organisation’s office, base or any other non-domestic premises, food waste must be monitored. Where the organisation produces 5kg or more of food waste in any seven consecutive days, it must be separated and presented for collection in line with Welsh workplace recycling requirements.

Food waste must not be disposed of down sinks, drains or toilets. Staff must not use macerators, in-sink disposal units or similar equipment to dispose of food waste into the sewer.

In service users’ homes, staff must follow the household arrangements in place for that address and support the service user only where this is part of the agreed care and support. Staff must not dispose of food waste in a way that creates infection control, pest control, odour, slip, trip or hygiene risks.

4.7 Waste Produced During Care Visits

Waste produced during care visits must be disposed of safely and in line with the service user’s personal plan, infection prevention and control procedures, and local arrangements. Staff must:

• dispose of ordinary household waste in the service user’s household waste system, where this is appropriate and agreed;
• dispose of PPE and hygiene waste in line with infection prevention and control guidance and the relevant risk assessment;
• never leave waste in a way that creates odour, pest, infection, fire, slip, trip or manual handling risks;
• never place clinical waste, sharps, medication waste, hazardous chemicals or confidential information into general household recycling;
• report concerns about unsafe waste accumulation, hoarding, pest infestation, blocked exits, fire risk or environmental health concerns to the Registered Manager.

5. Waste Contractors, Collection Records and Duty of Care

The organisation must only use appropriate waste and recycling collection arrangements for workplace waste. The Registered Manager, or delegated person, must ensure that:

• waste and recycling contractors are suitable for the waste streams collected;
• waste transfer notes or equivalent records are checked and retained where applicable;
• the description of waste being collected is accurate;
• confidential waste contractors provide suitable evidence of secure destruction where applicable;
• clinical, hazardous or specialist waste is collected only through appropriate authorised arrangements;
• staff do not use domestic service user bins to dispose of organisational office waste.

6. Staff Responsibilities and Training

All staff must understand and follow this policy in line with their role. Staff must:

• complete induction information on waste management, recycling, infection prevention and control, confidentiality, hazardous waste and environmental responsibilities;
• understand the difference between organisational workplace waste and domestic household waste in a service user’s own home;
• follow Welsh workplace recycling arrangements at the organisation’s office, base and any other non-domestic premises;
• support service users with household waste and recycling only where this is part of the agreed care and support or is reasonably connected to the care being delivered;
• promote the service user’s independence, dignity, choice and control when supporting with household recycling or waste;
• use PPE and safe handling procedures where waste may be contaminated or hazardous;
• never dispose of sharps, medicines, confidential information, clinical waste or hazardous waste in general waste or ordinary recycling;
• report hazards, non-compliance, missed collections, unsafe waste storage, hoarding concerns, pest concerns, sharps incidents, spillages or suspected data breaches to the Registered Manager without delay;
• record waste-related concerns in the appropriate care record, incident record or management record where required.

Managers must ensure that staff receive updates when legislation, local authority arrangements, infection prevention guidance or organisational procedures change. Where a staff member requires additional support or supervision in relation to safe waste handling, this must be arranged and recorded.

6.1 Manager and Responsible Individual Oversight

The Registered Manager is responsible for implementing this policy on a day-to-day basis. The Responsible Individual must maintain appropriate oversight through governance, quality assurance and service monitoring arrangements. Waste, recycling and environmental safety issues must be considered where relevant through:

• office or premises checks;
• infection prevention and control audits;
• health and safety audits;
• incident and accident monitoring;
• staff supervision, team meetings and training records;
• quality assurance systems and service improvement planning;
• feedback from staff, service users, representatives and commissioners where relevant.

Any repeated failure to follow this policy must be addressed through supervision, retraining, performance management or disciplinary procedures, depending on the circumstances and level of risk.

7. Monitoring and Compliance

To ensure compliance with this policy, {{org_field_name}} will:

• review waste and recycling arrangements at least annually and sooner where legislation, Welsh Government guidance, local authority arrangements, waste contractor requirements or service needs change;
• check that workplace waste streams are separated correctly at organisational premises;
• monitor whether food waste reaches the legal threshold for separate collection at organisational premises;
• retain relevant waste transfer notes, collection records, contractor information, confidential waste destruction certificates and audit records where applicable;
• review incidents involving sharps, clinical waste, hazardous waste, medication waste, confidential waste, spillages, pest risks or unsafe disposal;
• include waste-related learning in staff updates, supervision, team meetings or training where required;
• take action where audits, incidents, complaints or staff feedback identify poor practice or avoidable risk.

The Registered Manager will ensure that any significant waste-related health and safety, infection control, safeguarding, environmental health or data protection concern is escalated in line with the relevant organisational policy and, where required, to the appropriate external body.

8. Related Policies

This policy should be read alongside:

• Health and Safety at Work Policy (DCW16)
• Infection Prevention and Control Policy (DCW17)
• Confidentiality and Data Protection (GDPR) Policy (DCW34)
• Handling and Disposal of Hazardous Substances Policy (DCW22)
• Risk Management and Assessment Policy (DCW18)

• Medication Policy
• Records Management and Retention Policy
• Incident and Accident Reporting Policy
• Safeguarding Adults and Children Policy
• COSHH Policy
• Lone Working Policy
• Personal Protective Equipment Policy
• Duty of Candour Policy
• Service User Personal Plan / Care Planning Policy
• Business Continuity Policy

9. Policy Review

This policy will be reviewed at least annually, or sooner if there are changes to Welsh waste and recycling legislation, Welsh Government guidance, CIW requirements, statutory guidance, infection prevention and control guidance, local authority arrangements, waste contractor requirements or organisational practice. The Registered Manager is responsible for ensuring this policy is implemented, monitored and communicated to staff. The Responsible Individual will maintain oversight through the organisation’s governance and quality assurance arrangements.

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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}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.