Are special EA dispensations threatening the clinical waste sector?

ENDS reports a new entrant to the clinical waste disposal market has claimed there is a lack of incineration capacity, a concern that was first highlighted last year when a specialist waste firm collapsed. I am highly tempted to agree, and wholeheartedly so.

Andusia also claims that, following the demise of Healthcare Environmental Services (HES), the government has been permitting the disposal of many clinical waste streams via “inappropriate, largely domestic disposal plants, via special dispensation”.

The firm said this “cannot be a long-term solution” and should have only been a temporary fix, but said  the practice was still continuing.

A recent 2019 Anenta report and HTM0701 (the government’s Health Technical Memorandum on best practice for disposal of healthcare waste) verifies that under the laws prior to the collapse of HES, the segregation and transport of clinical waste meant that it had to be meticulously sealed, stored and segregated.

However, according to Andusia,  the dispensations granted to various companies have meant that these laws have been largely abandoned for a length of time for a select few contracts.

In addition, it notes that domestic waste incinerators are not designed for clinical waste, and “there is no guarantee of destruction of medicines, or inactivation of microorganisms in the domestic plants”.

Andusia added that the current actions permitted by government “are threatening the future of any much-needed investment in the sector, that is long overdue”.

In response, the Environment Agency (EA) said: “As a regulator we cannot influence the provision of suitable infrastructure or act to prevent business failure of operators. However, the EA  continues to determine healthcare permit variations and applications and provide local enforcement positions where we have been satisfied that these do not pose a threat to the environment or people.”

In April this year, Andusia announced itself as the sole waste supplier to a new clinical waste treatment plant in Worcestershire. The new plant, which is being developed in an existing, retired plant in Malvern, is the first of its kind to be built in the UK in the last decade and is one of up to four planned in the next few years. Andusia says the plant will help towards shrinking the capacity gap significantly.

I have much sympathy. For quite some years, the Environment Agency has been seeking to manipulate the clinical waste market with a mix of favouritism and blatant obstruction. Manipulation in this manner is, of course, entirely outside their remit and I presume illegal. However, and though it has been widely recognised for years, it has in all probability much to do with the actions of one individual rather than being Agency policy.

It was apparently a case of Bob’ll fix it, at least for those who he chose to support.

Despite professing my sympathy, it is difficult to ignore the consequences of this quasi-official stance in permitting etc. It has certainly encouraged some operators effectively and rather aggressively to abuse their positions to the detriment of others, preparing the way for a fall and, more generally, on the problems that we now see.

This situation cannot be placed at the feet of the aggressors. After all, it is their responsibility to shareholders to do their upmost to increase market share and much up prices and profitability. But if their was just the smallest drop of water separating some sector business leaders with those EA employees playing games in this way, then everything would smell much, much better.

Asa the situation evolving from the demise of HES Ltd continues to unravel, perhaps this will be brought into the light? One can only hope that it will be.

As a separate matter, Andusia’s claims that the government has been permitting the disposal of many clinical waste streams via “inappropriate, largely domestic disposal plants, via special dispensation” is of particular interest. After all, a properly managed domestic waste incineration plant has a far better environmental footprint and offers reduced costs compared to any dedicated clinical waste incinerator. I disagree with Andusia, expecting this to provide a valuable and effective long-term solution.

We have discussed that approach over the last 10 or more years, and considered it in considerable detail and experimentally with no concerns.

The Environment Agency opinion, and it is a very much ex-Cathedra opinion issued without evidence of fact, is that with this approach “there is no guarantee of destruction of medicines, or inactivation of microorganisms in the domestic plants”.

For the bulk destruction of waste pharmaceuticals, other arrangements would apply. However, for those drug residues present in the bulk of clinical wastes, there is much evidence that even temperatures below 400C are adequate, and that massive dilution further eliminates any residual hazard. And what about the administered dose?

Drugs administered to patients are excreted together with a number of metabolites, in urine and faeces. We know nothing of their fate, save to understand that clearly the treatment of sewage relies on a Victorian process that has no impact on the drug substances within that are subsequently discharged into rivers. All that the Environment Agency would say on the matter was that such discharges were nothing to do with hazardous wastes/clinical wastes but fall within the remit of a different division. How was that for dodging the question?

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