Though tattoos seem to be more popular then ever and a permanent adornment of the rich and famous, and those who wish to emulate them, there is much data to suggest that their popularity lies at the lower pole of the social strata. With that comes IV and other drug abuse, and a higher than average incidence of bloodborne virus disease.
It follows that there exists a high risk of infection that might be associated with tattooing. Logically, tattoo needles and bloodstained swabs, gauzes etc must also be considered high risk for infection and managed accordingly. If proof were needed, the incorrect use of tattoo needles not changed between clients, and even the re-use of bottles of ink but with a clean needle each time, have been associated with outbreaks of Hepatitis B infection.
Tattoo wastes are potentially dangerous, and must be handled accordingly.
To maintain the highest standards of safety, tattooists are highly regulated though some seek to operate outside those regulations and there the risk of infection escalates tremendously. But for the majority, the process is regulated and every care is taken to ensure the safety of clients and of the tattooist.
Wastes from tattooists should be handled accordingly, and logically we might expect that these should be handled as clinical wastes in order to package, handle and treat those wastes appropriately.
New guidance on good practice in tattooing and body piercing has been produced jointly by the Chartered Institute of Environmental Health (CIEH), Public Health England, the Health and Safety Laboratory and the Tattoo and Piercing Industry Union (the body representing practitioners). It is published on the CIEH and PHE websites; a copy can be accessed here. The ‘toolkit’ provides briefing on: principles of infection prevention and control, including use of PPE; sharps management; waste disposal; cleaning and disinfection; management following exposure to blood/body fluids; and how to ensure product quality of tattoo ink.
It is sharps management and waste disposal that will concern us here.
The toolkit references HTM 07-01. It refers throughout to sharps management requiring UN 3291 and BS7320 standards (should be BS EN ISO 23907:2012). It makes it quite clear that these wastes are , and must be handled as, clinical wastes. The document is clear, and the purpose is to ensure standards of care in use and disposal that ensure prevention of infection, for users, for the tattooists’ clients, and for those involved in waste disposal.
Despite this distillation of good practice endorsed by Public Health England, and providing the framework for regulation of tattooists, the Environment Agency had some years ago decided on the most flimsy administrative grounds to reclassify waste and sharps waste from tattooists as EWC 20 01 99 Municipal wastes and similar commercial, industrial and institutional wastes including separately collected fractions – other fractions not otherwise specified.
The relevant text is found in the Environment Agency guide “Using the List of Wastes to code waste”
Animal and human hygiene wastes that arise from activities that are not related to healthcare should not be coded using chapter 18, for example:
(i) non-clinical, municipal wastes, such as feminine hygiene waste from shops and offices and dog faeces from collection bins, should be coded using 20 01 99 – other fractions not otherwise specified but should be described fully e.g. feminine hygiene waste not from healthcare not subject to special requirements in order to prevent infection; and
(ii) sharps waste arising from non-healthcare activities, such as tattooing, cosmetic ear or body piercing and from substance abuse (where not arising from healthcare) should also be coded 20 01 99. Other sharps such as those that have been used by diabetics are a healthcare waste and should be coded under chapter 18.
Thus, wastes from tattooists is not clinical waste. Nor too is waste collected, as drug litter, from substance abuse (where not arising from healthcare). This exceptionally high risk waste is increasing found and its management requires the highest standard of performance to reduce any risk of exposure. Despite that, the Clinical Waste Discussion Forum reports a constant stream of cases where individuals are stuck with a discarded needle; many others go unreported.
Does it matter? The Environment Agency can play games with waste coding, interpreting as they see fit EU guidance. That is a paperwork exercise and, if that is what they want, is of little concern to anyone. One might question if it is appropriate, or necessary, or worthwhile, to account separately for the amount of waste from healthcare not inflated with that small additional fraction rom tattooists, or from drug litter? And obviously it does not matter what amount of waste is produced by the tattooists activities since this is coded into a generic catch-all 99 code.
So, why should we be concerned about this? Apart from the simple nonsense of this bureaucratic ‘quirk’ the great risk is from the negative message that it delivers, that these wastes are in some was less hazardous or perhaps non-hazardous by risk of infection. Is it time to revise the EWC list of wastes, to bring together wastes by its various properties – isn’t that what was intended anyway? – and do away with these confusing and potentially misleading peculiarities?