I have been asked for views on clinical waste pre-acceptance criteria, and the various layers of EA guidance – it is only guidance and not law, and if a better approach can be developed that should be acceptable.

Waste pre-acceptance audit is essential, and Blenkharn Environmental fully supports the principle. It is the main way by which processing of wastes can be managed properly, choosing the best option for any individual waste consignment.

Much of the guidance rightly focuses on liaison with waste producers, detailed periodic waste audit at each of the producer’s sites, and some degree of composition analysis. Doing nothing is not an option, but much of that which is recommended has little value, is unsafe and extremely misleading.

Audit cannot reasonably be considered without integrating this with education and teaching, and should consider local logistics since in many establishments wastes are aggregated between ward or department and final storage and collection point for transfer to the waste management provider.

Too often, I have seen auditors peer into open waste sacks and place themselves and others at risk by raking through the content with a stick. No gloves, and no though for the integrity of a thin-walled sack leaves wide contamination that someone else must clean up! This is unacceptable – on the grounds of health and safety, and for the very simple reason that ‘sampling’ a few bags by peering into the top of them is insufficient to provide the information required. Only by repeated and on-going audit is it possible to get an accurate feel for segregation performance.

The most common error, for waste ‘consultants’ and for researchers alike,  is to focus on clinical waste containers and ignore black sacks. Too often, proposals to improve segregation and reduce that volume of waste in clinical containers are measured by the reduction in clinical waste production. Leaving aside the quality of that research which so often ends with ridiculous claims of potential savings scaled up after just one day that obviously will not be sustained, nobody seems to ask where it all goes? Of course, some non-clinical wastes are taken out of orange or yellow bags, and rightly so. But what else is mis-directed to the black bag stream? That is a vital question, that addresses segregation errors when place waste handlers at still further risk.

Audit can be internal – and should be performed as part of an on-going process – with additional external audit to provide a fresh pair of eyes. The task may fall to an infection control nurse or estates manager though in neither case are the skills appropriate to consider all waste-related activities from bedside, or pharmacy, or theatre, mortuary, laboratory, toilets etc, all the way through collection and internal movement of waste by porters or cleaning contractors.

The key question was, should waste containers be opened and emptied at teh site or arising, or later when the waste management provider receives the waste. Apparently, some EA staff are suggesting that this must be done, though I would offer an emphatic NO. Without great care, this is a potentially dangerous procedure – I’ve done it before, for the ground-breaking 1988 LWRA clinical waste audit – that places individuals in immediate danger and risks extensive contamination of the working environment.

Audit at the contractors premises is almost certainly unjustifiable on the grounds of safety. Scratching around inside containers that should not be opened it totally wrong, and even examination of waste post-processing is inappropriate since there is the obvious tendency to jump on the occasional tablet or drug vial without considering the entire load thus taking things hugely out of context.

Waste audits that are conducted as part of a checklist inspection have their place, but for regulatory purposes are almost entirely meaningless. What is the unit of measurement for assessment of segregation performance? Per sack or per bin? Per ward or per department? Per lorry load? It’s all a nonsense but is presently being used, and abused, by Environment Agency staff some of whom have an axe to grind in support of their own vision for waste management  and others who lack clarity of thought.

Waste audits are an essential part of waste pre-acceptance criteria. This is a small part of a complex issue that includes close liaison with producers, not only those who compile some paperwork to satisfy the bureaucracy but front-end waste producers. Later audit performed as part of the contractors’ waste pre-acceptance criteria have their place and provide useful feedback to producers, but the information that they might provide can be hugely misleading, and mis-used.

Waste audits that do not form part of waste training and management for all producer staff are no more than a waste of money. Audit must map closely to training  and education, including an assessment of waste containers, container placement, hygiene, safety, logistics and staffing, internal collection and transport, storage, waste aggregation and waste stream management, waste carts and other equipment items, waste security, PPE and personal hygiene, occupational health and so on. It should form part of regular management control and include many staff from different producer sections, and representatives of any contractors including waste management, portering and cleaning since these latter services may be contracted out and external to the review process.

Occasional external audit is strongly recommended as this will often identify matters that have repeatedly been overlooked.