Treating microbiological laboratory waste on the site where it is produced: RPS 233

Microbiological laboratories produce microbiology cultures and other microbiologically contaminated wastes. They are autoclaved on site to sterilise them before they are removed from the site.

If you comply with the conditions in this regulatory position statement (RPS), you can autoclave microbiological laboratory waste from a containment level 1, 2, or 3 laboratory without an environmental permit.

This RPS does not apply to any other activity, even if it is under the same legislation. You may still need other permits or licences for other activities you carry out.

Conditions you must comply with

This RPS only applies if you:

• autoclave waste from a containment level 1, 2, or 3 laboratory on the site where the waste is produced
• treat no more than 1 tonne of waste per day – this limit applies to the site producing the waste, not the individual autoclave or autoclaves
• operate the autoclave to the standards set out in the Management and operation of microbiological containment laboratories HSE 2018, in particular appendix 4 on page 80
• carry out regular validation procedures as set out in the HSE guidance – you will need to include a worst case challenge load to make sure the core load is sterilised
• follow the guidance in the Health Technical Memorandum 07-01: safe management of healthcare waste when you dispose of the waste
• keep records for 2 years that show you have complied with this RPS – you must make these records available to the Environment Agency on request

Your waste operation must not endanger human health or the environment.

You must not:

• cause a risk to water, air, soil, plants or animals
• cause a nuisance through noise or odours
• adversely affect the countryside or places of special interest

At face value this all seems quite straightforward. However, they refer to “other microbiologically contaminated wastes” which could be just about anything, and certainly all of those vials of blood and urine processed by hospital pathology labs.

Taken to it’s logical conclusion, this might cause a lot of additional expense for the vast majority of laboratories that may be required to jump though hoops to prove that their autoclaves do not meet the required performance standards, and are then forced to pay for a major refit.

In the alternative, ignore this expensive possibility and autoclave the waste as best you can, then bag it and consign it as clinical waste, passing the regulatory obligations to a licensed contractor. If not, process it as indicated, using an autoclave the performance of which has been checked and confirmed. But then what? EA and their RPS is silent on this, but I suggest dealing with properly treated and safe wastes simply as commercial/trade refuse and get the cheapest possible deal for that.

Be careful that you keep records of your testing regime, and records for every autoclave cycle as it is not unknown that EA will demand these and use the failure to keep adequate records against you.

Lastly, do not overlook the inevitability that the waste you have processed will contain many original patient samples, almost all of which marked with an addressograph label bearing patients’ names and addresses. To comply with the obligation to data protection and privacy laws, these must never be discarded without ensuring a necessary degree of security and complete destruction.