Water UK published on 11th April its National Guidance for Healthcare Waste Water Discharges.
The document will be reviewed in detail over the next few days, but a quick glance suggests a carefully thought out and properly balanced document.
Many examples are given, and few are prohibited for discharge – and no surprises among those which are – with many others marked with a caution to seek official guidance on the local requirement for discharge consent.
Looking though the range of named pharmaceuticals the list is obviously incomplete – it would be inappropriate to expect anything else – and the lack of an entry should not be used to assume that discharge is permitted.
It is a pity that generic groupings of pharmaceuticals were not listed, rather than individual drugs, but its a start. The big issue of course is left unspoken. It there might be control over discharge of an amount of any drug, how much is of concern. Is this an absolute requirement, or is there some practical minimum or de minimis concentration? The really big question for example, is what about fully discharged sharps?
And of course, this must be seen in context. The discharge consent requirements do not apply, yet, to sewage discharges. Wastes deliberately sent to foul sewer are not considered in detail though this should not be seen as an excuse to drop wastes into the toilet, sluice or bedpan washer without restriction. Nor is there any restriction of patients, who urinate and defecate regularly and excrete the vast majority, up to 98%, or the drugs administered to them. That of course is the real problem here, and though it must be the base comparator it is no reason to ignore other discharges, however small they may be.
The Water UK National Guidelines are particularly helpful, though these are just a first step. There is no evidence of the hand of the Environment Agency in their construction. It is not surprising that these guidelines site unconformably against the much more restrictive EA constraints placed on the processing of clinical wastes by any of the ATT processes. Those constraints have largely been used to create an artificial and quite unjustifiable barrier to manipulate an industry and support an ideology that does not sit well against the hierarchy or waste processing and corresponding environmental concerns.
30 June 2011
Further reading the Water UK document has been a depressing and rather annoying experience. It is full of errors, on almost every page, demonstrating not only a lack of care but a serious lack of understanding of healthcare practice on the part of the authors. Some of those errors are risible, others may have a serious impact on the value and interpretation of this ‘guidance’, while the entire document might score at best a miserly 2/10 for content and quality.
The inclusion of external consultants may not have been wise; they certainly didn’t impact greatly on the production of a worthwhile document. If this were a student essay I would send it back for substantial revision. I certainly would’nt pay. Perhaps version 2 will be better, though they may need an adviser who actually understands what they are dealing with and can compile a meaningful and error-free document?
It is, of course, entirely correct to caution or prohibit the discharge of certain materials into the sewage process. However, the core tenet of the Water UK document seems to be predicated on a desire of the water industries to protect their share price and bottom line accounts by spending as little as possible. Nothing wrong with that, it’s what every company should do, but reading between the lines of the Water UK document is seems that they would prefer we didn’t discharge anything into the sewers so that they bear no cost whatsoever!
Unlikely? Well, maybe not. A recent Mail Online report concerns the “attempt by Water UK to gag weather forecasters because it could damage share prices“. That alone devalues the status of and tarnishes the reputationof the water industries and their representative body Water UK in particular. Is it correct therefore that they should be seeking the role of guardian of water and sewage disposal, at least without far more rigorous oversight from a technically competent external regulator who will act with independence and transparency?