Waste registration for embedded NHS service providers

This message, from Chris Lowe, PPC/RSR Officer 1 from the Environment Agency England & Wales) will cause considerable concern to many organisations working on hospital and university sites.

“It has come to our attention that there is some confusion over the requirement to register as a producer of Hazardous Waste. Under the current legislation as a general rule every producer of more than 500kg of hazardous waste in a 12 month period is required to register with the Environment Agency.

In the case of a hospital with multiple occupiers such as a private wards, university laboratories, 3rd party PFI facilities departments and even builders carrying out renovation work, then all the producers need to register. In some scenarios the waste storage area also needs to be registered.

If you are unsure about the need to register then our guidance on registering your premises can be found here; http://www.environment-agency.gov.uk/business/topics/waste/32198.aspx

Please don’t forget that a registration only lasts for 12 months and then it needs to be renewed before collections can recommence. Registrations and renewals can be made on line or by phone using the details found at the link above. If you have previously registered its important that you renew your premises rather than start a new registration.

There are specific exemptions for ambulance services and other mobile healthcare providers in our regulatory position statement.

As ever if you have any questions please don’t hesitate to contact myself if you are north of the River Thames 01707 63 2520

chris.lowe@environment-agency.gov.uk and Matthew Higginson on 0208 305 4809 or matthewr.higginson@environment-agency.gov.uk if you are south of the River Thames.”


From what is perhaps an incidental and, hopefully, unintentional consequence of the legislation it would seem that the Regulator is intent of creating difficulties and raising revenue through the box ticking that stems from an unnecessarily rigid interpretation.

With increasing outsourcing in the NHS and much close collaboration in University life with more and more embedded units intended working for a common goal the requirement to register as a waste producer seems entirely unreasonable. This might be appropriate for a contractor undertaking a major refurbishment that entails a considerable amount of asbestos stripping. However, where embedded contractors operating on site to provide, for example, pathology services work so closely that wastes are managed on a site-wide basis the requirement for separate registration seems quite unnecessary.

Extra payment for registration is perhaps the goal. But there will be additional need to create a more complex paper chain as waste moves along the hospital corridor from one organisation to another. Perhaps also separate disposal contracts eliminating any possibility for economy of scale. Administrative workloads will be increased, possibly with a need to create an additional waste manager role where previously a site waste manager had been sufficient. The extra costs will be borne ultimately by the tax payer, generally at the expense of maintaining an effective NHS service.

Universities may fare even less well, where individual research units may be entirely funded by a third party, even if the staff are paid by the university with recharge of salary costs to the funding body. If the regulator seeks to identify each such unit as a separate body for the purposes of waste regulation then the uproar from the Universities will be overwhelming. And if not, then such similar imposition to embedded NHS service providers must surely become untenable.

Unless of course they intend only to pick off the easy targets.

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