LB Barnet have been working hard to update their clinical waste information for community producers.
Their recently published GN 5 – Guidance Notes for Storage and Disposal of Clinical Waste explains the categorisation of clinical wastes (Groups A, B and E), the need for source segregation and the colour codes of waste sacks required. The note includes also instruction to producers regarding the secure storage of clinical wastes that might be appropriate for small commercial producers, (though I doubt very many would comply), and, presumably, domestic producers also.
For Group A wastes, “sacks … must be stored in a locked, secure, easily cleansable [sic], storage area while awaiting collection by a registered waste carrier. Where the sacks remain in the holder and need to be stored prior to collection they must be held in the locked, secure, easily cleansable, area. There must be a biohazard sign clearly displayed on the door of the storage area.”
Group B wastes, that Barnet seem to define as sharps waste, must be “…held securely while awaiting collection..”
By contrast, Group E wastes “can be disposed of in trade or domestic waste providing it is adequately wrapped and free from excess fluids. However, this waste requires some sort of risk assessment before disposal. “If the client is known to be suffering from, or is a carrier of, an infectious disease then the waste would become clinical and require handling as Group A clinical waste “…can be disposed of in trade or domestic waste providing it is adequately wrapped and free from excess fluids.”
Barnet make clear that “It is important therefore to determine the risks associated with the waste from waxing as a result of a client consultation to determine if the waste can be classified as Group E. If the client is known to be suffering from, or is a carrier of, an infectious disease then the waste would become clinical and require handling as Group A clinical waste.”
Of course, the real problem here is whether there is anyone who can make an adequate judgement about the health status of a patient or of a customer entering cosmetic piercing or similar premises. Where is the training for that risk assessment? In almost every case, there will be nobody competent to risk assess, it may breach reasonable confidentiality rules to ask, and of course in so many instances the individual may not know that they carry some nasty infectious disease!
It’s all a bit of a nonsense but one that, depending on this dodgy risk assessment, can upgrade Group E waste to Group A and add a substantial cost to disposal.
And of course the storage requirements. These seem to be pretty standard but it is impossible to believe that a domestic producer could comply with those conditions.
Though LB Barnet do not specify on their web pages the practicalities of domestic clinical waste collections in all probability they expect patients to leave wastes in an accessible location to await collection. Wastes may be inside a front gate for many hours, of for those without a garden on the pavement or in a walkway, corridor etc.
Perhaps predictably, we might reasonably assume that in the case of any incident, or simply when someone wants to put their foot down some domestic clinical waste producer, managing as best they can, will be held responsible for a breach in waste security standards for doing no more that that directed by their Local Authority. This was recently seen also with Cornwall and Isles of Scilly guidance, and no doubt many others.
So much for waste security!