This sounds exciting. What is being done to reduce the production of clinical wastes? What is being done differently, or not being done at all?

There are perhaps many ways to reduce clinical waste outputs. Some are promoted in schemes such as this one, others presented as more scientific study. One common theme is reclassification, rendering claims for real reduction little more than smoke and mirrors.

“Whatever happened to the red bags and bins labeled “biohazard waste” once found in every doctor’s office, patient room and clinic at Tulane Medical Center?

“In its bid to go green, the hospital says, it had to remove some of the red.

“Tulane is about nine months into a two-pronged initiative to reduce its regulated medical waste and cutting costs.

While certainly not denying the importance of the initiatives in Tulane, there must be question about the re-interpretation of waste classifications that push regulators into something of a corner. In some jurisdictions, this has been resisted and schemes to reclassify much clinical waste outputs have quietly failed. others show signs of success. Of these latter, the weight of local authorities to move almost all domestic clinical wastes to sanitary/offensive classification and from orange to Tiger bags has forced the hand of the Environment Agency and permitted similar reclassification of waste arisings in care homes, GP surgeries and acute hospitals.

What is not happening is any real reduction in waste. Regulators work hard to stifle any attempt at material recovery. Waste minimisation is almost unknown in the still laissez faire NHS, where avoiding waste still hasn’t become second nature and cost containment is almost unknown at the coal face.

These schemes crop up at regular intervals. Those involved work hard – and all credit to them – but fail to measure success in anything but the reduction in output of (orange/yellow or red bag) waste streams. Fewer stray wastes that have no place in a clinical waste container, less paper and glass, no drinks cans, no dead flowers or sandwich wrappers, no paper towels, all support headline claims of success.

The fatal flaw – in this context, can I really use that term? – is the failure to examine the domestic or black bag waste stream for items that should have been managed as clinical waste. Its a common, almost universal failure. I have recognised this for at least 30 years and know of no study that has flipped the coin and looked for waste segregation errors placing clinical wastes into black bags.

It must happen. Surely it must? Source segregation is rarely perfect and often woefully inadequate. That is the central tenet of proposals for studies of this kind. So why not follow through and examine the non-clinical waste stream for fugitive clinical wastes?

“The shift is already having an impact. Before the program started, Stericyle had to pick up regulated medical waste from Tulane twice a day. Now the company comes twice a week, he said.

“Tulane expects to generate 290,137 pounds of regulated medical waste in 2013, down from 641,665 in 2012. The reduction will amount to more than $60,000 in savings, Jett said.

A greater than 50% reduction in one waste stream suggests massive earlier source segregation errors. Did that stop overnight? Are staff not getting it right? Every time?

Probably not.

Does it matter, that some source segregation errors are still occurring, though in the opposite direction to contaminate black bag waste streams? Possibly not, as long as these too are handled with care, and assuming that 100% of those obviously hazardous wastes such as cytotoxics and some other drug wastes, sharps and some infectious waste items. Take out any confidential waste items also, including anything that bears a patient’s name. And those many items that might be considered to breach the interpretation of waste classification set out in EQC, and more particularly of an EA interpretation thereof.

It is that often rigid regulatory structure that will be the downfall of each of these attempts at waste ‘reduction’ though reclassification and changes to the practise of source segregation. Those who may secure funding to work alongside those intent on waste reduction such as the Tulane group, and very many others, to examine the composition of the down-regulated waste streams to assess compliance with the obligatory regulatory framework, will win few friends since the results of those studies will blow apart any idea of successful waste reduction through source segregation and down-regulation of wastes.