Health care waste in the community

Background

In 2006 the Department of Health produced Health Technical memorandum 07-01: Safe management of health care waste (HTM 07-01). HTM 07-01 introduced a unified approach to health care waste management including UK wide colour coded waste streams and brought health care waste management in line with European requirements, environmental, transport and safety legislation.

HTM 07-01 sought to clarify requirements in relation to waste created in community. The chapter on community nursing, states that where waste is generated by a health care worker in the community e.g. in private households, the health care worker has a duty of care to ensure that the waste is managed correctly. Under section 34 of the Environmental Protection Act (1990) and the Environmental Protection (Duty of Care) Regulations 1991 everyone who manages waste and/or has responsibility for the management of waste is required to fully comply with his or her own “duty of care”. This duty of care extends to the health care organisations.

Health care workers in the community and in the household environment need to assess the waste they are generating for the hazardous properties it may contain, most notably infectious, and dispose of it appropriately. HTM 07-01 provides an assessment process for infectious waste, including dressings. Following an assessment, for the main part it is acceptable for non-infectious waste to be disposed of in the domestic waste stream when wrapped inside another bag such as a sandwich bag or bin liner.

Health care workers must ensure that arrangements are in place to ensure that any infectious waste generated from the treatment they have delivered is segregated correctly, packaged and labelled correctly and transported for appropriate treatment and disposal. Further information on the definition of infectious waste can be found in Appendix E of the Safe management of health care waste (HTM 07-01).

HTM 07-01 state that local options for dealing with waste not suitable for the domestic waste stream namely:

Option one: Health care workers using their own vehicles to transport waste back to a base.

Option two: Arrange for an appropriate organisation (either a waste contractor, local authority or the healthcare provider) to collect the waste.

Members’ concerns

In November 2009, just over 600 members working in the community responded to an RCN questionnaire on the management of community health care waste. The results of the questionnaire indicate that the majority of members carry some form of clinical waste in their personal vehicle. Most of this is sharps waste contained in a sharps box, however a small number carry waste which they have deemed to be infectious such as used dressings. In some instances it appears that safeguards such as appropriate secure rigid boxes, following packaging instruction P621, are not being used.

The overwhelming majority of members would be extremely unhappy, some to the point of resigning their post, at having to transport non-sharp infectious waste in the boot of their personal vehicle. Members, with justification, are concerned about cross infection, the potential for leakages (and difficulties in cleaning a carpeted boot) and offensive odours permeating their personally owned vehicles. They are also concerned that infectious waste will contaminate clean equipment carried in their vehicles such as dressing packs. Another concern is the extra time taken to dispose of waste at a health care base could detract from time spent in the delivery of patient care.

RCN position

As a result to the responses of the questionnaire and in recognition of members’ concerns, the RCN has developed a position on the disposal of waste in the community.

The RCN strongly supports the local use of option two within HTM 07-01, that an appropriate organisation, either a waste contractor, local authority or the health care provider to collect health care waste (which cannot be put in the domestic waste stream) produced by a nurse in a household environment.

Members need to be aware of their duty of care and the need to assess and segregate waste appropriately and check that arrangements are in place to ensure that waste is collected as per option two.

Information and training on waste management should be delivered to all community based nurses.

As community based health care services expand, waste is likely to grow and become more complex to manage. Health care organisations must have procedures in place to plan and deal with this expansion. Nurses and health care support workers’ time is better spent in the delivery of care rather than making frequent journeys to transport and disposal of waste back at a health care base.

Where option one is used this must be planned in consultation with staff and their representatives and implemented with the agreement of staff. In some circumstances, it may be appropriate to carry small quantities of waste e.g. sharps waste where there is a risk to the householder or others if sharps are left at the site. The safeguards listed in the appendix should be in place.

The RCN, also wishes to point out that this method will add car mileage costs to the health care organisation.

The RCN has raised concerns in relation to option one with the Health and Safety Executive. In response to RCN concerns, the Health and Safety Executive have stated that it would be unacceptable if containers (used to carry clinical waste) leak or allow smells to permeate vehicles.

There is a requirement to ensure that any waste transported in nurses’ cars is segregated permitting ‘dirty and clean’ principals to be in place. This issue is frequently not considered in the context of nursing activities and the use of personal cars which may not permit this due to design constraints of personal vehicles.

Next steps

The RCN is currently involved in discussions on the proposed revision of the community nursing chapter of HTM 07-01 which will be produced later in 2010. Members’ concerns, issues around the definition of infectious waste and logistical difficulties in implementing safe disposal and transport are being raised during this consultation period and we hope that the revised edition will address these concerns.

Further information/advice

Further information on this topic including the assessment and segregation of community waste can be found in HTM 07-01 on the Department of Health website.

Members concerned about the situation in their organisation, including a lack of consultation on changes to the procedures to manage community waste, should discuss the issue with their local RCN safety representative or Regional Officer/Professional Officer for Scotland, Wales and Northern Ireland.

Safeguards if using option one:

Risks of spillages/leaks

An approved rigid leak proof container (following UN packaging instructions P621) must be used to transport sharps and bags of waste in the boot of a vehicle. Spillage kits should be provided and spillage and decontamination procedures should be in place.

Infection control

Waste and waste containers have the potential to contaminate clean equipment and dressings. Procedures should be put in place to regularly clean containers which are being re-used.

Fire extinguishers

There is currently a requirement to carry a fire extinguisher in a vehicle that is carrying small loads of clinical waste.

Training

All health care workers producing clinical waste in a community setting must have appropriate training on the responsibilities of duty holders under the Environment Act; assessing the type of waste and appropriate waste stream and safe storage; transportation and disposal of waste following local policies and spillage/decontamination procedures.

Personal safety/security

Health care workers must be given information on where to dispose of the waste following transportation to a health care building. There may be increased risks associated with lone working and the disposal of waste at isolated health care sites during out of hours/twilight services. Risk assessments should be carried out and any risks to personal safety reduced.

Working hours

Time taken to transport waste to a health care site must be countered into working hours. It is not acceptable for staff to have to take waste home with them at the end of a shift as this presents a risk to other car users and family members.