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Note on specific cases requiring additional consideration

Contaminated material arising after administration of a medicine

a. Secretions, excretions or other body fluids containing cytotoxic and cytostatic medicines. b. Anatomical waste and carcasses containing residual

medicines.

The definition of medicinal waste does not normally include anatomical waste, carcasses, secretions, excretions or other body fluids containing residual quantities of medicine as a result of therapeutic administration to the patient. However, in some circumstances the presence of such substances may prove hazardous to those coming into contact with the waste or may affect disposal options.

Where cytotoxic and cytostatic drugs are involved and the pharmacokinetics of a specific drug are likely to result in the presence of potentially dangerous quantities of an unmetabolised drug in the waste: • the waste description should specifically identify

the presence of such substances;

• the EWC code for cytotoxic and cytostatic drugs (18 01 08* or 18 02 07*) should be assigned to the waste;

• the waste is clinical waste and hazardous waste. Any disposal to foul sewer should be in accordance with trade effluent consent.

Medicinal glassware, aerosols and other containers

Containers (bottles, ampoules, vials etc) used for liquid medicines and powders are normally contaminated with residual quantities of those medicines. Inner packaging used for tablets may or may not be contaminated. If contaminated, containers should be classified and disposed of as waste medicines. Only if rinsed out, in accordance with a trade effluent consent, may they be disposed of as packaging (for example glassware for recycling). Uncontaminated outer packaging may also be recycled.

Medicines in aerosol formulation are not possible to clean out and should be classified as waste medicines (not aerosols). It is not acceptable to discharge liquid medicines to sewer (see paragraph 9.18, ‘Discharge to sewer’).

Step 3

Step 3: Assessment of chemical properties

Note

This section is not provided for use in assessing laboratory chemicals and reagents. It is provided as an overview to support the assessment of other healthcare waste streams that may contain or be contaminated with waste chemicals. The following advice applies for waste chemicals:

• They should not be placed in clinical, offensive or municipal waste streams (in England and Wales such mixing is prohibited).

• They should be segregated and packaged according to transport classifications and chemical

• They should normally be classified as 18 01 06* or 18 01 07 unless they are photochemicals (these are classified under sub-chapter 09 01).

• Hazardous properties should be assessed and classification codes assigned using the procedures set out in WM2.

Chemical containers, unless completely empty (that is, rinsed out), would normally be contaminated and classified as the chemical they contain (ignoring the weight of the container). It is not acceptable to discharge liquid medicines to sewer (see paragraph 9.18, ‘Discharge to sewer’).

Used absorbents and spill-kits for chemical spills should be classified under chapter 15 of the EWC.

4.48 This step assesses each element (components and contaminants) of the waste for chemical properties. The assessment is supported by Figure 6. Each element is classified on the basis of its chemical properties alone as:

• either a clinical or non-clinical waste; and • either hazardous or non-hazardous waste.

4.49 An appropriate EWC code is then assigned.

4.50 The medicinal, infectious and offensive properties of the waste must also be assessed.

Clinical or non-clinical waste

4.51 A waste chemical would not normally be a clinical waste. However, another healthcare waste will be a clinical waste (with reference to the definition in the Controlled Waste Regulations) if it contains or is contaminated with a dangerous substance at sufficient concentration (in the item) to generate a hazardous property.

4.52 If the chemical is not a dangerous substance or is not present in the waste or waste item in sufficient concentration to generate a hazardous property, it will not result in the waste being classified as clinical waste.

Hazardous or non-hazardous waste

4.53 The waste will be classified as hazardous (with reference to the definition in the Hazardous Waste Regulations) if it contains or is contaminated with a dangerous substance at sufficient concentration to generate a hazardous property.

Start (i) Does the waste contain waste chemicals?

(ii) Does the waste contain waste chemicals that are dangerous substances? Assess the waste chemicals for hazardous properties H1–H8 and H10–H14. If yes, the EWC codes 18 01 06* or 18 02 05* should be assigned to the waste.

(iii) Does the waste contain other chemicals?

This element of the waste should be assigned the EWC codes 18 01 07 or 18 02 06.

(iv) Classify the waste for transport. (v) Go to Step 4 of the

assessment framework.

NO

YES

EWC codes

4.54 These are assigned dependent on the source and hazardous status of the waste item as indicated below:

• Human healthcare chemicals (except photochemicals) are classified as 18 01 06* (hazardous) or 18 01 07 (non-hazardous). • Animal healthcare chemicals (except

photochemicals) are classified as 18 02 05* (hazardous) or 18 02 06 (non-hazardous). • Photochemicals (including X-ray) are classified

in chapter 09 of the EWC.

Step 3(i): Are chemicals present in the waste?

4.55 Waste chemicals should never be placed in any clinical, offensive or mixed municipal waste stream. Examples of these include laboratory reagents, auto-analyser cartridges from laboratories and wards, photochemicals, hand gels, disinfectants, cleaning chemicals, and therapeutic chemicals and their contaminated packagings.

Note

Alcohol hand gels that do not contain siloxanes (which cause significant damage to plant and equipment used in the sewage treatment process) and whose safety data sheet (SDS) does not prohibit discharge to the sewer may be rinsed out and the packaging recycled or placed into the municipal waste stream.

4.56 Where these chemicals are present in the waste, changes to segregation should be implemented to prevent this occurring in future. The waste containing them must, in addition to any other classification, be classified with the chemical code(s), and appropriate measures must be taken to describe, package, transport and dispose of the waste at a suitably authorised facility. These are not considered further in this assessment.

4.57 In some instances, clinical waste items may be produced that contain or are contaminated with chemicals. Examples might include:

• anatomical or pathology specimens or samples preserved in chemicals (for example

formaldehyde or alcohol);

• sample vials or diagnostic kits containing chemicals;

• sharps or other clinical waste items

contaminated with therapeutic or laboratory chemicals;

• materials used to clean up biological spills that are contaminated with chemical disinfectants.

4.58 These items are considered further in this assessment.

4.59 Where such items are present, the chemicals (even if only present in small quantities) should be identified in the waste description and composition (a requirement of the consignment note), and the chemical hazardous properties of the item assessed using WM2, as in step 3(ii).

Step 3(ii): Are chemicals containing dangerous substances present in the waste?

4.60 The first step is to identify the chemicals present and whether they are dangerous substances (for example, have they been assigned a chemical risk phrase by Table 3.2 of the classification labelling and packaging regulations (CLP) or associated European databases, or if not by these on a Safety Data Sheet).

4.61 If the chemical(s) present include one or more dangerous substances, the properties and concentrations have to be considered for the relevant hazardous properties using the assessment procedures set out in appendix C of WM2. Where the waste item is a container (for example a sample vial or specimen pot), the weight of the container is normally excluded from the assessment.

4.62 If the item possesses a chemical hazardous property, the waste is a clinical and hazardous waste and should be assigned the 18 01 06* EWC code (or 18 02 05* for animal healthcare) as a result of this part of the assessment. The chemicals and

hazardous properties must be identified in part B of the consignment note.

4.63 If the item does not possess a chemical hazardous property, the waste is not a clinical waste nor a hazardous waste and should be assigned the 18 01 07 EWC code (or 18 02 06 for animal healthcare) as a result of this part of the assessment. If the waste is a hazardous waste due to other components, the chemicals must still be identified in part B of the consignment note.

Step 3(iii): Are other chemicals present in the waste?

4.64 Where the chemicals present in the waste do not possess hazardous properties, this element of the waste is:

• not clinical waste; and • not a hazardous waste

as a result of the assessment of its chemical properties only. Assessment of other properties, or elements of the waste, can alter this status. The presence of the chemical must be described on the accompanying paperwork. The EWC codes 18 01 07 (human healthcare) or 18 02 06 (animal healthcare) should be used.

Step 3(iv): Classification for transport

4.65 The classification of chemicals for transport is beyond the scope of this guidance. Chapter 7, ‘Transport packaging and operations’ contains general advice on transport matters.

Step 4

Step 4: Assessment of infectious properties

4.66 This step provides the assessment for each element (components and contaminants) of the waste for infectious properties. The assessment is supported by a flowchart (see Figure 7). Each element is classified on the basis of its infectious properties alone:

• as clinical and hazardous and dangerous for carriage (typically UN 3291); or

• as non-clinical and non-hazardous and not dangerous for carriage; and

• the appropriate EWC code(s) is/are also indicated.

4.67 This assessment considers:

• the legal definition of clinical waste (the Controlled Waste Regulations);

• appendix C9 of WM2 on the hazardous property “infectious” (H9);

• the definition of infectious substances given in ADR.

Clinical or non-clinical waste

4.68 The waste will be classified as a clinical waste (with reference to the definition in the Controlled Waste Regulations) if it may cause infection to any person

or animal coming into contact with it (that is, if it presents any risk of infection).

Hazardous or non-hazardous waste

4.69 Healthcare waste will always be classified as hazardous (with reference to the definition in the Hazardous Waste Regulations) if it is:

• a clinical waste as indicated elsewhere in step 4 (see ‘Key points’ below);

• dangerous for carriage under UN 3291 or other infectious substance UN number.

Key points:

A clinical waste that is considered infectious for carriage purposes (for example, UN 3291) must

possess the hazardous property H9: Infectious; The only healthcare wastes that can be both clinical and non-hazardous waste are non-cytotoxic and non- cytostatic medicines.

EWC codes

4.70 These are assigned to infectious waste dependent on the source of the waste, as illustrated below: • Infectious waste from human healthcare is

classified as 18 01 03*.

• Infectious waste from animal healthcare is classified as 18 02 02*.

• Non-healthcare-related infectious waste from municipal sources is classified as 20 01 99.

Note: Segregation of infectious and