Strategies for sharps disposal to safeguard the health of workers and the wider environment are important considerations for any organisation. Anne Harriss and Angela West examine one NHS trust’s approach to contaminated waste clearance.
Occupational health practitioners (OHPs) acknowledge the effect of work on individuals or groups of workers. Those thinking outside the box recognise that the community outside the confines of the workplace might also be affected by poor hazard control.
Enlightened OHPs, as public health practitioners, should also consider the broader environmental impact of their organisation, particularly with regard to possible emissions into the atmosphere (air), to water via accidental spills, disposal through the sewer system, or to land including waste disposal to landfill.
Waste management is an important consideration within each organisation’s environmental management strategy. Strategies to ensure worker health and environmental management should be designed to work hand in glove in order that they both promote a broader public health strategy.
There are environmental effects linked to many work processes in various organisations, from light and heavy industries to healthcare facilities. The NHS produces a significant amount of hazardous waste particularly clinical waste including contaminated sharps.
This article outlines the approach to the disposal of contaminated sharps undertaken by one NHS trust, because a safe, effective approach to clinical waste management in particular is also a public health issue.
Waste management is covered by the Environmental Protection Act 1990 (EPA). As such, inappropriate waste management in any healthcare facility, whether in hospitals or in primary care settings, including health centres, podiatry and dental surgeries or even OH services, could potentially breach both environmental and general health and safety legislation.
Relevant law includes Regulation 9 of the Workplace Health Safety and Welfare Regulations (1992) and Regulation 6 of the Control of Substances Health Regulations 2002 (as amended) (COSHH). Both sets of legislation relate to waste management and the COSHH Regulations can be applied specifically to exposure to microbial hazards.
Section 34 of the EPA coupled with the Environmental Protection (Duty of Care) Regulations 1991, which are associated with that Act, impose a duty of care on those keeping, treating or disposing of waste, ensuring that waste transfer is undertaken in a suitable container and to a suitable person. Section 45 of the EPA covers the management and collection of hazardous waste that includes healthcare-generated clinical waste.
Marmot (2010) refers to the importance of sustainability. A “Sustainable Development Strategy for the Health, Public Health and Social Care System 2014–2020”, was launched in January 2014 by the Sustainable Development Unit, accountable to NHS England and Public Health England. This details a vision for a sustainable healthcare system by 2020, with a range of strategies including reducing emissions and promoting healthy environments. Waste management is an important element of this sustainability strategy.
The Department of Health (2006) Health Technical Memorandum 07-01 Safe Management of Healthcare Waste provides best-practice guidance on:
- Identifying, classifying and managing healthcare waste.
- Standardising the colour-coding of waste.
- Safe, secure on-site waste storage.
Clinical waste management and subsequent disposal requires a licence from the Environment Agency. In England, the Waste Framework Directive 2008/98/EC includes a hierarchy of approaches to managing waste.
Peterborough and Stamford Hospitals NHS Foundation Trust wished to determine the environmental effects and sustainability of its waste management strategy and focused on safe disposal of sharps and reduce its environmental impact. Previously, when full, the entire sharps bin unit was incinerated.
The trust recognised the emissions to air associated with the incineration of these bins and sought to reduce the amount of waste that it sent for incineration. In 2012, it changed its approach to the disposal of sharps containers.
A decision was made to dispose of sharps in re-usable sharp-care containers. This provided an environmentally friendly and cost-effective process. Staff safety remained paramount: the bins were designed to reduce the incidence of accidental inoculation injuries.
Further benefits included:
- a reduction in carbon emissions and its carbon footprint;
- enhancement of the trust’s environmental credentials;
- an enhanced approach to sustainability; and
- compliance with the sharps Instruments in healthcare Regulations (2013).
An unexpected bonus of the introduction of these bins was an almost instant fall in the number of inoculation injuries. Previously a frequent cause of injury was pierced or over-filled bins. The sharp-care bins have a tip-tray aperture; used sharps are placed onto a tray which then tips them into the container. The tray aperture design prevents overfilling the container and thus accidental inoculation injuries.
An additional benefit is that users cannot put their hands into the bin because once the maximum level is achieved the container automatically locks with a tamper-proof mechanism. Fill-levels are visible via a window on the container. Once locked, containers are bar-coded for tracking and then sent to a sharp-care plant where they are emptied, washed and disinfected. The contents of the bins are sent for incineration. Each container has a 10-year life span and will be washed 400 times.
Since implementing this system in 2012 the trust has reduced its carbon emissions and its carbon footprint by 82.8 tonnes per year. Furthermore, 14.84 tonnes of plastic have been diverted from incineration. This has removed more than 44,000 kilos of single-use plastic bins from the sharps waste stream preventing more than 248 tonnes of carbon emissions.
The 10-year life span of each container results in the trust needing no more containers until 2022, a further carbon reduction of 750 tonnes. Reusable sharps bins have been used by this trust for more than three years.
Infection control was an important consideration when instigating this strategy. The new bins undergo a six-stage washing and disinfection process (as highlighted in box p.28 above). All stages are continuously monitored ensuring that temperatures and cycle times are maintained at the required level.
Each bin unit is bar-coded to confirm a thorough history of the clinical area in which the bin has been used and the frequency and number of times it has been cleaned and disinfected. After a bin has been through 400 cycles confirmed by the bar-code labelling system, the whole unit is sent for recycling, making the practice as environmentally friendly as possible.
The number of washes required to ensure the bins are clean and no longer run the risk of causing an infection is heavily dependent on how much water is used. Reducing both the amount of water and the power consumption is an important consideration within the cleaning process.
In addition to using steam processes, “grey” water from the final two stages is recycled for use within the first stage, an initial cold jet wash removes any detritus from the bins. Each cycle lasts eight minutes, and 16 bins are accommodated within the machine at any one time.
The bin management company has a clear commitment to reducing carbon emissions and is in line with the NHS carbon reduction strategy, which encourages the NHS to drive change toward a low carbon society. The strategy illustrates the scale of carbon reduction required for the NHS to progress to the requirements of the Climate Change Act (2008).
The Good Corporate Citizenship Model, revised in 2009 by the Sustainable Development Unit and the Department of Health, provides a self-assessment tool for NHS organisations supporting them to assess, measure and make improvements on their efforts towards sustainable development.
One of the six areas of the assessment incorporates facilities management, in which waste management comfortably sits. Active engagement with this model has a positive impact on improving community public health and may also have financial benefits.
By changing the management of clinical waste from single-use bins to fully reusable/recyclable bins, the trust reduces the amount of waste it produces. Significantly, every part of the bin is recyclable and should constituent parts become substandard, then they can be replaced and any damaged parts can be recycled. This in turn avoids recycling the whole unit.
The disinfection process is totally enclosed and water spray or mist is extracted via local exhaust ventilation that is continuously monitored for its effectiveness. This process ensures that there are no releases into the immediate or local environment.
The process of bin disinfection ends with quality control checks on every container. The barcode of each bin is re-scanned and the wash cycle is recorded before the bin is returned to the hospital. This barcode system forms an integral part of the company’s ongoing auditing procedures and records the number of times the container has been used, emptied and cleaned.
The detergent used in the cleaning process is similar to those used in domestic dishwashers. Potential emissions to air associated with the use of these materials are controlled adequately by correct use in line with the materials data sheet guidance and compliance with the COSHH Regulations.
The bin management company has a consent-to-discharge permit, allowing it to discharge the large quantities of waste water used within this process through the foul sewers. This permit is issued and monitored by the Environment Agency (EA). The company conducts monthly water sampling of the foul sewers, and the EA undertakes sampling on a quarterly basis.
All records of monitoring are kept and there has never been a recording outside acceptable limits. The company is committed to minimising the amount of water used during the process, by using a steam process, a high-speed spinning process, and recycling water during the process where possible.
The bin management company is fully compliant with legislation, and also with the standards expected to ensure continuing accreditation to environmental management and quality assurance standards: ISO14001 and ISO9001 respectively.
All the control measures employed by the bin management company are clearly recorded, monitored and implemented.
The introduction of the system is a positive step, both in terms of a reduction in the number of inoculation injuries and in the demonstration of a pro-active approach to environmental management. Effective environmental and waste management strategies are important aspects of public health and the NHS – as one of Europe’s largest employers – should demonstrate best practice.
In November 2015, the trust, along with the waste management company processing these containers, scooped a gold Green Apple Award, in recognition of excellence within its approach to environmental best practice.
The Green Apple Awards began in 1994, and are organised by the Green Organisation, an environmental group supported by the EA, the Chartered Institute of Environmental Health and the Chartered Institute for Waste Management.
It would be a giant leap forward if other trusts followed their lead.
Marmot and others (2010). Fair Society Healthy Lives. London: The Marmot Review.