What is a Pre-Acceptance Waste Audit?
The Environment Agency requires that producers of waste must provide an audit of their waste before it can be legally collected by a licensed waste carrier. This is known as a pre-acceptance audit.
Your audit should include:
• Quantity and types of waste
• European Waste Catalogue code (EWC),
• Size and container type (how your waste is packaged including components within the waste)
Providing above information as part of your pre-acceptance audit will enable your waste contractor to decide whether they can safely dispose of the waste, the audit should also help you to meet your duty of care obligations.
Who should prepare a pre-acceptance audit?
The person carrying out the audit should be someone with a working knowledge of HMT 07 01 and its successor SMHW V2 www.gov.uk/government/publications/guidance-on-the-safe-management-of-healthcare-waste. There are many ways to undertake an audit;
• You can collect and compile the Waste Audit information yourself provided you understand what is required before doing so, and can provide sufficient information to your waste contractor that allows them to access whether the waste you are describing will be accepted at a waste disposal site, in accordance its environmental permit.)
• You can employ a specialist third party to collect the data on your behalf and produce an audit.
• You can ask your waste contractor, many offer this as a service for a small charge, alternatively your waste contractor may assist you with guidance.
The types of organisations and businesses who should have waste audits include but are not limited to;
• Care homes that provide medical or nursing care
• Dental practices
• GP surgeries and health centres
• Veterinary practices
• Community pharmacies
• Ambulance Trusts
• Research laboratories that produce clinical waste
• Pharmaceutical manufacture and supply
• Any other medical practices
Are Pre-Acceptance Audits a Legal Requirement?
Yes, audits are a requirement if your waste is sent to an alternative treatment plant or clinical waste incinerator for disposal (even if via a waste transfer station) you must provide your waste contractor with pre-acceptance information. If you do not provide the information and therefore breach your duty of care, the Environment Agency can take enforcement action. In addition, the operator of the clinical waste alternative treatment plant, clinical waste incinerator or IPPC transfer stations may no longer be able to accept your waste onto their site and your waste contractor may be unable to collect your waste as a result.
For more information on pre-acceptance audits contact Principal Hygiene Ltd on 0843 309 2180
Hazardous Waste How to Control the Risk?
Clearly, the control measures adopted will depend on the type and quantity of hazardous waste involved. However, under the waste management hierarchy and COSHH, the first matter to consider would be risk control through “prevention”. By designing out the use of materials or processes that produce hazardous waste, organisations can eliminate the source of the waste.
This can be a low-cost option with immediate payback, removing the need for the disposal of hazardous materials in the future and protecting employees involved with the handling or transport operations. Where prevention is not possible, control activities can be broken down into a number of areas, these being waste minimisation, handling, storage and collection. Minimisation could take place by changing products used, by changing processes or by re-cycling/re-using materials and substances.
For handling, storage and collection, a number of aspects should be critically examined;
• Hazardous waste segregation; Are hazardous wastes segregated into appropriate categories based on classification and assessment?
• Containers; Are appropriate receptacles used for the storage? Are the containers sensibly located and suitably labelled?
• Storage areas; How and where are the wastes stored? How long are wastes stored prior to transport and disposal?
• Waste handling; Are hazardous wastes handled in a safe manner with due attention to any associated hazard? Do we inform contractors handling waste of the risks?
• Documentation and records; Are adequate records kept of all wastes produced and of their safe and correct transfer/disposal?
• Emergency procedures; What emergency procedures are in place for implementing in the event of an unwanted incident? Is there a pollution control plan for emergency situations?
• Staff safety; Are employees made aware of the hazards of the waste? Are adequate safety equipment and systems provided? Are staff members made aware of segregation requirements and arrangements?
Under the duty of care, organisations have a responsibility to take reasonable steps to ensure that no other persons illegally treat, keep, deposit or otherwise dispose of hazardous waste. What the waste producer must do to ensure that waste is disposed of properly and safely when passed onto another party is open to interpretation.
According to the Environment Agency Code of Practice for the duty of care, “it is not possible to draw a line at the gate of the producer’s premises and say that their responsibility for waste ends there. A producer is responsible according to what he knows or should have foreseen”.
In practice, organisations should ensure that any hazardous waste to be carried is properly and securely packed for transport and notice taken of the carriers handling of the waste. If the producer ignores the illegal handling or treatment of their waste, the blame (and consequent punishment) can be shared.
Call the experts
As a waste producer do you know if you are compliant? Do you know how effective or if your waste disposal service represents value for money? Not sure? Then talk to Principal Hygiene we can help you with advice and support ensuring you have the right services in place that delivers value for money, is compliant and meets your waste disposal needs.
Get a Clinical quote today or call us to discuss further, if you are unsure about the type of container you should be using or you have a mixed waste stream call us, we are on hand to provide advice and support.
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