Jane Renehan on waste management compliance documentation

Jane Renehan, a national expert on dental regulation, answers a question from a reader regarding waste management compliance documentation.

The question – Dear Jane…

In our dental clinic, we take our waste management responsibilities seriously. Nonetheless, we’d value some guidance prior to reviewing and updating our waste management compliance file. What would you advise?

The answer

With any compliance documentation, it’s best to keep it simple, easy to read and in a format that is understandable to both clinical and non-clinical team members. Where possible, use diagrams, one page operator instructions, and easy to complete checklists. 

If you’re unclear where to begin writing compliance documents, going back to first principles is always a good idea. Start by identifying the four pillars of compliance: 

  • Who
  • What
  • Where 
  • How. 

Next, deal with any miscellaneous matters that you have not covered.

1. Who (governance)

The overall legal responsibility and liability for a dental clinic’s waste management lies with the practice owner. 

For efficiency, the day-to-day oversight can be delegated to a named person, such as a practice manager or senior dental nurse. The roles and responsibilities of named persons should be easily identifiable in the practice waste policy document. 

When it comes to managing sharps waste, the legislation is very clear. The person who creates the sharps is identified as being responsible for its safe disposal. For example, following giving an injection, it is the clinician who should dispose of the needle and used local anaesthetic cartridge. 

2. What (waste streams)

Dental practices generate two types of waste:

Healthcare non-risk

Healthcare risk.

When writing your policy, be clear which items you define as non-risk or risk waste. 

Healthcare non-risk waste is not hazardous. It will usually include rubbish generated in the office and kitchen, including items for recycling. Non-risk waste is disposed of by your local general waste disposal and collection services. 

Healthcare risk waste is classified as hazardous and must never be disposed of with general waste. 

Risk waste consists of any substance that can harm human health or the environment because it is explosive, oxidising, flammable, irritant, toxic, carcinogenic, corrosive, infectious, mutagenic, sensitising, or eco-toxic. 

There is a legal obligation on practice owners to ensure that healthcare risk waste is handled and disposed of safely, and in a manner that avoids transmission of potential infection. 

Staff should be aware of the need to exercise personal safety when handling hazardous waste and that using appropriate PPE is essential. Performing hand-hygiene after handling waste is recommended, even when gloves have been worn.

3. Where (bins and storage)

Where possible, waste items should be correctly segregated at the point of origin, according to their waste stream. Bins should be clearly labelled and used for a single waste stream only. They should be solid sided, with a pedal or handsfree operated lid. Bins should be easy to clean both outside and inside. 

Routinely, healthcare non-risk waste bins are white, labelled as general waste and have black plastic bin liners. 

Healthcare risk waste bins, sharps containers, and clinical waste bags are yellow, identified with a biological waste identifying warning sign and satisfy the class 6 UN 3291 standard. 

Both the black and yellow plastic bags should not be filled by more than two-thirds. They should be securely tied when removed from their waste bin. 

Sharp items (see Table 1) must be separated from other risk waste and placed in yellow, puncture-resistant leak-proof sharps containers. Containers should be no more than three-quarters (or beyond the manufacturer’s mark) filled. When not in use, the lid of sharps containers should be in the temporary close position.

Waste awaiting collection must be stored in a secure, safe, dry, and rodent-free area, which the public cannot access. Containers should be vandal-proof, capable of dealing with spillage and easy to handle by staff. 

4. How (communication)

Your waste management policy is designed to demonstrate your practice’s commitment to maintaining a quality, safe and consistent system, that is mindful of the environment. It advises staff of practice-specific procedures and everyone’s obligation to comply. 

Consider if there’s a need to schedule an in-house refresher training session. Awareness of practice waste compliance should form part of induction training for new and locum staff.

Ideally, your documentation and collection receipts should be held centrally in a waste compliance folder. This information should be retained for at least three years and be available to an inspector on request. 

Miscellaneous Items

Once the routine items of risk and non-risk waste have been sorted, any remaining items can be dealt with. You may need to include waste amalgam, extracted teeth, gypsum plaster, pharmaceutical waste, gas canisters, spent chemicals, lead foil, and end of life instruments. 

Discuss how best to deal with these directly with your licensed hazardous waste collector. There are a range of appropriate containers in a variety of sizes to suit your specific needs.

Your waste collector should also be able to provide you with posters illustrating segregation and packaging of healthcare risk and non-risk waste. These types of posters are ideal for demonstrating to an inspector that you are communicating your waste system within the practice. 

Finally

Compliance documentation should always aim to be user-friendly and specific to your practice. If you use sample templates, take care to fully customise them to your particular procedures and premises.

Demonstrating staff’s awareness, their understanding and commitment to your policy and procedures, along with documentary evidence of consistency in compliance, is your goal. 


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