The draft Waste Management Paper (WMP) comes ten years after the first edition was issued by the DoE. Since then the Environmental Protection Act 1990 has introduced tougher standards for clinical waste incinerators and the "duty of care" on waste producers. And at EC level, clinical waste management practices are now under scrutiny in one of the European Commission's "priority waste stream" projects (ENDS Report 222, p 42 ).
Through this EC connection the DoE has discovered that the UK produces ten times as much clinical waste per head as Germany and twice as much as Ireland. The DoE believes this is because half of the 309,000 tonnes of "clinical waste" generated annually in the UK consists of material which should not be in the clinical waste stream. Many hospitals still use yellow bags for all their waste, rather than separating waste of a non-clinical nature into normal black bags to be disposed of as municipal waste.
This practice is costly. The disposal cost for clinical waste is £200-300 per tonne. For municipal waste it is £20-50 per tonne. Until recently incineration was virtually free because of the low standards of many NHS incinerators and the lack of incentive to segregate non-risk waste under the prevailing financial arrangements in the NHS. Today, with hospitals more responsible for their finances, the cost savings from segregation are more self-evident.
The draft WMP therefore places greater emphasis on segregation than its predecessor. But the National Association of Waste Disposal Contractors (NAWDC) has warned that the guidance "fails to take account of the serious problems which can be caused by improper segregation of clinical wastes from non-clinical wastes. NAWDC has little confidence in the ability of many health service managers to achieve simple segregation of clinical waste." Until the effectiveness of segregation programmes is proved, NAWDC believes that they should not be encouraged.
Members of NAWDC collect clinical waste and some operate the incinerators which burn it. Inadequate segregation can put their employees at risk. But improved segregation would also reduce its members' income from incinerators.
The segregation debate extends beyond the non-hazardous waste from hospitals. The draft WMP says that some actual clinical waste can be collected in labelled black bags for disposal in landfills not licensed to take clinical waste - unlike the previous guidance. This applies to Group E waste - items such as disposable bed pans, incontinence pads and urine containers. The DoE explains that "it is difficult to justify special disposal or treatment for Grade E waste when similar material is routinely landfilled."
NAWDC has condemned this statement, arguing that all Group E waste should be treated as clinical waste because it is "at the very least offensive and can also be hazardous." The use of black bags for Group E wastes is unacceptable, it says. But with the DoE's drive to reduce clinical waste volumes and to treat similar wastes from domestic and hospital sources on the same basis, NAWDC is unlikely to be win on this issue.
The WMP also provides advice on treatment methods such as autoclaving and microwave technology which render wastes non-hazardous and suitable for landfilling. Several of these techniques, it says, may have lesser environmental impacts or lower costs than incineration. A microwave heat treatment facility, for example, could cost £200,000 compared with an incinerator of £2 million of equivalent throughput.
The main obstacle to treatment technologies is the lack of certifiable procedures and protocols to minimise operator risk and ensure that waste is consistently rendered non-hazardous, the WMP says. NAWDC concurs, but believes that the point should be made more forcibly.
The guidance also encourages waste prevention, recycling and reuse. Prevention is the most effective way to reduce the waste problem, it says. Eliminating excessive packaging, matching units of issue to local requirements, and requiring the take-back of transport packaging are among the options.
However, NAWDC is not in favour of reuse or recycling of clinical waste. It says that the WMP's statements in favour of both were inserted "on the grounds of environmental pollical correctness rather than for sound waste management reasons." There is little evidence that hospitals can establish safe and effective reuse programmes, it says.
But other EC countries have had experience in reuse and recycling and expect to expand these routes as clinical waste management options. This is shown in the targets being put forward in the work of the priority waste stream group (see figure). Reuse and recycling are both expected to increase from 5% in 1992 to 10% in 2010. Incineration with energy recovery and treatment are also expected to increase, with landfill and incineration declining.
The priority waste stream project is due to be completed at the end of the year. Its output will include an overview document on the current state of health care waste streams and management systems, and a strategy paper containing broad targets and recommendations to the European Commission for legislation. It will then be for the Commission to take the initiative forward.