Pre-acceptance Waste Audits
Pre-acceptance waste audits
ISSL has been conducting pre-acceptance audits on behalf of both waste producers and waste contractors for several years. The format and subsequent report that ISSL has developed for pre-acceptance waste audits has been recognised as meeting the stringent requirements of S5 07 (version 1.1) and Safe Management Healthcare Waste (2012). Furthermore, the structure of the reports allows organisations to easily identify where actions are required and prioritise them accordingly. This has been crucial in the development of action plans in order to address areas of non compliance in a timely manner.
Why do we need to do it?
All waste producers have a statutory Duty of Care to ensure that the waste they produce, handle, treat, dispose and transport is done so safely. Under the Duty of Care, producers must provide the person who is collecting the waste with the required information to ensure they are authorised to accept and treat the waste. The Duty of care also requires waste producers to provide the waste contractor with information on the quantity of waste, the EWC codes, how it is packed and the constituents and types of waste.
The Environment Agency produced a guide for waste producers and waste contractors to enable them to discharge their legal duties. This document is called Clinical Waste EPR5 07 (version 1.1) and outlines the waste producers’ and waste contractors’ responsibility for monitoring and controlling waste. It also gives clear audit criteria and the frequency the audits are to be undertaken.
Waste Pre-Acceptance – What is it?
Procedures undertaken prior to the delivery of the waste to the disposal site, to determine the composition of the waste by audit of original waste producer. It provides the waste contractor with information and checks to ensure that their waste treatment facility can safely dispose of the waste and therefore, meet its pre-acceptance criteria.
How Frequently do I need to audit my site?
Frequency of the audit and the information required depends on the volume of clinical waste produced annually and the type of waste producer. The table below gives an indication of the timescales and frequency of audits.
Frequency of Pre-acceptance audits for waste producers
Volume of waste
Initial audit to be completed by:
Frequency of audit after initial audit completed
**All healthcare providers ≥ 5 tonnes/annum November 2011 Initial audit should be of entire hospital/site. Thereafter if results of audit show compliance hospital/site can audit 1/3 of premises including high risk areas on a 12 month rolling regime. If non compliant whole site will require re-auditing. Higher Risk Waste ProducersDentists, Vets, Research laboratories ≤ 5 tonnes/annum March 2012 Audit of entire site. Thereafter audit entire site every 2 years Lower Risk Waste ProducersOther medical practices engaged in general practice consultation and treatment in the field of general and specialised medicine by GP’s, medical specialists and surgeons.(SIC 2003 85.12) ≤ 5 tonnes/annum 1st July 2011 Entire site every 5 years Other medical practices not involving hospitals or practising medical doctors, including paramedical practitioners legally recognised to treat patients. (SIC 2003 85.14) ≤ 5 tonnes/annum 1st July 2012 Entire site every 5 years Community Pharmacies ≤ 5 tonnes/annum 1st July 2013 Entire site every 5 years Care Homes nursing or medical ≤ 5 tonnes/annum 1st July 2013 Entire site every 5 years Any healthcare waste producer not wholly or partially encompassed by the above ≤ 5 tonnes/annum 1st July 2012 Entire site every 5 years
Full details of the timescale and rational for compliance for undertaking pre-acceptance waste audits can be found on the Environment Agency Website.
The carriage of dangerous goods is a complex and strictly regulated operation.
Carriers and Consignors (senders) of dangerous goods are required by the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 to appoint an examination qualified Dangerous Goods Safety Advisor (DGSA).
Independent Safety Services Limited acts as DGSA for numerous organisations throughout the UK. Commercial clients include Frontier Medical Group (www.frontier-group.co.uk), which ISSL works with on dangerous goods services, ensuring that clinical waste packaging is fully compliant with the requirements of dangerous goods legislation (ADR 2015).
We offer a comprehensive solution to all dangerous goods transportation issues, including radioactives and infectious materials.
Dangerous Goods Safety Advisory (DGSA) Services:
- Full dangerous goods advisory services
- Comprehensive auditing of all dangerous goods related activities
- Completion of annual reports
- Contractor auditing
- Advice on development of new products designed to carry dangerous goods
- Assistance with reportable incidents concerning dangerous goods
- Development of dangerous goods policies and procedures
- DGSA, ADR and ‘general awareness’ training and implementation
Waste management can be a complex issue. Our consultants at Independent Safety Services Limited can offer advice on resource efficiency and management of a wide range of wastes, from recycling to hazardous chemicals. Independent Safety Services Limited has a proven track record for supplying high quality consultancy to the healthcare sector and has been delivering waste management and dangerous goods services to healthcare providers since 2001. Clients include hospitals, primary care trusts, mental health institutions, prison services, teaching hospitals and medical research laboratories.
Providing a ‘one stop shop’ for comprehensive auditing, training and consultancy services, our team of specialist consultants have expertise in the field of healthcare waste including research and operational experience. In addition to their healthcare waste expertise, all our consultants are exam qualified Dangerous Goods Safety Advisers (DGSA) and are CRB checked.
They are aware of the legislation that affects the management and movement of waste including:
- environment and waste legislation
- health and safety legislation
- transport legislation (Road, Rail, Air & Sea)
We have an established relationship in the United Kingdom with the National Health Service (NHS) as well as the private sector and have experience undertaking work internationally.
As a company we offer round the clock advice and support for our clients. All our advice is totally independent as we have no affiliations to any specific suppliers of services to the industry. As independent advisers we are able to advise on the most appropriate transport, packaging and waste disposal services without conflict of interest or commercial gain.
These services are offered by Independent Safety Services Limited and their sister company Peak HSE (www.peakhse.co.uk).
The effective Management of Environmental issues is a key strategic & operational goal for many organisations. Whether the main aim is legal compliance, best practice or simply cost saving we can offer professional expert support & guidance. We are committed to developing systems and giving advice that are both practical and proportionate to the organisation’s risks and goals. Developing robust management systems with specialist support as required will help protect the environment & your organisation.
Areas in which we can offer support and guidance are as follows:
- Environmental Management Systems
- CRC Support
- Waste Management
- Permit Applications & Variations
Retained Health and Safety Consultancy
The Management of Health and Safety at Work Regulations place a specific duty on employers to provide and maintain health and safety advisory support within their business to ensure best practice and safe working environments.
Independent Safety Services Limited provides a bespoke consultancy service to businesses that do not have their own internal safety professional or for larger companies which have their own safety support but need additional assistance.
The standard retained service agreement includes an initial Health and Safety audit on management systems, process controls and site performance. The retained service specification will detail the services available.
Working at Height
This service is provided by our sister company, Safety & Access Limited.
The Work at Height Regulations 2005 brought a new, single set of regulations to the UK, covering work at height activities for all businesses. The HSE reports that over 4,000 employees suffered a major injury as a result of a fall from height in 2008/09.
It is important to understand that these regulations apply not just to Construction but all sectors of business and all sizes of business, including many that may not have considered that they have a work at height issue. Examples where businesses have not considered their work at height issues include:
- Access to and from the back of a lorry for deliveries
- Putting posters up (eg: in a school), using a chair for access is not acceptable
- Simple maintenance tasks (eg: window cleaning, cleaning leaves out of gutters, painting edges of flat roofs, from the roof)
- Control of contractors working at height on clients’ premises
The regulations require every business to:
- Avoid work at height if possible
- Prevent falls by using suitable means of working at height, if work at height is unavoidable, and if so,
- Mitigate the consequences or distance of any potential fall.
The regulations also require businesses to consider the need for collective protection over personal protection (for example, guardrails which protect everyone are more significant than harnesses which protect individuals, particularly important when working on roofs).
Work at Height must also be properly organised, planned and supervised by people who are competent and knowledgeable enough to select the safest solution. Does your business have a competent person?
With many years experience of providing advice to clients on work at height issues, we are uniquely placed to deliver a wide range of services, including:
- Work at Height safety audits
- Development of Work at Height specifications and procedures
- Work at Height planning, co-ordination and supervision – including the pre-contract planning of major projects
- Work at Height training needs analysis
We also have specific expertise relating to Scaffolding.