&Views

Addenbrooke's NHS Trust
Estates and Facilities Dept.
Box 129, Hills Road,Cambridge
Cambridgeshire CB2 2QQ
http://www.addenbrookes.nhs.uk
Tel: 01223 217193 Fax: 01223 217220
Contact: Mrs Vicki Ayers
victoria.ayers@addenbrookes.nhs.uk
Albany Washroom Services
15 Brook Road
Brook Road Industrial Estate
Rayleigh, Essex SS6 7UT
http://www.albanyfacilities.com
Tel: 0870 366 5777 Fax: 0870 366 5778
Contact: Mr Mike Burton
enquiries@albanyfacilities.com
Amcor Flexibles / SPS Laboratories
Winterbourne Road
Stoke Gifford, Bristol BS34 8PT
http://www.sharpakforsharps.co.uk
Tel: 0117 983 6000 Fax: 0117 983 6001
Contact: Mr. David Scarrow
David.Scarrow@Amcor-Flexibles.com
Blue Cross Hygiene Ltd
3 Blackstaff Way
Kennedy Way Industrial Estate
Belfast BT11 9DT
http://www.groveservices.com
Tel: 02890 431888 Fax: 02890 431666
Contact: Ms. Jennie Black
hygiene@groveservices.com
Brimaid Ltd
15 High Ridge Way
Radbrook, Shrewsbury SY3 6DJ
http://www.brimaid.co.uk
Tel: 01743 351443 Fax: 01743 351443
Contact: Mr Mel Turner
melturner@tiscali.co.uk
GW Butler Ltd
Bowling Iron Works
Bowling Back Lane
Bradford BD4 8GG
Tel: 01274 722761 Fax: 01274 681332
Contact: Mr. Paul Butler
pbutler@gwbutler.co.uk
Cannon Hygiene Ltd
Northgate House, White Lund,
Morecambe, Lancashire LA3 3BJ
http://www.cannonhygiene.co.uk
Tel: 01524 595384 Fax: 01524 4443938
Contact: Mr Dave Dingle
dave.dingle@cannonhygiene.com
Cathedral Hygiene Services
Building 300, Relay Point
Relay Drive, Tamworth
Staffs. B77 5PA
http://www.hygieneservices.co.uk
Tel: 01827 263910 Fax: 01827 263911
Contact: Mr. Tom Gooder
CHS@building300.com
Cliniserve Ltd
Vinnetrow Road
Vinnetrow Business Park
Chichester, West Sussex PO20 6QH
http://www.cliniserve.co.uk
Tel: 01243 782288 Fax: 01243 784488
Contact: Mr. James Geary
sales@cliniserve.co.uk
Compact Power Ltd
Hydro House, St. Andrews Road
Avonmouth, Bristol BS11 9HZ
http://www.compactpower.co.uk
Tel: 0117 980 2900 Fax: 0117 980 2901
Contact: Mrs. Celia McAllister
c_mcallister@compactpower.co.uk
Craemer Environmental Systems Ltd
23 Gladstone House, Hadley, Telford
Shropshire TF1 4NF
http://www.kliko.co.uk
Tel: 01952 641366 Fax: 01952 641766
Contact: Mr. Clive Hames
clive@kliko.co.uk
Daniels Healthcare Ltd
Honours, 72 - 80 Akeman Street
Tring, Herts HP23 6AJ
http://www.daniels.co.uk
Tel: 01442 826881 Fax: 01442 826880
Contact: Ms Dee Ward
dee@Daniels.co.uk
Enviros
61, The Shore, Leith Edingburgh, EH6 6RA
http://www.enviros.com
Tel: 0131 555 9533 Fax: 0131 555 9515
Contact: Ms. Wendy Rayner
wendy.rayner@enviros.com
Griffiths and Nielsen Ltd
Wyvern House, 49 Station Road
Billingshurst, Sussex RH14 9SE
http://www.g-and-n.co.uk
Tel: 01403 784881 Fax: 01403 784988
Contact: Mr Giles Griffiths
giles@g-and-n.co.uk
Grundon Waste Management Ltd
Lakeside Road, Colnbrook
Berkshire SL3 0EG
http://www.grundon.com
Tel: 01753 686777 Fax: 01753 686002
Contact: Mr. Andrew Stratton
clinical@grundon.com
Icomed Ltd
Unit 2A Heathfarm, Swerford
Chipping Norton, Oxfordshire OX7 4BN
http://www.icomed.co.uk
Tel: 01608 683939 Fax: 01608 683940
Contact: Mr. John Ely
ico@icomed.co.uk
Mauser Benelux B.V.
Souvereinstraat 1 Postbus 235
4900AE, Oosterhout, Netherlands
http://www.mauser-group.com
Tel: (31) 162 483700 Fax: (31) 162 483750
Contact: Mr Kees Vredevoort
kees.vredevoort@mausergroup.com
NHS Estates (Honorary)
1 Trevelyn Square, Boar Lane
Leeds LS1 6AE
Tel: 0113 254 7000 Fax: 0113 254 7299
Contact: Mr. Brian Latham
Peake (GB) Ltd
Stoneybridge, Liskeard
Cornwall PL14 3NQ
http://www.peake-gb.co.uk
Tel: 01579 342212 Fax: 01579 344520
Contact: Mr. Richard Brenton
rb@peake-gb.co.uk
PHS Group plc
Western Industrial Estate
Caerphilly CF83 1XH
http://www.phs.co.uk
Tel: 029 2085 1000 Fax: 029 2086 3288
Contact: Mr Dean Williams
deanwilliams@phs.co.uk
Plastic Omnium Urban Systems Ltd
Plastic Omnium House
Tweedale Industrial Estate
Madeley, Telford, Shropshire TF7 4JR
http://www.pourbansystems.com/uk
Tel.: 01952 582 583 Fax: 01952 586 453
Contact: Ms Gill Denbeigh
gdenbeigh@plasticomnium.com
Polkacrest Ltd
Platt Industrial Estate, Maidstone Road
Platt, Sevenoaks, Kent TN15 8JN
http://www.polkacrest.co.uk
Tel: 01732 880910 Fax: 01732 880900
Contact: Mr. Alex Marland
alex.marland@polkacrest.co.uk
Rentokil Initial plc
Felcourt, East Grinstead
West Sussex RH19 2JY
http://www.rentokil-initial.co.uk
Tel: 01342 833022 Fax: 01342 326229
Contact: Mr Ian Pepper/Mrs Sonja Stewart
ipepper@r-d.rentokil-initial.co.uk
Sterile Technology Group Ltd
Technical and Operations Centre
Waterside House, Waterside Industrial Park
Smiths Road, Bolton BL3 2QJ
http://www.bfhgroup.co.uk
Tel: 01204 544110 Fax: 01204 544120
Contact: Mr. John Hancock
johnhancock@steriletech.co.uk
Egbert H Taylor & Co Ltd
Oak Park , Ryelands Lane
Elmley Lovett , Worcestershire WR9 0QZ
http://www.taylor-ch.co.uk
Tel: 01299 251333 Fax: 01299 254142
Contact: Mr. Andy Howorth
custserv@taylor-ch.co.uk
Tyseley Waste Disposal Ltd
James Road, Tyseley, Birmingham B11 2BA
http://www.onyxgroup.co.uk
Tel: 0121 680 2000 Fax: 0121 680 2051
Contact: Mr. Steve Mitchell
smitchell@onyxgroup.co.uk
White Rose Environmental Ltd
Head Office, PO Box 63, Leeds LS9 0XH
http://www.WhiteRoseEnvironmental.com
Tel: 0845 124 2020 Fax: 0113 235 1286
Contact: Mr David Hughes
customer.services@WhiteRoseEnvironmental.com
Sanitary Medical Disposal
Services Association
Office and Secretary, 111 Wollaston Road,
Irchester,Northants NN29 7DD
http://www.smdsa.com
Tel: 01933 311223 Fax: 01933 311223
Contact: Mr Martin Foulser
info@smdsa.com
Every effort is made to ensure that the information given herein is accurate, but no legal responsibility is accepted for any errors, omissions or
misleading statements in that information caused by negligence or otherwise, and no responsibility is accepted in regard to the
standing of any firms, companies or individuals mentioned.
Designed and produced by Shire Publicity Limited - Tel: 01933 275475
Issue Five
In Part 1 of a series of articles Dave Dingle explains the new
requirements for Producers, Carriers and Disposers of Hazardous
Wastes – turn to page 4
Nick Davis - Frontier Medical Products
Sharp pricing increases for polypropylene (the raw material commonly used in the
manufacture of plastic containers) have driven manufacturing costs to the highest
level in recent years. With material price increases of as much as 60% in the last six
months alone, container manufacturers are experiencing severe pressure on their
margins.
These price rises are associated with escalating oil prices and the demand/supply
balance in the commodity market. In particular the exploding demand for plastics in
the Far East, particularly China, has resulted in shortages of material supply in Europe
which in turn has been a factor in driving prices up.
Consequently, the buyers’ market of recent years has been transformed by these
changes into a sellers’ market, where the material producers now ‘call the shots’ –
dictating what they will and will not supply at different pricing levels. Furthermore,
the stability derived from long term contracts has now been turned on its head, with
manufacturers being increasingly forced to buy on the spot-market (an international
market in which commodity products are traded for immediate delivery at the
current price).
With these increasing material cost pressures and little opportunity to offset these
with increased production efficiencies, it is likely that container manufacturers will be
forced to share the problem with end users through finished product price increases.
news &
Views
Spring 2005
ALL CHANGE AT THE TOP OF SMDSA
Norman Haworth
One of the key founding fathers of the SMDSA, Norman Haworth, retired in
2004. Norman was Chairman of Cannon Hygiene Ltd after rising through the
ranks during a career lasting 49 years with the company in which he pioneered
the exchange unit service. In 1993 he was the architect who, together with the
Directors of PHS, formed the SMDSA and he remained a Director until his retirement
in 2004. The members would like to thank him for his tireless contribution to this industry
and wish him a long and active retirement. Norman’s position as Director of SMDSA has
been taken up by Marshall Beach, Cannon Hygiene.
Louis Howe
We should also like to express special thanks to Louis Howe who has stepped
down as Chairman and Director of the Association after nearly 10 years. The
Association owes much to Louis’ efforts to raise the profile from a small ‘club’ of
companies to the professional organization it has become today with over 40
member companies representing a majority of hygiene service and waste contractors
in the Healthcare sector and more than 96% of clinical treatment and disposal capacity in
the UK. In addition, the Association has welcomed a series of members who play an equally
important role in this industry from container and packaging manufacturers and
distributors to analytical services and environmental consultancy. Louis is particularly
responsible for gaining significant recognition for the SMDSA within government and
regulatory bodies and ensuring that the voice of the smallest operator in the sector can be
heard in the corridors of Whitehall and beyond. Through Louis’ guidance and direction
SMDSA representatives are now frequently invited as experts within the sector onto
technical working groups and assist in writing relevant guidance for the industry and NHS.
Dr Nick Williams, Safety Health and Environmental Manager, PHS Group plc has been
appointed as a Director of SMDSA.
Andy Stratton
We are pleased to welcome Andy Stratton as our new Chairman. Andy has
picked up the chalice of providing new vision and direction to the SMDSA.
Previously full membership was restricted to companies with an established
long trading record. Creating an opportunity for new and start-up companies to
access the knowledge and expertise contained within the SMDSA through Associate
Membership will help to ensure that young companies are able to understand and comply
with the constant changes in Regulation so that they can continue to develop and
contribute to the raising of standards within the industry as full members.
“It is fundamental to us that every member has an opportunity to raise subjects for
discussion at our quarterly meetings, regardless of their company size and market share
and we will strive to maintain a balance of technical input and straight forward
interpretation of legislation and guidelines, to ensure the meetings have value to all
members. Recently we have decided to further raise the profile of the Association through
active participation in exhibitions and the expansion of our ‘public’ web site to provide
access to more information externally.”
Is Orange the new Yellow ?
It sounds like a fashion trend but there is more to it than that! The use of
orange bags for clinical waste is likely to increase in the future. The use of
orange bags started a number of years ago in Scotland where the NHS have
chosen to use different coloured bags to differentiate between types of clinical
waste depending on the most appropriate treatment and disposal route. A number of
Health Boards in Scotland now only use yellow bags for waste that requires disposal by
high temperature destruction and they use orange bags for waste that can be safely
treated in alternative technology (non-incineration) facilities.
With the growing use of alternative technologies throughout the UK (more that 50% of
the UK’s clinical waste is treated this way) we may see the introduction of the orange bag
system UK wide. Whilst there is no legal requirement for producers to use orange bags for
wastes suited to low temperature treatment, it is likely that the colour coding systems will
be introduced into new industry guidance later this year, following agreement of SMDSA
members, producers and regulators. However, producers should discuss with their waste
contractors before changing segregation systems. In the mean time watch this space and
we will let you know if the idea takes off south of the border.

Dr. N Williams
PHS Group plc
In issues 3 and 4 of this newsletter, we published
guidance on the requirements for carrying clinical
and pharmaceutical wastes by road. Dr Nick Williams
provides an update to the changes during 2004 and
anticipates further changes this summer. A full review
of the definitions of Infectious substances will follow
in the next issue.
The Carriage of Dangerous Goods and Use of
Transportable Pressure Equipment Regulations
2004 (CDGTPE)
The CDGTPE Regulations 2004 apply to the carriage
of dangerous goods by road and rail. They place
general duties on everyone with a role in the carriage
of dangerous goods, and specific duties on those in
the transport chain, i.e. consignors, loaders, packers
etc.
The Regulations refer to the European Agreement
concerning the International Carriage of Dangerous
Goods by Road 2003 (ADR 2003) and Regulations
concerning the International Carriage of Dangerous
Goods by Rail 2003 (RID 2003). The Regulations also
implement a further Directive on transportable
pressure equipment. They replace, by a single
Statutory Instrument (SI), twelve previous SI’s that
regulated carriage of dangerous goods by road and
rail in Great Britain (GB).
The GB Regulations will only apply in England,
Scotland and Wales. Northern Ireland have their own
Regulations similar to the GB Regulations.
Changes in CDGTPE 2004
Under The Carriage of Dangerous Goods by Road
Regulations 1996 (CDGRoad) load limits were set out
in Table 2 of Schedule 1 as follows:
Transport Individual Total mass or
Catagory Package mass volume of packed
or volume dangerous goods
0 0 0
1 1 20
2 10 200
3 25 500
4 unlimited unlimited
These load limits changed under CDGTPE 2004 to the
following:
Transport Catagory
Load Size
0 0
1 20
2 333
3 1000
It should be noted from this that the package size
threshold of CDGRoad has been dropped and that
now every container, regardless of size, will count
towards the load size.
For example, previously under CDGRoad clinical
waste of Transport Category 2 could be transported
in rigid containers or in yellow clinical waste bags
inside rigid containers (wheelie bins). Provided that
each individual yellow bag or rigid container
weighed less than 10kg the load size was not
applicable as the package size in column two of the
Table 2 (shown above) did not exceed the threshold
to count towards the load size. Now, under CDGTPE
all containers and yellow bags will count towards the
load size.
Once the load size is reached there is a requirement
to apply the Regulations in full, namely vehicles to
bear orange plates front and rear. If the vehicle is
over 3.5 tonnes (maximum permissible weight) then
drivers will be required to be ADR trained etc…
Implications
Rigid containers transported on vehicles will have to
be kept below the 333kg threshold to avoid orange
plating the vehicles. If the vehicles require orange
plates drivers will require “in-house” training
provided their vehicle does not exceed 3.5 tonne
(max. permissible weight), TREMcards, relevant PPE,
emergency equipment etc as set out in ADR 2003
Chapter 8.1.5.
If the vehicle exceeds 3.5 tonnes then driver ADR
training is required and the associated
equipment/documentation as detailed above.
If transporting clinical waste in bulk the Regulations
apply as soon as waste is placed on the vehicle. In this
case four orange plates are required to be displayed
– plain orange plate on the front of the vehicle and
orange plates bearing 2X displayed over 3291 on
both sides and the rear of the vehicle.
Vehicle Equipment
Vehicles will be required to ensure that all of the
emergency equipment listed in ADR 2003 Chapter
8.1.5 is carried and is fully functional on vehicles with
a maximum permissible weight greater than 3.5kg
This includes wheel chocks, warning markers, hi-viz
vests, torch, TREMcard and relevant PPE, fire
extinguishers (cab and load compartment).
Reports On Accidents and Incidents
If a serious incident occurs during the transportation
of dangerous goods there is a need to comply with
ADR Section 1.8.5.1 and report to the national
authority, e.g. DfT in the UK. This relates to a
transport related injury as a direct result of the
carriage of the dangerous good itself.
ADR does not specify a time scale in which to submit
this report, and the ‘new’ UK domestic regulations
mirror ADR.
Please note that this is in addition to the requirement
to report the incident under the Reporting of Injuries,
Diseases and Dangerous Occurrences Regulations
1995 (RIDDOR).
Future Changes
ADR 2003 has since been superceded by ADR 2005
that has been available since January 2005 but will
only be implemented in July 2005. The Carriage of
Dangerous Goods and Use of Transportable Pressure
Equipment (Amendment) Regulations 2005 are due
to be released to coincide with the updated ADR text
and reflect the changes in ADR 2005. The
requirements of ADR will be extended to cover the
following:
1. ADR training will become a requirement for drivers
of all vehicles regardless of maximum permissible
weight from July 2005 (transitional period until
January 2007) if transporting dangerous goods over
the load threshold values.
2. There will be an additional requirement for
vehicles with a maximum permissible weight
exceeding 7.5 tonnes to have an extra fire fighting
(fire extinguisher) capacity of 4kg above that
currently required e.g. fit a bigger fire extinguisher.
3. In response to 11th September 2001 the United
Nations introduced an enhanced requirement for
security of dangerous goods being transported. The
new security measures apply to all dangerous goods,
except those that are nuclear. The requirements are
split into two:
A general level applicable to all dangerous goods;
and
A higher level for the carriage of high consequence
dangerous goods.
With regard to Class 6.2, Infectious Substances, high
consequence dangerous goods are those of Category
A, clinical waste is to fall within the general level of
security.
The measures required to comply with this include:
■ carriers to be properly identified,
■ transit sites that contain dangerous goods to be
made secure,
■ security training to be provided and general
security awareness to be raised,
■ for high consequence dangerous goods a security
plan to be put in place.
Wendy Rayner MCIWM MIHEEM &
Environmental Consultant
Enviros Consulting
The management of Hazardous Waste in the UK is changing in order to incorporate
the requirements of the European Hazardous Waste Directive 91/689/EC. Separate
Regulations are being introduced in Scotland, Northern Ireland, Wales and England
reflecting each administration’s devolved powers with respect to environmental
regulation. SMDSA and its Members have actively participated in the consultation
processes throughout the UK and will be able to provide specific advice and support.
This section summarises the main changes in each part of the UK and identifies
additional guidance which can be downloaded directly from the SMDSA web site
http://www.smdsa.com/hazardous-waste.htm or which provides the relevant links to
Agency guidance.
Scotland
The Special Waste Regulations 1996 were amended by The Special Waste
Amendment (Scotland) Regulations 2004. Scotland was the first part of the UK to
amend its Regulations as these came into force on the 1st July 2004. The new
Regulations do not affect the current consignment system and there should be no
reason to change existing procedures. However the main thrust of the amendment
was to replace the definition of special waste with one referring to hazardous waste
as defined by the EC Directive. This is now mirrored by the new Regulations in
England and Wales and details of exactly which healthcare wastes are classified as
hazardous for the UK forms the subject of the next SMDSA newsletter. The SEPA web
site includes a section of Frequently Asked Questions (FAQ) with useful advice and
provides guidance on the consignment and regulation of Special Waste in Scotland.
Download a guide to consigning Special Waste in Scotland from our web site.
Northern Ireland
The Department of Environment (DOE) Northern Ireland is currently drafting new
Regulations. The consultation closed on the 25th March 2005 and Special Waste
(Amendment) (Northern Ireland) Regulations are expected within the next few
months.
The consultation document can still be viewed on the SMDSA or DOE (NI) web sites
At this stage, their proposals are to adopt the same system as Scotland retaining
existing consignment procedures and updating the definition of special waste to
include all hazardous waste within the EC definition.
Wales
Dave Dingle MSC, MRSC, CChem, MCIWM
Environmental Controller
Cannon Hygiene Ltd
The Welsh Assembly Government is due to release new Regulations in the next few
weeks. The new Welsh Regulations are believed to be virtually identical to the
English Regulations and will also be Hazardous Waste Regulations. Other than the
fact that separate Regulations are required for Wales, the England and Wales
systems should be identical, and are intended to run in parallel with the same
systems, regulated by the Environment Agency for both England and Wales.
Further guidance can be obtained from the SMDSA or Welsh Assembly Government
web sites.
England
The Hazardous Waste (England and Wales) Regulations 2005 and associated List of
Wastes (England) Regulations 2005 have recently been published. Despite their title
the new Regulations apply primarily to England (other than amendments to the
Environmental Protection Act 1990) with separate Regulations being produced in
Wales as described above. The new Regulations introduce what is largely a
completely new management regime for hazardous waste, details of which are
detailed in the article on page 4.
What does this mean in practice?
Generally these different changes in legislation will only affect producers, consignors
or carriers of hazardous waste if they are moving waste between the different
Countries in the UK. In that case procedures may have to be amended to reflect the
requirements of more than one Consignment Note and charging system. In general,
contractors moving the waste will be the ones who will deal with this and will be
able to advise producers. This aspect of the Regulations will be covered in more
detail in our next Newsletter. However nothing in these regulations will prevent
waste being transported across Boundaries between the different parts of the UK
where that is necessary to ensure appropriate management and disposal.
Regulations specifically refer to consignment notes produced in one part of the UK
being recognised in other parts to avoid unnecessary duplication.
Is your waste Hazardous?
NHS Estates is currently revising the guidance document ‘Safe Disposal of Clinical Waste’ The new guidance document is to be titled
‘The Safe Management of Healthcare Waste’ is be released for consultation in May 2005. SMDSA member Enviros Consulting Ltd
have been contracted to compile the new guidance. The content of the guidance has been approved by a project steering group
comprised of representatives from the UK Environmental Regulators, the Health and Safety Executive, the Department of Transport
in addition to representatives from the NHS throughout the UK. The new guidance document has been drafted to take into
account recent regulatory changes, notably the Hazardous Waste Regulations (Special Waste in Scotland) and the Carriage of
Dangerous Goods and Use of Transportable Pressure Equipment (Amendment) Regulations 2005. The new guidance document
is considered to represent ‘best practice’ and introduces a new UK wide colour coded segregation system for all healthcare waste.
The SMDSA has been heavily involved in the production of this new guidance, with representatives of the SMDSA attending a
number of the ‘expert working groups’ established by NHS Estates to establish what is best practice. The new guidance will
form an essential link for the healthcare sector between the Joint Agencies Hazardous Waste guidance WM2 by providing a
practical interpretation of what is considered Hazardous Waste. If you interested in participating in the consultation process
of the new Healthcare Waste guidance, once released a link to the consultation web site will be available from the SMDSA
web site (www.smdsa.com).
Guidance on the definition and classification of hazardous waste is provided by a
joint Agencies guidance document entitled WM2. Copies of the guidance document
can be downloaded from any of the UK Environmental Regulators web sites (EA,
SEPA or EHS) or by contacting their offices directly. Hygiene waste is not classified as
a Hazardous Waste and is not listed in WM2. However, healthcare waste is included
and there are a number of changes introduced by the new guidance affecting the
way that waste is defined and classified. New hazardous wastes include dental
amalgam, fluorescent tubes, cathode ray tubes (e.g. Televisions and PC monitors) and
others. The status of prescription only medicines (POMs) as special waste has
changed, with only cytotoxic and cytostatic medicines now being classed as
hazardous. The interpretation for infectious waste is changed, but remains under
debate with Government and Regulatory Agencies. Further guidance on the
management of hazardous healthcare waste is expected, including the rewritten
‘The Safe Management of Healthcare Waste’ to be released later this year and the
issues concerning the classification of healthcare wastes and whether or not they are
hazardous will be featured in our next newsletter.
Visit the SMDSA web site for regular updates.

Dave Dingle
MSc, MRSC, CChem, MCIWM, MCIWEM
Environmental Controller, Cannon Hygiene Ltd
In April the long awaited Hazardous Waste (England
and Wales) Regulations 2005 and The List of Wastes
(England) Regulations 2005 were published, having
been laid before Parliament in late March to be
implemented ahead of the General Election. The
equivalent Regulations for Wales have been delayed
but, according to DEFRA, will be identical to those in
England, with the systems for both England and
Wales hopefully running seamlessly.
The new Regulations introduce to England and Wales
what is largely a completely new management
regime for hazardous waste implementing the
requirements of the EC Hazardous Waste Directive,
91/689/EC. Whilst, for years, we have had references
to hazardous waste in associated legislation, finally
we have a complete system within the UK with
hazardous waste defined in our own domestic
legislation. This differs elsewhere in the UK as
detailed in the article on the previous page.
Following the usual round of consultation by the
Department of the Environment, Food and Rural
Affairs (DEFRA) and the Welsh Assembly and
responses from the many interested parties including
SMDSA, the Regulations introduce further relaxation
of the legislative requirements in addition to those
originally proposed. These will potentially benefit
smaller waste producers such as dental practices, GP’s,
and veterinary practices. However they also bring
new hazardous wastes, systems and procedures which
will result in those receiving hazardous waste for
storage or disposal having additional responsibilities
and likelihood of increased costs. The revised
charging mechanisms also increase the costs of
consignment of hazardous wastes, particularly for
those collected on Carriers Rounds, as much of the
waste in the healthcare sector is. Implementation of
the Regulations will takes place in two stages over
the three months between 16 April and 16 July 2005.
A summary of Frequently Asked Questions on the
Regulations can be found on the SMDSA and DEFRA
web sites. Other DEFRA and Environment Agency
guidance on specific aspects is detailed below and can
be sourced through the SMDSA web site, with further
guidance still to be published.
The Changes
The main de-regulatory aspects compared to the
previous system are:
■ Removal of the need for pre-notification of
hazardous wastes to The Environment Agency
■ Removal of the requirement to send a Deposit
Copy to The Environment Agency confirming
receipt of each consignment of waste at the
storage and/or disposal site.
■ Removal of the requirement to pay The Agency
in advance for individual Consignment Codes.
The features of the special waste system retained for
hazardous waste, albeit with some changes, are
■ Consignment notes for each collection
■ Copies required to be completed at each stage of
the waste movement and retained by the
Producer, Carrier and Consignee (i.e. those
receiving the waste)
■ Provision of information on consignments to The
Environment Agency (although in a different way
to previously, as outlined below)
■ Charges for each consignment of hazardous
waste collected (although at different rates).
■ Procedure for rejection of consignments
■ Prohibition from mixing different categories of
hazardous waste or with non-hazardous wastes.
The new and additional requirements brought in by
the HWR include:
■ Changes to the way hazardous waste is defined
■ Requirement for producers of hazardous wastes
to register premises to The Environment Agency
(unless exempt – see below)
■ Additional information required in the
Consignment Note e.g. Producer Premises Code,
Carriage of Dangerous Goods information, SIC
(Standard Industrial Classification) Code.
■ Confirmation of deposit at the receiving site
(whether transfer station or final disposal) to be
provided to the Producer
■ Quarterly returns to The Environment Agency by
those receiving wastes (consignees)
■ Fixed penalties where offences are committed
Hazardous Waste Definition
From 16th July, hazardous waste is defined
specifically by those wastes having an asterisked
entry in The List of Wastes Regulations or any other
waste which the Secretary of State determines as
hazardous. The List itself is a UK adoption of the
European Waste Catalogue, EWC.
It is important to avoid confusion and note that
although Schedules 1, 2 & 3 to the Regulations list
categories of wastes, constituents, and properties of
waste which may render them hazardous, they do
not need to be referred to in considering whether
waste is hazardous. Only the List of Wastes needs to
be considered for that purpose and then the only
evaluation of whether a waste is hazardous, or not, is
dependent upon whether it is an absolute entry (i.e.
waste which is always hazardous) or a mirror entry
(i.e. dependent upon an evaluation of the waste).
The criteria for consideration of mirror entries is then
detailed in those Regulations. The main reason for
the Schedules is to provide a mechanism if The
Secretary of State wishes to determine other waste as
hazardous. Schedule 3 may need to be referenced for
a list of hazardous properties when completing
consignment notes.
New waste types are now classified as hazardous such
as fluorescent tubes, TV’s, PC monitors but the main
change in relation to healthcare wastes is that all
prescription only medicines are no longer
automatically hazardous. Only Cytotoxic or
Cytostatic medicines meet the criteria. The
Environment Agency have produced a document
entitled ‘Interpretation of the definition and
classification of hazardous waste technical guidance
- WM2’ as guidance on the classification of hazardous
waste, although we understand that this is to be
reviewed by July. The current version is available
from the SMDSA web site, as will any consultation on
the process.
The potential for clinical waste to be hazardous due
to its infectious nature was already included in the
Special Waste Regulations and remains a feature of
these Regulations. With a change of criteria and
interpretation rests the potential for a majority of
clinical wastes to become hazardous and the division
into hazardous and non-hazardous categories is
currently under furious debate with both DEFRA and
The Agency.
As a result, publication of the new NHS guidance
document ‘The Safe Management of Healthcare
Waste’ has been further delayed. In light of these
delays, details on which clinical wastes are hazardous
will be featured in the next issue of our Newsletter.
Notification of premises
Each individual premises in England and Wales where
hazardous waste is to be produced or removed from
after 16th July 2005 must be notified to The Agency
before that waste is removed, unless exempt from
notification. This can be effected by either the
Producer, a Holder or a Consignor (i.e. someone who
removes, or causes removal) and can be made from
16th April. The Agency intend to be able to accept
notification by post (from 16th April), telephone &
internet (from 3rd May) and by electronic data
transfer or on disk (from 9th June). The charges for
each notification are scaled with the intention of
discouraging the use of paper notification and to
reflect the processing costs of different methods.
These have been initially set at £28 (paper), £23
(telephone), and £18 (other electronic formats). In
future charges will be set as part of The Agency’s
Annual Charging Scheme and in common with all
other charges can only be expected to increase. The
Agency will issue a code number when a premises is
registered (known as a ‘Premises Code’) which will be
required on Consignment Notes. The Premises Code
is valid for 12 months and hence will need to be
renewed annually. Although the Regulations in
Wales are not yet in place, The Agency will be able to
process and issue Codes for premises in Wales from
16th April.
The electronic format to be used for Premises
Notification is still to be specified by The Agency but
must be used so there is little scope for variation. As
this newsletter went to press and in spite of dialogue
between the Agency, SMDSA and other Associations,
details of The Agency format are not expected until
June. Clearly there may be substantial IT work to be
carried to modify waste contractors systems to match
the Agency format if bulk registration of Producers
Premises is to be carried out before 16th July, and
further delays are likely to cause chaos as the
deadline approaches.
DEFRA issued ‘Hazardous Waste Regulations Interim
Guidance on Premises Notification’ in January. Hard
copies can be obtained by telephoning 08459 556000
(DEFRA Publications) and this can also be found on
the SMDSA web site together with the Agency’s Site
Premises Registration Guide.
Exemption from premises notification applies if
■ Less than a total 200kg of all hazardous wastes is
removed from the premises in any 12 month
period with no limit on the number of
consignments, and
■ Removal is only by a registered or exempt carrier
of waste, and
■ The premises are included in a list of industry
types specified in the Regulations
The main types of premises exempted are shops,
offices, dental, veterinary or medical practices,
premises listed in Section (a) to (e) of the
Environmental Protection Act 1990 or Schedule 1 to
The Controlled Waste Regulations 1992 (examples
include prisons, residential and nursing homes). For
healthcare premises the total of all types of
hazardous wastes will include TV/PC monitors,
fluorescent tubes and is not restricted to waste
arising from the clinical activities. Exemption is only
from premises notification - consignment notes will
still be required when hazardous waste is removed
from the site.
After 16th July 2005, it will be an offence to collect
hazardous wastes from premises unless they have
been notified or are exempt. Waste Contractors will
therefore require proof of registration or some form
of assurance that a premises is exempt, unless the
producer has asked the contractor to register them.
We would expect that most Waste Management
Contractors will offer this service to customers but
may make an administration charge.
The Agency are required to provide details of
existing Premises’ Registration, and in time this will
be available on their web site, although not
immediately. Fortunately The Agency will carry out
these responsibilities through one centralised
location at their National Call Centre (08708 502858)
in Rotherham, and forms for paper registration are
available from them now or can be downloaded
from our web site.
Consignment Notes and Charges
Although the requirements for pre-notification and
provision of proof of receipt at the waste
management site (Deposit Copies) to The Agency no
longer apply, consignment notes will still be required
when any hazardous waste is removed from 16 July
2005 onwards. The format of the consignment note
is similar to the Special Waste Consignment Note, but
with added information such as Premises Code (if not
exempt), Carriage of Dangerous Goods information
and SIC (Standard Industrial Classification) Code for
each producer. More information is now required for
each type of waste collected and each individual EWC
code. The Consignment Note number will no longer
be obtained from The Agency but will be generated
by the consignor according to an Agency Coding
Standard. Producer (and Consignor if different),
Carrier, Consignee and possibly a Producer
Confirmation copy may be required. There are new
procedures where more than one Carrier is involved
in the movement (now confusingly referred to as a
Schedule of Carriers).
Where multiple collections are carried out and
delivered to the same Consignee (previously referred
to as Carriers Schedules) these are now referred to as
Multiple Collections with considerably different
requirements including a summary Consignment
Note for the multiple collection and a separate
Annex for each Producer which is considerably more
detailed than the existing Carriers
Schedule. Unlike the previous
Carriers Rounds, there is
no restriction on the
time which can be
taken for a multiple
collection without
delivery to the
Consignee, other than
reference to delivering
‘without undue delay’.
The charges for each
consignment are then
raised by invoicing
Consignees on the basis of
quarterly returns made to the
Agency.
Records and Returns
As outlined above, there are a number of new
requirements to provide returns and keep records:
■ Consignee returns to Producers/Consignors
■ Quarterly returns to The Environment Agency by
Consignees
■ Registers of consignment notes and Consignee
returns by Producers/Consignors
■ Registers of waste held at waste management and
disposal facilities, in relation to the locations of
storage or disposal
When the waste is accepted at the waste
management site, the Consignee must send to the
Producer either a copy of the Consignment Note
confirming receipt, or a summary detailing all loads
delivered from that Producer, in either case within
one month of the end of each quarter. Unlike formats
for Premises Notification or Consignee Quarterly
Returns which are specified by the Agency, these are
already detailed in a Schedule to the Regulations.
The quarterly returns of consignments made to the
Agency are then used to determine the Consignment
charges to be paid in each quarter for which an
invoice is sent to the Consignee. As with Premises
Notification, the charges depend upon the way in
which the quarterly return is made – again
discouraging the use of paper -.£19 for each single
and £10 for each part of a multiple consignment; or
if made electronically £10 for each single and £5 for
each part of a multiple consignment. Overall these
charges represent significant increases. Agency
guidance on providing Quarterly
Consignee returns and the
specified format have
still to evolve as they
will not be required
until 31st October 2005.

HAZARDOUS WASTE COMES OF AGE continued
The Agency’s Role
The purpose of these changes is to release Agency
resources from administrative tasks in order to carry
out more inspections of waste producers and
consignees. There is a much greater likelihood that
Producers, Carriers and Consignees will receive visits
from local Agency offices to inspect systems and
registers in future.
Offences and Enforcement
As you would expect there are a range of offences
under these Regulations such as collecting from nonnotified
premises, incorrect completion of
consignment notes and associated paperwork, failing
to notify premises, provide returns, or keep registers.
A new concept is introduced into environmental and
waste legislation of fixed penalties for most of these
offences, in the same way as road traffic offences. The
format of these Notices is detailed in the Regulations,
and it is to be expected that after an initial period of
applying a ‘light touch’, future offences will result in
The Agency serving fixed penalty notices on those
they believe are in breach. As with any fixed penalty
system there remains an option of non-payment and
potential for the matter to be referred to a Court if
the defendant believes they are innocent. Unlike the
use of speed cameras, where the evidence is very
much a matter of fact and inevitably conclusive, the
question of whether or not a breach of these
Regulations has been committed may be very much
subject to interpretation in each case, and more likely
to be open to challenge.
Cross Border Movements
The previous article outlines certain differences
across the UK due to the devolved Governments. To
allow for potential differences in what is hazardous
waste in different parts of the UK, the Regulations
state that anything which is consigned as hazardous
waste in one part of the UK remains hazardous waste
in any other part of the UK. Subject to certain
exceptions (such as pre-notifying to SEPA in advance
if moving waste from England to Scotland due to
retention of pre-notification in Scotland)
consignment notes prepared in one Country are valid
in another Country, although there is the potential
problem of double charging under the different
systems. This is an aspect which merits further
consideration once the Agencies issue further
guidance and will be dealt with in more detail in a
future Newsletter.
Transitional Provisions
As always with Regulatory changes there are
provisions for transition such as to waste
licences/permits where waste has become hazardous
for the first time (‘changed status wastes) to allow
sites to accept wastes up to 16 July 2006, or until a
new permit is issued.
Biffa Waste Sevices
Potters Lane, Wednesbury WS10 7NR
http://www.biffa.co.uk
Tel: 0121 505 1662 Fax:0121 505 2120
Contact: Mr. John Waddington
John.Waddington@biffa.co.uk
Frontier Medical Products
Newbridge Road Industrial Estate
Blackwood, South Wales NP12 2YN
http://www.frontier-group.co.uk
Tel: 01495 235800 Fax: 01495 235808
Contact: Mr. Nick Davis
nickdavis@frontier-group.co.uk
Frontier Medical Products manufactures and markets the Sharpsafe range of
sharps disposal containers throughout the UK and worldwide. The Medical
Products division is part of the Frontier group of companies which also supplies
the Multigate brand of swabs and dressing plus the Repose range of pressure
ulcer prevention products to the NHS.
Hygieco Ltd
Clockhouse Estate
Cavendish Road, Glemsford, Suffolk CO10 7PZ
http://www.hygieco.co.uk
Tel: 01787 281188 Fax: 01787 282222
nick@hygieco.co.uk
Privately owned, Hygieco Limited have provided local and national companies
with specialist Washroom and Clinical Waste Services since 1990.
Intercare Distribution Services
Middlewich Road, Leighton, Crewe
Cheshire CW1 4QT
http://www.intercareuk.com
Tel: 01270 257254 Fax: 01270 250959
Contact: Mark Greenhalgh
mark@intercareuk.com
What do we do?... We excel in the delivery of specialised transportation and
distribution solutions through partnership with the healthcare sector.
Mr Tom Gooder
Cathedral Hygiene Services
The SMDSA is the primary trade organisation representing
the hygiene and healthcare waste industry. Affiliated to
the Chartered Institution of Wastes Management (CIWM)
the SMDSA provides a unique forum for debate and the
sharing of knowledge and expertise. Membership of the
SMDSA is open to any company involved in or supplying
products or services to the management of healthcare
waste.
The SMDSA opens its arms to Associate Members
One of the main aims of the SMDSA is to raise the standards of operators dealing
with sanitary, medical and clinical waste. Since 1993 its membership has risen
from the founding members, PHS and Cannon, to over 40 organisations
including washroom services, waste carriers, waste disposers, container
manufacturers and distributors and consultancy. As well as lobbying government
agencies for practical legislation and regulation the members meet regularly to
discuss best practice.
To help raise these standards the SMDSA has now launched a new membership
category to assist newly formed and small companies. Associate Members will
now be able to share the knowledge of the Association without meeting the full
membership criteria. The benefits include regular attendance at discussion
groups, access to a vast industry library and a network of individuals with many
years of industry experience.
Furthermore the SMDSA has amended the application process for full members
to ensure that together with its existing members they operate to a high industry
standard. Acceptance as a full member may be achieved by providing references
from existing members, a statement of the applicants intended contribution to
the Association, a commitment to attend a quarter of the SMDSA’s meetings, and
evidence that they meet the Association’s Code of Conduct. By setting standards
of operation the SMDSA is changing the perception of the industry and raising
standards throughout.
For more information on becoming an Associate or Full Member please contact
Martin Foulser, the SMDSA secretary, on 01933 311223 or by emailing
info@smdsa.com.
CONTINUED FROM COVER
Are you ready for WEEE?
The UK is currently drafting regulation to
meet the requirements of the European
Directive on Waste Electrical and Electronic
Equipment (WEEE). The new Regulations
which are likely to be titled the ‘The Waste
Electrical and Electronic Equipment (Producer
Responsibility) Regulations. The UK is current
behind schedule in drafting the regulations as
the Directive set a deadline of August 2004 for implementation. The UK
regulations are now due in Summer 2005 with the main requirements coming
into force In January and July 2006. The new regulations will define who is
responsible for the management of WEEE and will set targets for the re-use
and recycling of component parts. Medical devices are just one of the ten
classes of WEEE that will fall within the scope of the new regulations.
The Department of Trade and Industry (DTI) is current drafting
guidance and further information can be found at:
http://www.dti.gov.uk/sustainability/weee/
Bogged down by acronyms ?
The waste industry loves seems to love acronyms so you may be excused for not
knowing the difference between your EWC and PPC.! In an effort to help those
involved in waste management from producer to disposal contractor the
SMDSA has produced a guide explaining the most common terms. The guide
can be accessed from the SMDSA web site:
http://www.smdsa.com/acronyms
New Regional Centre for Cannon
With the simultaneous launch of its new corporate identity and logo, Cannon
(as it is now branded) opened a new purpose built Regional Centre and
Transfer Station in January
this year combining under a
single roof its hygiene,
clinical, textile care,
horticulture, security,
environmental and cleaning
divisions on the ‘brownfield’
site of a former Sewage
Works at Oldbury, West
Midlands.
Greencare Environmental
Unit 1, Warsop Trading Estate
Hever Road, Edenbridge, Kent TN8 5LD
http://www.greencareuk.com
Tel: 01732 865400 Fax: 01732 866447
Contact: Adam Warren
adamwarren@greencareuk.com
H & A Waste Services Ltd
49 Cardrew Way
Cardrew Industrial Estate
Redruth, Cornwall TR15 1SS
Tel: 01209 219993 Fax: 01209 219995
Contact: Mr. Kim Always
kim.alway@btopenworld.com
specialise in the collection and disposal of all grades of clinical waste, operating
from licenced waste transfer stations throughout the South West.
In addition, we offer a complete range of products and services for the
washroom.
Healthcare Environmental Services Ltd
Calderhead Road, Shotts, Lanarkshire ML7 4EO
http://www.healthcareenv.co.uk
Tel: 01501 822233 Fax: 0151 822211
Contact: Garry Pettigrew
garry@healthcareenv.co.uk
Healthcare Environmental Services Group are a privately owned specialised
waste management company. We have depots UK wide and collect all types of
waste including Clinical, Chemical, Trade, & Radiaoctives. We provide a full
facilites waste management service to all our customers. We have our own
autoclave treatment facility at our Shotts Head office.
Homeport Ltd
3 Devonshire St., London W1W 5BA
http://www.homeport.info
Tel: 020 7631 0607 Fax: 020 7631 0608
Contact: Mr. Romain Bertrand
romain.bertrand@homeport.inf
Homeport Ltd develops & markets secure delivery systems that allow healthcare
deliveries and collections - including clinical/pharmaceutical waste - to be made
24/7 without the recipient/sender being present. Our systems are suitable for
installation in most healthcare locations including all types of surgeries,
pharmacies, opticians, hospitals or patients' homes.
The Homeport itself is the only permanent fixture with deliveries being secured
into containers which can remain permanently fixed or be removable.
Scientific Services Ltd
P.O. Box 130, Redruth TR16 4ZX
http://www.scientificservices.biz
Tel: 01209 843988 Fax: 01209 843740
Contact: Mr. Tim Hamilton
enq@scientificservices.biz
Scientific Services Ltd is a consultancy company specialising in the validation of
alternative treatment technologies used for the treatment of clinical waste.
Our UKAS accredited laboratory supports our consultancy activities by
providing an array of microbiological, physical and chemical analysis
Steriwaste Brandbeat Ltd
Meadow House, Kerswell
Cullompton, Devon EX15 2ES
http://www.steriwaste.com
Tel: 01884 266666 Fax: 01884 266333
Contact: Mr. David Colgate
info@steriwaste.com
Alternative Technology for ‘In House Treatment’ of Clinical Waste. A proven
hygiene & infection control system ( Yellow Bag Waste)
● Collecting, transporting and disinfecting in puncture-proof multipurpose reusable
containers.
● HF thermal disinfection directly at the source of the waste.
● Regional waste disposal as industrial waste with a fraction of the cost of
clinical waste disposal
No longer does the bulk of untreated clinical waste need to travel the roads of
Britain.
Vernon-Carus
Factory Lane, Preston, Lancs. PR1 9SN
http://www.vernon-carus.co.uk
Tel: 01772 744493 Fax: 01772 320449
Contact: Tim Eaglen
tim.eaglen@vernon-carus.co.uk
Vernon-Carus manufacture a wide range of branded products and are also UK
distributors of products manufactured by other major brand leaders such as the
Sharpak range of sharps and clinical waste containers. A major supplier to the
NHS, with over 30 years of experience in the healthcare market, Vernon-Carus
is committed to delivering healthcare solutions and outstanding customer
service.