Clinical waste issue

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Hello all and a very merry christmas to everyone :santa2:

An incident just arose in a private physio clinic where I have rented a room.

Background info: it is a partnership business between a physio and a remedial sports therapist. They rent rooms to other therapists covering acupuncturists, counsellors, masseur, beautican, chiropractor and other such therapists.

When I went there 9 months ago I set up a clinical waste service as there was no such service at the clinic (aside from sharps bins). The bin was installed in a room I used for clean up.

approx 8 weeks ago I began noticing a large amount of waste material in there that I had not produced (mainly large sheets of couch roll), and when I asked about it one of the partners said that a patient of the physio partner had cut her hand and a lot of blood was spilled, which they cleaned up with couch roll. They thought it best to put it in "the clinical waste bin" (my bin!). She said it was a one off and wouldnt normally be necessary to do this (!) Then last tuesday when I went in to clinic I noticed the bin was once again full of couch roll. Annoyed (my expense) and confused (thought they said they didnt produce clinical waste) I sent an email to the partners to ask if any of their therapists were unaware that the bin was for clinical waste, my clinical waste, specifically, and should any of them require such a facility, I would be happy to share the bin in exchange for shared costs. This is the email I got back:


The couch roll that’s going in the bin is from one of our physio’s clients and she’s doing do so at our request as her client is HIV positive and currently undergoing treatment for skin cancer, hence our preference that the couch roll used is treated as clinical waste. Similar suitable precautions are also taken with any other items that he may have come into contact with during his treatment. As far as the paper waste, this amounts to perhaps 3 or 4 handfuls, which we didn’t think would be an issue in a 50 litre bin and his treatment will be more or less completed this week.



Naturally, I was alarmed. Firstly, not to have been notified that potentially HIV infected material was going into my bin, as I could have come into contact with it, had it not been for my gloves. Secondly, what would they have done with that waste had my bin not been there. Not to mention the bin's use at my own considerable expense.

What would you have done/said....

 

Happy holidays footsie girl

I would suggest that the small amount of waste they are putting into your bin is insignificant and you should be a little charitable, after all you do claim your waste expenses against tax.
As for HIV waste, why would you even want to rummage round in the waste once it was in the bin?

CM

 

Sorry, i'm with cornmerchant on this one.

How much extra is this likely to cost you?

Personally my clinical waste bin has a protected locked lid with flap. Once waste goes in, the only time that it is opened is when the waste service agent comes to collect it,risk is zero.

Chances are your collegues would probably have put the contaminated towels in a bag and chucked it in the domestic waste otherwise, this is a bit scarier for all concerned.

What are they doing that produces such blood spillage?? If this is a regular thing they should probably get there own bin, or share the cost of yours. If its only a handful of towels i wouldn't get so bothered about it. In shared practice expect a bit of give n take.

Scott

 

Thanks for the responses...

I certainly dont mind sharing, but the amount deposited in the bin is not insignificant, despite the response email I got from their practice manager. It was several couch long lengths of couch roll, which was worming itself out of the bin. I was specifically told that they do not need a clinical waste bin, and I would have to fund it alone when I first joined, I did not know there was contaminated waste in my bin, let alone potentially HIV contaminated waste. Unfortunately, the yellow bin scheme is not the sealed unit type, that Scott describes (which I have had before) but a lift up lid type. This has naturally raised issues of its safety. One of the main areas of my concern - rather the than merely cost to me, was the fact that the practice does not have any contingency for clinical waste produced on an adhoc basis. I personally think they would be failing to comply with the law if I left and took my bin with me, and they did not put in place a clinical waste system for such waste...

 

Isn't HIV contaminated waste classed as hazardous clinical waste and as such generates a different reference on your transfer of waste notice.

The practice manager has therefore made it your responsibility to notifiy the handlers of the clinical waste and bear the costs of disposal.

I assume you have informed the relevant authorities now you are aware of the change in situation however short term?

GB

 

Hi GB, Thanks for taking the time to reply.

How can the practice manager make it my responsibility? They were not even going to inform me that they were using the bin, let alone that it contained HIV contaminated waste! The waste disposal is a system that I have arranged, and is nothing what so ever to do with the practice. How can waste produced by another practitioner become my responsibility just because it has been put in my bin? The mind boggles....

 

FG,
It is difficult to comment on this as we don't know what was in the contract you signed when you rented the room. We do not know whether this is a shared room or a room that you use solely.

Nor do we know what arrangement you made with others about clinical waste when you set up the system. Obviously you will have made the owners aware that you have such a facility as the owners of the premises will have had to agree to this.

If you share the room then the only answer is a lockable bin.

I agree with GB that if your clinical waste route is being used for the disposal of HIV contaminated material (even without your consent) then you need to take advice from your contractor on this. You are responsible as you have set up the contract.

I was under the impression that it was the responsibility of the creator of clinical waste to make sure that the receptacle is stored securely to stop situations such as this?

http://www.initial.co.uk/medical-services/clinical-waste/index.html

CF

 

Footsie Girl

Regardless of who uses or what goes in that clinical waste bin of yours, you have signed the contract, you are responsible. The manager has indicated as such by their actions. If you don't know what is going in it or who is using it then you must be aware of the worst case scenario and advise the uplifter of the waste as such.

I would suggest you do not fully understand the responsibility for clinical waste or else you would have argued the case with your practice manager and would not be posting here. You would have also purchased a locking bin which would have prevented both the removal of and depositing of clinical waste without your knowledge.

Perhaps contact your professional body for advice?

GB

 

How often are you using the room? If it is just the odd day or hour then you might consider using sealable yellow bags and and a small sharps bin and take you waste away with you and put it in your contract bin at home or at another practice ( share a bin with someone else). This will avoid the issue of people using your bin. This is annoying and i have had to discusss this with other therapists in my practice. They all take their couch roll and rubbish home with them now as no-one wanted to pay. This is the crux of it, if they wont share the cost and contract and therefore the risk then dont leave your bin there. There is a lot to be said for sharing in a multi disciplinery practice but it has to be fair. Protect yourself first, also just out of experience I find emails can cause offence and get up noses even if unintentional, as can notes left for suspects in waste sabotage, its always best to see people face to face to ensure relationships remain friendly even if business problems are not. Good luck

 

All blood and bodily fluids must be assumed to be infective. It's called universal precautions for a reason, lots of people don't know they have hep or HIV but are no less infective than people who know.
In Ontario, blood contaminated articles are not considered hazardous medical waste unless the amount of blood saturates the article, meaning that you could wring blood out.
Spotted items rapidly dry and can be disposed of as typical waste. We don't throw bandaids or towels from kitchen mishaps in a biological waste bin at home, even if known HIV is present.
Call the waste management legislative office to confirm practices in your area. And stick a lock on that bin, free loaders are a pain and must learn that there is NO FREE LUNCH

Sarah

 

I do sympathise with Footsiegirl .I work part of my week in a doctor's practice. She quite rightly has made herself responsible for all the waste produced on the premises. I'm probably treading the middle ground on this one. The cost of clinical waste disposal has gone up by leaps & bounds over the last couple of years so I would resent someone else using my facililty without my permission.I think you've got to make it politely plain in writing that you will keep the position under revue & if they overstep the mark you will have to remove the facility, even if its inconvenient to you. I would point out though you do seem to be getting in a state over the potential hazard as the HIV virus is not that infectious .ie :You need to grossly contaminate youself with this blood -borne paper to risk your health.

 

I would caution any one who thinks carrying clinical waste away from clinics is a good idea - it is not. Should you find yourself in an accident and you are carrying anything identifiably clinical waste without a licence to carry clinical waste you will be most likely prosecuted.
As far as the clinic footsiegirl uses, my feeling is that the local council environment department would consider the premises owner/management responsible for providing the necessary waste management not any particular practitioner within, irrespective of internal contracts as it would be them prosecuted not an individual practitioner.
Well that's my interpretation anyhow, for what it's worth.

 

David,

Have you ever been responsible for filling in the transfer documents relating to clinical waste?

I don't think the local council/environment will give a damn what happens whilst the clinical waste is within the 4 walls of a practice. Their concern is at the point of transfer, what is being transferred and who is the named producer on that transfer document. In this case it is Footsiegirl and she must apply the correct codes and description to the clinical waste for transfer and estimate the amount being produced. There may be local variation on what information is asked for.

The issue Footsiegirl has in the short term is not being in control of the clinical waste and what is going into that bin. The management of clinical waste has been swiftly side stepped by the manager of the practice and handed to Footsiegirl. It is doubtful that any prosecution would ever arise from this situation but if it did, the named producer would carry the can once the clinical waste had been transferred to the disposer.

But who would take responsibility until the point of transfer is anybody's to speculate in this particular situation.

I for one do not like these untidy situations. There are 3 producers of clinical waste within my practice, so as practice manager I take full responsibility for "internal management" of the stuff and I am the named producer for transfer purposes. Practice users pay for this service within their rent. If I were Footsiegirl this is what I would be aiming for wherever I worked and this is what I would be challenging the manager on.

GB

 

George
Many thanks for the clarification. I do contract to a multi practice clinic (Several ...oligy's) but the clinic deals with waste and that's where I consider responsibility SHOULD lay.
Regards
DW

 

Thanks for the many and varied responses.

The clean up room/cupboard was used soley by me. This is where the clinical waste bin was stored. As there was no lock on the door, I took one in so that I could maintain safety and control of the area. However, the lock was confiscated and that was that.

I resorted to writing an email because the partners and practice manager were never around to ask. You may recall in an earlier posting here, that I said I initially spoke to the junior partner, and she described it as a one off occurance. Only later did it transpire that it was not.

UPDATE:

Shortly after raising the query the senior partner decided I was too much trouble and asked me to leave.

I spoke to the clinical waste bin service, and they said that the senior partner had asked if I could leave my bin there, if I no longer required it, as they now said they required a clinical waste facility (!) I guess they could have been concerned that I may report them for flouting the law.

I am doing purely dom visits at the mo, but looking for an appropriate premises.

 

Thanks GB

For the record, The practice stated at the outset that they did not produce clinical waste and that it was down to me to make my own arrangements. What I should have done, is walk away at that point. A lesson learned.

 

Better off out of it. However i have a question, not specifically aimed at footsiegirl but in general. When you carry out a domiciliary visit, how do you deal with the waste produced. Surely contaminated instruments, sharps and gloves have to be transported? David Widdowson raises an interesting point about transporting waste yourself. How do others deal with this?

 

do you do Dom visits yourself Lizzy1so?

 

No, I am clinic based. I used to do them when i first started, i had a sharps bin (lockable) and small sealable yellow bags that i placed in a locked bin at my clinic at the end of the day.

 

you cant just take stuff away with you in a yellow bag though!

 

FG,
I would suggest you follow the advice from your Professional Body on this subject.

regards

CF

 

with regards to what CF?

 

Actually footsie girl you can! as long as the waste is categorised as clinical and not hazardous there is no issue with moving it, although you can put non pathologic nails and skin the patients own waste. My question was about moving used instruments about if you are a dom practitioner. But, just out of interest, what do you do, (i showed you mine now you show me yours)

 

FG,
I was referring to the topic under discussion which was dealing with (clinical) waste generated on Dom visits, I believe?

CF

 

lizzy1so,
Sorry, but that's not correct.
The SCP are very clear on this:-

"NHS and Private Practices – disposal systems

Safe disposal of waste is the responsibility of the practitioner, nursing home owner or centre management. The domestic waste collection SHOULD NOT be used for clinical waste irrespective of where it is generated.
Options for disposal are:

• Local authority special collection and disposal service for clinical waste
• Independent contractor to local hospital incinerator
• Independent contractor to local authority facilities
• Independent contractor to contractor’s incinerator
• Practitioner taking waste by arrangement to local hospital incinerator.

Sharps

Health care staff including podiatrists who treat patients at home should remove any sharps that they generate in appropriate containers for disposal via their employers clinical waste disposal system.

There is no confusion as far as HSE are concerned. Any waste generated by a podiatrist (i.e. toenail clippings, callous, swabs etc.). is Group A waste and as such must be disposed of through the channel designated for clinical waste. It is against the Regulations and is a breach of the COSHH regulations and HSWA if it is left to normal domestic waste. Any one or any Trust found to be advising that the waste can be treated as domestic waste is in direct contravention of current legislation and may be prosecuted if HSE were to investigate or hear of the policy."

Catfoot.

 

Hi Catfoot I Spoke to the Society this morning for clarification. They have just revised the guidelines for clinical waste disposal and recommend that non-pathological waste can be put in household rubbish. If this is not correct apologies. Just passing on what they said. still interested in what others are doing on their dom visits, so far no-one has commented. Beginning to wonder why, because this must be an issue that affects a lot of people. Hazardous waste is a different kettle of fish and does come under Duty of care legislation. Come on you Dom Pods open up and tell what you do with your waste and instruments, you must have to transport them somehow?

 

When I worked for the NHS, dom visits which did not generate hazardous waste, ie, non-pathological nails and callus, was treated as domestic waste and disposed of in the pts refuse.

As far as I`m aware, if it is non-infectous (and under 200kg) this is still perfectly acceptable. These links appear to confirm this;

http://www.chiropodistwastedisposal.co.uk/pdf/ChiropodistsDisposalwaste.pdf

http://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/documents/digitalasset/dh_073328.pdf

Note this paragraph in the above `Environment and sustainability Health Technical Memorandum: Safe management of healthcare waste`document;

Domestic waste
7.34 Domestic waste is waste similar in nature and
composition to waste generated in the home.
Domestic waste should not contain any infectious
materials, sharps or medicinal products. Domestic
waste may be placed in black or clear bags for
disposal.

 

Hi lizzy1so,
Thanks for that info.

I took what I posted directly off the SCP site this afternoon, so it looks like they haven't yet updated it. No wonder we are all confused!

With regards to the transportation issue all my instruments used on doms are placed in a snap-top plastic container in a weak solution of washing-up liquid, the blades are put in a sharps bin, and the clinical waste removed from the patient's home in sealed yellow bags and transported in a large snap-top plastic container. All these are kept out of sight in the boot. On returning back to base the clinical waste goes in the clinical waste bin for collection/incineration and all instruments/containers removed and de-contaminated.

regards

CF

 

CF: I remain vigilant about the current legislation regarding the disposal of waste. Thank you for your interest, but I was confused, as I hadn't asked for guidance on this matter. It was Lizzy1so who raised the issue.

As for transporting instruments, I bag them and put them in a lidded box. Scalpels go into a blade box. Its a great topic, Lizzy1so, and one that should be discussed. I hadnt evaded the question, I was merely away from my computer.

Thanks for your input blinda - I know for a fact that the local PCT's policy is that such waste can be designated as household waste.

 

FG,
It seems I misunderstood, as I wasn't sure if your post 20# was a statement or a question.

So, for interest, what guidance does your professional organisation give on the subject ?

CF

 

Ok folks, here is my protocol, the common sense approach since I do not believe that my dirty instruments are going to jump out of the boot of my car and attack the public.

Dom waste if non pathological is put into the patients own waste bin as this is where they would out their own nail clippings! Any yukky stuff is put in the yellow bag left by the community nurse , because yes , you have guessed it , they are under the nurse anyway for various medical conditions, often an ulcer , or from daily support staff that carry out personal care .If there is no bag I bring it back to put in the clinical waste bag at my surgery which is a GP practise that takes care of all my clinical waste .
Used instruments go into one of the gloves I have used for the patient and turned inside out . This is taken to the car and put into a lidded box. I always know then that any instruments within a glove have been used and need decontamination.

So go on, report me.

Cm.

 

Common sense, indeed. :drinks

 

I concur,

Common sense indeed.

Regards (as always)

Mandy.

 

more info on clinical waste here

Clinical Waste