More an environmental management problem than a H&S issue, but hoping that there may be some expertise out there to help me understand the implications of some proposed action. The scenario is a health care setting which produces a mix of waste, some clinical, some domestic or general etc. The operational staff appear to have incorrectly bagged and labelled what is essentially general waste as clinical waste which now needs disposal. Clearly there are cost and handling issues associated with this and an argument is developing such that there may be a desire to examine the contents of the sealed clinical waste bags to determine whether or not they do indeed contain clinical waste. There is a proposal from our waste removal contractor that the sealed bags be removed from them to a site that is not theirs, and not licensed as a waste handling facility for examination and subsequent segregation with onward transport to the licensed disposal site for treatment/disposal. This does not sound correct to me but I am not an environmental expert and I do not want us (the producer) to authorise activity which may be in contravention of any necessary legislation. My question therefore is, can such waste be transferred to an unlicensed/permitted location for examination and what are the implications for the producer and the handlers of that waste? Any thoughts gratefully received. I must stress that no action beyond routine storage at site has occurred as yet, we're simply trying to explore options for dealing with the situation as it exists. We already have an action plan in play to prevent further incorrect segregation at source. I should also point out that we are aware of the relevant safety legislation and would not be undertaking any activity without first thoroughly assessing risk and applying the appropriate control measure.

'morning Wainwright Interesting post given that you're identified as working in consultancy. As I read your post, the lower hazard waste has been treated as clinical waste - a much higher hazard waste. So, aside from the undiclosed volume of the incorrectly classified waste, what's the problem? I presume that your clinical waste goes for incineration? The costs of segregating and sorting will probably not be less than just paying for it as clinical waste for incineration and the proposal by your waste contractor rings so many bells that I've gone dizzy! Frank Hallett

I think I would also be challenging the competence of your “carriers” for making such a suggestion. If nothing else let them prove it is ok to do so. I’m guessing that there is a lot of waste. Cost of sorting would probably outweigh the cost benefit; also if you mix hazardous and non hazardous it all gets treated as hazardous. You would have to really review your waste to make sure of no cross contamination. Chalk up to experience, pay up and move on. Chris

The only thing that I can add, is that I believe that some waste, which was previously classified as clinical, may now be classified as 'objectionable'. That may or may not make a difference to your situation.

The EA website has excellent [and easy to follow] guidance on the duties on the waste producer [that's your health care Co] with regard to tracking haz waste. It includes you to have procedures for ensuring that the carriers actually process and dispose of your waste "as advertised" and that they are suitably licenced to legally handle [sorry - but that's the word] your categories of waste!! If your organisation gets involved in the suggested sorting in the original post in the way described [the sealed bags be removed from them to a site that is not theirs, and not licensed as a waste handling facility for examination and subsequent segregation with onward transport to the licensed disposal site for treatment/disposal] I would suggest that you personally must consider your position. Frank Hallett