Arrangements for the Disposal of Waste by Incineration
Following the closure of the incinerator at the Queen's Medical Centre clinical and radioactive waste which had previously been incinerated there is now removed by a contractor for incineration off-site. In addition to the need for compliance with health and safety legislation and the Radioactive Substances Act 1993 (in relation to radioactive waste) the University is also subject to a "Duty of Care" under the Environmental Protection Act 1990. The Duty of Care places a cradle to grave responsibility on the producer of waste to ensure that it is correctly packaged, labelled and transported for suitable final disposal at an authorised location.
The involvement of contractors also gives rise to an extended disposal route with increased handling, and the potential for more people to be exposed to hazardous waste through loss of containment due to incorrect packaging. The following procedures have been produced to ensure compliance with both statutory requirements and the conditions of acceptance as specified by the contractor.
Clinical/infective laboratory waste
Dry or moist waste with mild chemical or biological contamination must be placed in yellow bags for disposal. Wherever possible infective materials should be made safe prior to disposal, for example by autoclaving, and then disposed of in yellow bags. The bags should not be filled more than two thirds full and then sealed. A suitable means of sealing includes tying a knot in the neck of the bag. Tying with wire, the use of clips or stapling, is not acceptable.
Clinical or biological waste, which is either wet or cannot be rendered non-infective, should be put in yellow bags which are in turn placed in rigid plastic one way burn-bins. These are available through the Medical School Stores in 30 and 60 litre sizes. Animal carcasses and potentially harmful animal bedding, e.g. infective or containing hazardous chemical residues, fall into this category. When ready for disposal the burn-bin should be lidded. Once the lid is in place it cannot be removed.
Sharps should continue to be packaged as previously. Prior to disposal the container should be labelled with departmental tape. Sharps boxes must not be placed inside yellow bags or one-way burn-bins.
Yellow bags and burn-bins must be marked with departmental tape to enable subsequent identification of the originator should this be necessary.
Waste should be delivered to the loading bay supervisor at the waste skip (in the northern spur of the central service area) between 1.30 p.m. and 3 p.m. Monday to Friday. A docket must be completed to confirm the number of bags sent for incineration. If waste has previously been frozen it should be delivered in a state of advanced defrost.
Solid waste must be placed in red bags which are sealed and labelled as above when no more than two thirds full. Additionally two radioactive waste labels must be completed to indicate the activity of the various radionuclides contained. One label must be applied to the bag. The bag must be placed in a one way burn-bin and the second label stuck towards the top of the side of the burn-bin. More than one red bag may be placed in a burn-bin.
Once full, the bin should be lidded and marked with departmental tape and radiation hazard warning tape. A radioactive waste transfer note must be completed. This is the responsibility of the person securing the lid on the bin and they should check that the number of bags in the bin tallies with the number of radioactive waste labels on the outside. Information on the radioactive waste labels must be compiled and entered in section B of the low level radioactive waste transfer note (example enclosed). Section A should also be completed and the collection point must be described as University Stores, Medical School, Queen's Medical Centre.
Before the bin leaves the Department the dose rate at the surface of the bin should be monitored and the reading entered in the appropriate part of Section D of the transfer note. The dose rate must not exceed 5Sv hr-1. Departments should contact the Safety Office if they do not have access to a dose rate meter or contamination meter with conversion data. No other entries should be made in Section D since this will be completed when the bin is delivered to the contractor's container.
After completing the transfer note it should be photocopied and the copy retained. All 5 sheets of the form should be placed in an envelope and fixed to the lid of the bin with adhesive tape. The envelope should be addressed to the person completing the transfer note and marked "FOR RETURN OF WHITE COPY OF TRANSFER NOTE". This enables the Department to confirm that the waste has been collected by the contractor. The forms need to be kept for 2 years and it is advised that this is done centrally within the Department. Once the white copy of the form has been returned to the Department the photocopy may be destroyed. Eventually the yellow customer invoice copy will be returned to the Department and this should be married up with the white copy.
Bins for disposal should be taken to the Medical School Stores and placed inside one of the grey bins on the loading bay at the rear of the Stores. The key to the bins should be obtained from the stores. Radioactive waste can only be taken to the Medical School Stores on Monday to Thursday. Collections cannot be received on Fridays.
Used scintillation fluid in vials may be disposed of via the contractor. Vials must be placed in rigid sealed plastic containers which are suitable for incineration. The aggregate volume of liquid must not exceed 3 litres per box. An appropriately sized sharp-safe container would be suitable.
Once full, the container should be closed, sealed and labelled with the Departmental tape, radioactive waste label and radiation hazard warning tape. The box must not be placed in a burn-bin but placed separately in a holding bin at the Medical School Stores loading bay. This must be accompanied by a transfer note as described above.
Very low level solid radioactive waste (i.e. 3H/14C less than 4 MBq/0.1m3; other beta/gamma 0.4 Mbq/0.1m3) should be placed in yellow bags and disposed of as clinical waste. Radioactive waste labels, warning tape or transfer notes should not be used. However the activity disposed of by this route should continue to be recorded in the activity isotope records as very low level waste to properly account for the use and disposal of radioisotopes.
Pharmaceutical and cytotoxic waste
This waste must be collected in orange bags and disposed of as for clinical waste except that it requires transfer note documentation to accompany it. The transfer note procedure for this type of waste is slightly more complex than that for radioactive waste in that pre-notification of the disposal has to be sent to the relevant waste regulation authority. This introduces a delay of at least 5 working days into the disposal route. Separate guidance on this is in preparation.
Dr J A Sutherland, Safety Officer
2nd October 1995
To: DSOs and RPSs in Departments using unsealed radioisotopes (QMC and UP)
Waste for incineration - transitional details
The accompanying circular describes the steps which have to be taken to ensure the safe and correct disposal of waste for incineration. There are some transitional details which will slip into place as the system beds in. These are as follows:
Medical School via NHS Supplies, Curie Court, QMC - contact Mrs Wendy Parker (Tel 42896).
University Park via the manufacturers:
Compact UK Limited,
The Harnham Trading Estate,
(Tel 01722 326411).
Orders of 36 rolls are carriage free, orders of 12 will attract a 5 carriage charge unless departments could collect them from the NHS Works Stores situated at the QMC boilerhouse yard.
Dr J A Sutherland, Safety Officer