If your organisation produces healthcare waste, you are obliged to conduct an annual waste audit in line with your statutory obligations.
Failure to complete pre-acceptance audits could mean your waste contractor will not be permitted to legally accept your waste. To do so would put them in breach of their environmental permit. This matters because if your hazardous healthcare waste can’t be collected, your right to operate could be put in jeopardy.
In addition, Duty of Care waste audits should be conducted by the business to satisfy themselves that they are managing all waste streams in accordance with relevant regulations and guidance. Cumulatively errors and deficiencies in both audits could be seen as negative aspects by entities such as the Care Quality Commission and Environment Agency as they are inextricably linked to demonstrate satisfactory management practices
In normal times, audits would require a site visit by an independent auditor to analyse policies, staff training and compliance with regulation, including compositional analysis of waste in a series of spot-checks.
Feedback from these audits allow healthcare settings to resolve any issues at hand, helping to ensure that good waste management processes are in place, delivering consistency of approach, correct protocols, and appropriate training. Correctly implemented, this process enables producers of healthcare waste to comply with their statutory requirements, which in turn permits waste to be collected.
Since the outbreak of the coronavirus pandemic, healthcare settings ranging from care homes to primary care providers, GPs and pharmacies, have all been looking to minimise the likelihood of the introduction of Covid-19 into their premises. Understandably on-site audits undertaken by third parties fall into this bracket.
To address these concerns, Anenta has developed a new Covid-19 compliant app that enables users to meet waste audit requirements remotely.
Taking users step-by-step through the process, the app enables users to conduct compulsory clinical waste pre-acceptance audits at the same time as duty of care audits, all without the need for third-party on-site visits.
Operated from a desktop as well as mobile devices, the secure app takes the user through the audit process, covering duty of care and waste pre-acceptance in one go. Taking around 40 minutes to complete, the app streamlines a process that can take up to six days when conducted on the ground - including expensive on-site visits - consuming the valuable time of staff and management.
The app identifies and records details of training undertaken linked to duty of care. A record of this is kept for compliance purposes. It also identifies if the correct waste management policies are in place and keeps full details for assessment, including whether hazardous consignment notes are kept for three years, and in what format; a compliance requirement.
The app establishes if the user has a working knowledge of Health Technical memorandum (HTM) 07-01, and Environmental Permitting Regulations (EPR) 5.07 detailing how to comply with environmental permits issued by the Environment Agency. It also logs details of the number of clinical staff and clinically active rooms.
Particulars of all internal waste containers are recorded, including their location and content, and whether these are correctly labeled and clearly outline waste segregation by waste type e.g. sharps containers, clinical bags, medical containers, non-clinical waste containers. Details of the clinical bag-type, sharps container type, medicinal container type and non-medical storage type are also taken.
These details are supported by images of both clinical waste containers and non-clinical containment, room by room*. These are uploaded as a point of reference using mobile devices, enabling multiple site assessments to be undertaken; colleagues can be emailed with a link to the section of the waste management audit that they need to complete.
A similar process is undertaken for external bulk waste storage containment – both clinical and non-clinical – to ensure that there is no cross-contamination e.g. a clinical bag in general waste.
* a minimum of two clinical rooms applies for settings with up to five clinical rooms. A minimum of four clinical rooms applies for practices with over five clinical rooms.
Once the remote audit has been completed, Anenta assesses the audit and provides a report with advisory notes and actions to be taken covering: missing policies, segregation requirements, and areas where action needs to be taken to comply with regulations; be that in terms of duty of care or the clinical waste pre-acceptance audit process. This enables clients to quickly and easily address aspects of the audit that will enable them to continue operating.
All audits undertaken using the Anenta app are stored electronically, are readily accessible by the user and can be used to track remediable actions providing a breadcrumb trail for compliance purposes and CQC checks.
All healthcare providers need to comply with the management of healthcare waste in accordance with the Health Technical Memorandum 07-01 (HTM 07-01). Sitting above this is the Environmental Protection Act 1990, setting out Controlled Waste Regulations and Duty of Care Regulations, as well as a long list of other statutory instruments. Within this, there are duties that you as a waste producer need to comply with; a significant one being the pre-acceptance audit.
Effectively, this is a bill of health for your waste contractor, confirming that the waste and quantities of waste produced are managed in accordance with the law and is waste that your contractor is allowed to dispose of. Without this in place, your waste contractor cannot legally accept waste as they would be in breach of their environmental permit. Your audit, and subsequent policy and process development, should help to facilitate the successful completion of your waste pre-acceptance audit.
With Environment Permit Regulations under review, more stringent rules could be on the horizon soon. If introduced, the Environment Agency will be able to monitor performance in greater detail. That includes the ability to track waste from source, all the way through to disposal. If this is put into place, waste audits will not only be desirable, they will be essential.
Understanding your waste profile more accurately is the key to procuring cost-effective and appropriate waste contracts that have the potential to save your businesses thousands of pounds each year.
Without this information, even the very best procurement officer can only procure the lowest headline costs for you. That might generate a cost-saving in the short term, but if the contract fails to reflect your actual waste profile, you can be sure you won’t be getting the best deal. Instead, you could find yourself bound by a ‘cheap’ headline contract where cross-contamination penalty charges are punitive.
An audit that includes compositional analysis of waste will enable you to understand the real-world picture on which a waste collection contract can be more accurately negotiated. This will help your business control costs associated with expensive or unnecessary services and could help prevent avoidable penalties by framing a more appropriate contract for your business.
To gain access to the Audit app, advice on on-the-ground audits and to understand associated costs please contact our team on 03301 222143 or mail us.