Pre-Acceptance Waste Audit
Pre-Acceptance Waste Audit
From 1st October 2010 some producers of healthcare related waste have been required to assess the composition of the waste they produce and inform their waste contractor, in order to assist in its safe collection and disposal.
The Environment Agency has prioritised the applicability of this requirement, based on risk, and so pharmacy contractors have been subject to these requirements from 1st July 2013. Waste contractors will be unable to collect waste from a pharmacy until it has been satisfied that an audit has been carried out, to identify the waste streams and so that it can ensure appropriate disposal.
These requirements are detailed in the document 07-01 Safe Management of Healthcare Waste, available from the Department of Health. Pages 170-184 apply specifically to community pharmacy, and pharmacy contractors will find references to the pre-acceptance audits elsewhere in the document. The Environment Agency has also published a briefing note for producers of waste which pharmacy contractors may find helpful.
With the assistance of the Environment Agency and The Co-operative Pharmacy, PSNC has developed a Pre-Acceptance Waste Audit Tool. This is based upon a similar template prepared with the assistance of the Environment Agency for general practitioners.
This Tool is designed to support a practical audit which will allow pharmacies to identify all waste streams in their pharmacy, including patient returned medicines and waste produced by the pharmacy. The use of this particular tool is not mandatory. As part of the pre-acceptance audit process, pharmacists will need to assess waste in all parts of their pharmacy.
Waste Contractors may offer (for a fee) to provide support in carrying out a waste audit at the pharmacy, but there is no obligation to accept such offers. Whoever conducts the audit, it is the pharmacy contractor that is responsible for its accuracy and completeness.
Note: Pharmacy Contractors should be aware that from 1st July 2013, waste contractors may not be able to collect waste from community pharmacies who haven’t submitted a pre-acceptance audit.
Completing the Audit
Once this has been completed, the audit should be sent to your waste contractor.
The audit can be printed and completed by hand, or can be completed on your computer. Page one and two are an introduction to the audit, which should be read first.
Page 3 sets out details about the pharmacy location, ownership and the details of the Audit.
The Audit Report Sheet on page 11 should be completed for each room or area of the pharmacy – an example is included, which would be expected in a dispensary. Create extra copies of this report for each area examined.
Page 12 contains an Audit Summary Sheet which should be used to combine the container types found during the previous stage.
Page 13 should be completed identifying from the Summary Report Sheet, the different waste streams, along with the hazards associated with them, and the disposal options. Again, examples are included. Page 14 – 16 sets out details about Hazardous waste, which may be useful to allow the pharmacy to identify and segregate hazardous waste.
The Audit Findings – Composition Questions should then be completed on pages 6-10. These questions allow contractors to identify segregation practices, and assist in the clarification and description of waste.
Finally, the Audit Findings should be completed on pages 3 – 5. These summarise the information collected in the other sections of the audit.
The environmental legislation now seeks to increase the amount of recycling that takes place and the Audit should enable pharmacy contractors to identify any waste that is suitable for recycling (such as cardboard from pharmaceutical packaging and glass bottles). However, medicines should never be removed from their blister packaging, although contractors are encouraged to recycle the cardboard packaging (once patient-identifiable information has been removed).
During the course of the development of the audit tool, the Environment Agency confirmed that there is no absolute prohibition to rinsing liquid medicines such as methadone into the sewer system, but that this is dependent on obtaining approval from the water authorities. Approval has to be sought on an individual premises basis, because consent is dependent not only on the amount of waste to be discharged to the sewer, but also to the consents already granted to waste producers upstream and downstream of the premises. If consent has not been granted to discharge limited amounts of liquid waste to the sewer, then bottles which are contaminated with medicines should not be rinsed out. Instead, they should be disposed of with other medicines waste.
Q. My waste contractor has said that I only need to do an audit for clinical waste, and not all the waste produced by my pharmacy. Is this correct?
A. The Environment Agency guidance confirms that the audit should cover all waste streams (page 26). Without identifying all waste streams then there is the possibility that different streams may be inappropriately mixed; page 24 of the guidance specifically states that “the absence of an offensive-hygiene healthcare waste stream in treatment areas of a medical practice, is a key indicator of the waste being inappropriately mixed with clinical waste”. Therefore, PSNC believes that contractors are required to complete the pre-acceptance audit for all waste streams produced by their pharmacy. Q. How should I classify finger pricking devices (lancets) from, for example, diabetic patients and others who have finger prick tests? A. This would be included in “Non medicinally contaminated sharps”. Q. How often do I need to do the waste audit? A. The waste audit should be conducted every five years.