Waste Management Overview

Section 1 – Legal framework

The primary law governing the safe management of waste is the 'Environmental Protection Act 1990'. This applies across the UK and establishes the overriding duty of care for waste producers to ensure their waste is handled, managed and disposed of correctly. A practice is fundamentally responsible for the safe disposal of its waste until its final destination.

This is supplemented by the 'Waste Duty of Care: Code of Practice', issued under Section 34(7) of the Environmental Protection Act 1990, which provides practical guidance on meeting the legal duty of care.

Under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, dental practices must ensure that all waste is correctly segregated, stored securely in appropriate containers, and disposed of through suitable methods. During inspections, CQC will evaluate, under the SAFE key question, whether waste management is appropriate to comply with the above.

1.1 - W/HTM 07-01

The purpose of this guidance is to provide a framework for best-practice waste management to help both Private and NHS practices comply with their legal obligations above.

In addition, the guidance supports the NHS's drive to be a Net Zero health system by 2045.

To achieve the objectives set out by the UK Government and the separate targets set by the NHS, the guidance places greater emphasis on adequate waste segregation based on its infectious and/or hazardous properties.

1.1.1 - Compliance Targets

For all NHS practices in England, the NHS Clinical Waste Strategy has endorsed this approach by introducing the offensive waste stream and subsequent targets of correctly segregating waste as follows:

• 20% of segregated waste to be sent to incineration via the orange waste stream
• 20% of segregated waste to be sent to alternative treatment via the yellow waste stream
• 60% of segregated waste to be classified and disposed of as offensive waste

For Private practices in both England and Wales, there have been no specific targets set; however, the Health and Social Care Act 2008: code of practice on the prevention and control of infections and related guidance (England) and The Private Dentistry (Wales) Regulations 2017, require practices to have written arrangements in place covering the safe handling and disposal of waste, in line with current best practice guidance such as W/HTM 07-01. Therefore, following this guidance will ensure that you can demonstrate to inspectors that you are managing waste safely in accordance with the above legal frameworks.

1.1.2 - Infectious vs non-infectious

Historically, all clinical waste was treated as "potentially infectious" and was therefore disposed of via the orange or yellow clinical waste streams; however, over-classification of waste has been identified as one of the major issues contributing to ineffective waste management and high carbon emissions due to the process of high-temperature incineration or alternative treatment (where waste is treated through a heat sterilisation process).

On the other hand, offensive waste can be disposed of using conventional EfW (Energy-from-waste) incineration methods that operate at much lower temperatures. The reduction of over-classified waste has therefore been identified as a key factor in driving the targets to reach net-zero carbon emissions.

To accommodate this approach, greater emphasis has been placed on assessing healthcare waste at the point of generation to determine whether it poses an infection risk before disposal.

1.1.3 - Assessing waste for infection

To undertake this assessment, practices need to consider the following:

• Whether the waste has come from a patient being treated for an infection or from contact with a patient carrying a transmissible disease
• Whether the waste has come from a patient with a history of a known infection, for example, a blood-borne virus
• Whether the waste has been identified as infectious by a clinician

Whilst patients are not obliged to declare an infection risk, a sensible approach should be undertaken based on the evidence at hand; for example, if the patient is in visibly good health, with no apparent signs of infection, and has a clear medical history, then it would be deemed reasonable to classify the patient as non-infectious, with all associated waste being disposed of via the offensive waste stream, unless the waste is medicinally contaminated, or a sharp, in which case other streams are to be used as indicated in Section 2.

However, if the answer is 'yes' to any of the above, and there is a reasonable belief that the patient may be infectious, the waste should be disposed of via the clinical waste stream.

1.1.4 - Implementing the offensive waste stream

The approach to assessing patients' infectious risk is likely to result in a significant change in how healthcare waste is managed, as most waste would now fall into the offensive waste category rather than the clinical waste category. Therefore, to manage this effectively, where surgeries have more than one clinical waste bin available, at least one should be filled with a tiger bag and designated for offensive waste only. Where surgeries have only one clinical waste bin, this should be replaced with a tiger bag designated as offensive waste only, with a smaller bin made available for clinical waste.

Practices should speak to their appointed waste carrier to discuss the appropriate solutions they can offer regarding the types and sizes of waste bins available.

1.1.5 - Circular economy

In addition to the new approach of classifying waste based on assessing infection risk, there is a greater emphasis on preventing unnecessary waste through sustainable procurement, where products and materials are kept in use rather than being sent to landfill.

To help achieve a circular economy at the practice level, the aim is to avoid and prevent waste as much as possible by considering the following:

• Reducing consumables, particularly items such as single-use plastics
• Prioritising reusable equipment over single-use equipment
• Leasing or hiring equipment where available
• Purchasing remanufactured devices
• Refurbishing furniture or equipment
• Going digital over print
• Purchasing materials that are recyclable or biodegradable
• Substituting hazardous products with non-hazardous or less hazardous alternatives, and
• Managing stock levels to avoid the purchase of surplus items

Section 2 – Waste classification and segregation

Section 3 – Waste streams

To achieve effective waste management, practices must implement appropriate procedures for storing and disposing of various types of waste and train staff to segregate, store, and dispose of waste correctly, as outlined below. Waste must also be packaged in a way that prevents escape or leakage whilst on site, in transit, or in storage, and should be correctly labelled. There are special containers for clinical waste, sharps, waste amalgam, waste amalgam capsules, gypsum, X-ray fixer, X-ray developer, X-ray lead foil, and outdated drugs/LA cartridges.

3.1 - Clinical waste

This is any item that has come into contact with an infectious patient and has been contaminated with the patient's blood, saliva, or other body fluids, which can cause harm to anyone who comes into contact with it. Clinical waste includes masks, gloves, disposable bibs, mouthwash cups, tray liners, disposable film, tissues, etc. Appropriate clinical waste sacks should be fastened securely when three-quarters full. Do not put your hands into the clinical waste sack. Thick rubber gloves and aprons may be worn to protect employees handling clinical waste. All sacks should be stored in a special container, labelled with the date and the place of origin.

3.2 - Offensive waste

This is any healthcare waste that may contain body fluids, secretions, or excretions which have been assessed and deemed as non-infectious, i.e., is not clinical waste. Items such as used non-infectious PPE, swabs, cotton, and dressings would be classified as offensive waste, not clinical waste, as well as used nappies and sanitary products (unless they are from an infectious person).

3.3 - Cytotoxic and cytostatic contaminated waste

This is waste contaminated with a medicinal product labelled 'acute toxicity', 'carcinogenic', 'toxic for reproduction', and/or 'mutagenic' (e.g. Botox and Dermal fillers, etc.). Practices that generate this waste, including cytotoxic and cytostatic medicines that are no longer required, have expired, spilt, or have been contaminated, need to ensure a suitable, purple-lidded pharmaceutical bin is available for this waste stream. Mixing cytotoxic and cytostatic medicines with other medicines is prohibited.

3.4 - Sharps

These include used syringe needles, scalpels, suture needles, fully discharged LA cartridges, and used matrix bands. They should be segregated from the rest of the clinical waste and stored in a sharps bin, which is not filled more than 2/3 of its capacity. Sharps bins must be labelled with the date and the place of origin before disposal. Keeping the sharps bin safely in a cupboard is advisable to prevent children or others from accessing it.

3.4.1 - Sharps contaminated with cytotoxic and cytostatic medicines

These must be disposed of in a purple-lidded, rigid yellow sharps container. Consistent with other sharps bins, cytotoxic and cytostatic waste should be collected when the bins are filled to the fill line and should never exceed 2/3 of their capacity. It is advisable to keep the sharps bin safely in a cupboard to prevent access by children or others.

3.5 - Prescription medicines / Pharmaceutical waste

Whilst prescription medicines were classified as 'special waste', only those that are cytotoxic or cytostatic are now considered hazardous. However, all prescription medicines must still be separated from other waste and disposed of by incineration via a registered carrier in a blue-lidded pharmaceutical bin.

3.6 - Gypsum

Although gypsum and plaster casts are deemed non-hazardous (unless they come into direct contact with an infectious person), they can generate highly toxic gases when mixed with biodegradable wastes. As a result, gypsum waste is banned from landfills and must be disposed of as a separate waste stream in a designated gypsum container for incineration.

3.7 - Chemicals

Practices use various chemicals, including disinfectants, hand gels, resins, and diagnostic kits. While there are clear guidelines on the safe disposal of X-ray developers and fixers (classed as hazardous waste), the safe disposal of other chemicals should be checked with the waste management contractor.

When segregating waste packaging from chemicals, consider the following:

• Empty containers from hazardous chemical wastes may contain enough residue to remain hazardous unless rinsed, and the water is discharged to the foul sewer via the sink. You should contact your local water company to check if a trade effluent consent is required
• Alcohol hand gel bottles can be rinsed, and the packaging recycled or placed into the domestic waste stream

3.8 - Waste electrical and electronic equipment (WEEE)

Equipment such as freezers, fridges, cathode-ray screens, fluorescent tubes, computer flat-screen monitors, and some batteries (lead-acid or nickel-cadmium) is deemed hazardous waste. These must be consigned from the dental practice. If you are replacing equipment, the supplier may be able to dispose of the old equipment, or you may be able to take it to a local civic tip. But you must obtain a consignment note. If using a local tip, check that they can provide you with a consignment note.

3.9 - General (residual) waste

This includes non-hazardous, non-recyclable waste, which is to be collected by a business waste carrier, such as the local Council (if they provide a commercial collection service), or companies such as Biffa or Veolia.

3.10 - Recyclable waste

All non-hazardous waste items should be recycled where possible to minimise unnecessary waste being sent to incineration or landfill.

In England, the recycling of non-hazardous waste has been made a legal requirement for dental practices under the 'Simpler Recycling' rules, which came into effect on 31 March 2025 for practices with 10 or more full-time employees.

*These rules do not come into effect until 31 March 2027 for practices with less than 10 full-time employees. Practices can, therefore, choose to wait until the implementation date or be proactive and start implementing these changes sooner.

The duty requires all non-hazardous recyclable waste to be separated into one of the following waste streams before the waste is collected and transported off-site:

• Dry recyclables (plastic, metal, glass, paper and card)
• Food (leftovers, peelings, teabags, etc. - any amount)

The total number of employees includes full-time equivalent employees but excludes the self-employed. If a business operates over more than one location, the total number of employees is calculated across all premises, e.g. if a registered provider has two separate dental practices, each with six full-time employees, then the total number equals twelve, which means they were required to implement the recycling rules by 31 March 2025. If, however, a registered provider has three separate dental practices but only three full-time employees at each location, then the total number is nine, meaning they do not need to implement these rules until 31 March 2027.

From 1 April 2025, members of the public and other parties can report practices to the Environment Agency that they feel do not comply with the above. If practices are not compliant, the Environment Agency can issue a compliance notice that may include a fixed monetary penalty.

Section 4 – Waste containers and collections

4.1 – Hazardous waste

A suitable waste collection and disposal contract must be in place with a waste management company, e.g., Initial, to collect your clinical waste, sharps, and other hazardous waste. When choosing a hazardous waste carrier, ensure they hold a valid waste carrier's certificate.

All hazardous waste bags and containers need to be fit for purpose and in good repair to prevent accidental spillage or leaks; however, hazardous waste sacks, such as those used for the orange and yellow waste streams, are often used for the disposal of hard clinical waste items, such as aspirator and 3-in-1 tips, which increase the risk of puncturing the bags. Therefore, practices should instead consider using a rigid UN-approved clinical waste container for these items, in addition to the clinical bags, which should be used for soft waste only. The decision to include rigid bins should be made locally and agreed with the appointed waste carrier.

Hazardous waste bins located inside the practice should be lidded, positioned where they can be easily accessed, and hands-free (e.g., foot- or sensor-operated), where situated in clinical areas and toilets.

4.2 – Recyclable waste

To comply with the 'Simpler Recycling' rules, practices in England must arrange a recyclable waste contract with their local council or an alternative waste management company that incorporates the correct number and type of recyclable waste containers for their needs. Some waste companies, however, will not provide a single dry recyclables container and will require that particular recyclables, such as glass, be collected in their own designated containers. This is because some waste recycling facilities that contractors use cannot separate the dry recyclables themselves.

Practices should discuss the arrangements with their waste carrier to understand the options available to them, e.g., the types and sizes of containers available, the number required, and the collection frequency. If the options are unsuitable for the practice's needs, practices should speak with alternative contractors and consider switching to a service that better supports them.

The containers should be located where staff can easily access them in areas where waste generation is anticipated, such as the reception and staff room. If waste bins are made available to visitors and patients of the practice, then recyclable containers must also be provided.

All containers should be clearly labelled or marked with appropriate signs to advise persons of their correct use and what can and can't be placed in them, to avoid incorrectly mixing waste streams.

4.3 - Amalgam separators

Dental practitioners must ensure that their amalgam waste (including amalgam residues, particles, fillings, teeth, etc.) is handled and collected by an authorised waste management company.

If a practice uses or removes amalgam, separators that meet ISO standard 11143:2008 must be fitted to collect the waste either chairside or centrally. If waste procedures are in place and followed, it is not strictly necessary to fit separators into either manual cleaning sinks or washer-disinfectors.

All separators must retain at least 95% of amalgam particles.

Section 5 – Waste storage

Clinical, general, and recyclable waste must be segregated and stored in separate, clearly identified, and designated areas, with waste bins stored securely before collection. This area should have an easily cleanable surface in case any waste leaks. Providing a hose point is desirable for wash-down purposes.

All receptacles used for waste storage and transportation must comply with the required UN-approved packaging standard.

Waste storage must be sited away from food preparation areas, general storage areas, and public access routes. It must be secured when unattended, with access restricted to trained, authorised personnel only. They must be enclosed and display appropriate hazard signs. Care must be taken to ensure there is no potential for cross-contamination of any adjacent surface water drainage systems. Bin lids must be kept closed and locked to prevent cross-contamination and rodent or vermin access.

Section 6 – Documentation

There must be a hazardous waste consignment note for each hazardous waste collection and waste transfer notes for non-hazardous waste. Waste must be described accurately and fully on the accompanying documents when removed and transferred to an authorised person for transport to an authorised waste site.

6.1 - Consignment notes

You must have a hazardous waste consignment note for each collection and a quarterly consignee return for all hazardous waste collections. A consignment note is used to track movement and ensure the safe disposal of hazardous waste.

In line with Regulation 49 of the Hazardous Waste (England and Wales) Regulations 2005, all hazardous waste consignment notes must be retained for a minimum of 3 years from the date on which the waste is transferred to the waste carrier.

Every quarter, the waste collection company (consignee) must also provide the practice with a consignee return.

These should be sent to the practice within one month of the end of the quarter, during which the waste was accepted. Without consignee returns, your records are incomplete. If the waste contractor did not provide them, you must request them in writing.

6.2 - Waste transfer notes (WTNs)

These are used to collect non-hazardous waste. The dental practice completes a waste transfer note provided by the waste company. Legal responsibility for describing the waste rests with the dental practice. If a contractor collects the same waste at regular intervals over a period no longer than 12 months, an annual duty of care waste transfer note for non-hazardous waste is usually provided for completion by the practice.

In line with Section 35 of the Waste (England and Wales) Regulations 2011, waste transfer notes must be retained for a minimum of 2 years.

Section 7 – Waste audits

Under environmental legislation, waste producers are responsible for the safe control, management, transport, and disposal of their waste. Your waste company likely sends waste to a Clinical Waste Alternative Treatment Plant or clinical waste incinerator. These sites are required to obtain a pre-acceptance audit from healthcare waste producers. Therefore, your waste company may ask you to complete a pre-acceptance audit. They will either offer to do this for you, usually at a small fee, or you can undertake your own audit using (M 269A). If you are required to conduct an audit, it should be reviewed every 2 years.

Further information

• Environmental Protection Act 1990
• HTM 07-01: Safe and sustainable management of healthcare waste
• WHTM 07-01: Safe and sustainable management of healthcare waste
• NHS clinical waste strategy (England)
• NHS Wales Decarbonisation Strategic Delivery Plan
• HTM 01-05: Decontamination in primary care dental practices
• The Hazardous Waste Regulations (England and Wales) 2005
• The Waste (England and Wales) Regulations 2011
• The Control of Substances Hazardous to Health Regulations 2002
• The Waste Separation Requirements (Wales) Regulations 2023
• Welsh Government: Separate Collection of Waste Materials for Recycling: A Code of Practice for Wales
• Simpler recycling: workplace recycling in England - GOV.UK