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Waste Management Policy

Last modified: 15 May 2026

Purpose

The purpose of this policy is to ensure we fulfil our legal Duty of Care that waste is managed in a safe and compliant manner to avoid unnecessary harm to human health and the environment.

The procedures set out in this policy also align with national guidance such as HTM 07-01 to support the targets of eliminating avoidable waste by placing an emphasis on segregation based on the infectious and/or hazardous properties, including the utilisation of the offensive waste stream for non-infectious waste to promote more cost-effective and sustainable treatment methods.

[NHS England: By correctly classifying and segregating healthcare waste, we are making a commitment to achieving the 2026 NHS Clinical Waste Strategy targets as set out below, which contributes to the government's overall strategy to achieve net zero carbon emissions by 2050:

  • 20% of healthcare waste to be segregated and disposed of through the orange waste stream
  • 20% of healthcare waste to be segregated and disposed of through the yellow waste stream
  • 60% of healthcare waste to be segregated and disposed of through the offensive waste stream]

Responsibilities

This policy applies to all team members, contractors, and individuals, who are involved in the generation, handling, storage, transportation, and disposal of waste.

The Practice Manager (Murray Pratt) is responsible for the implementation and monitoring of this policy, including oversight of waste segregation based on its infectious and/or hazardous properties.

Definitions

Hazardous waste

A waste product is classified as hazardous if it can cause harm to humans or the environment, this includes products marked with a corresponding hazard warning/label.

Non-hazardous waste

If the above does not apply, then the waste can be treated as non-hazardous and can be managed as either offensive waste, residual/municipal waste, recyclable waste, or confidential waste.

Healthcare waste

This covers all waste that is produced directly from dental activities, which is then sub-categorised as follows:

  • Clinical waste
    Healthcare waste that contains infectious pathogens that can cause disease in humans is treated as hazardous.
  • Offensive waste
    Healthcare waste that contains body fluids, secretions, or excretions, and is not deemed infectious. Whilst offensive waste can be associated with unpleasant smells and appearance, it is to be treated as non-hazardous.

Circular Economy

The aim of a circular economy is to avoid and prevent unnecessary waste production by focusing on the regeneration of natural systems, designing out waste and pollution, and keeping products and materials in use.

Waste Hierarchy

As part of the duty of care to manage waste effectively, the waste hierarchy sets out the steps that must be taken in the appropriate order of priority as detailed below:

  • Prevention
  • Correct segregation
  • Recirculate back into use
  • Recycle
  • Generate for energy sources
  • Dispose
  • Landfill

Waste classification

All healthcare waste is classified based on its infectious and/or hazardous properties.

The clinical team will review the patient's medical history at the start of each appointment and will make a judgment on the infectious risk of that patient to determine the correct waste stream.

To judge the risk, an assessment is undertaken based on the patient, their circumstances, and medical history, with consideration given to the below:

  • Is the patient being treated for infection?
  • Is the patient carrying a transmissible disease?
  • Does the patient have a history of known infection?
  • Has the patient been identified as potentially infectious by the clinician?

If the answer is yes to any of the above, the healthcare waste is treated as infectious and disposed of as clinical waste.

If there is no good reason to believe that the healthcare waste is infectious, or hazardous, e.g., chemically/pharmaceutically/cytotoxically contaminated or radioactive, it is not classified as clinical waste but instead treated as offensive waste.

The following colour-coded waste streams are used for the disposal of waste based on its classification:

  • Orange: Healthcare wastes that are identified as infectious (clinical/hazardous waste)
  • Yellow: Infectious wastes that are contaminated with medicinal products (clinical/hazardous waste)
  • Purple: Cytotoxic and cytostatic healthcare waste (clinical/hazardous waste)
  • Blue: Medicinal/Pharmaceutical healthcare waste (non-hazardous waste)
  • Yellow/Black (Tiger-striped): Healthcare wastes identified as non-infectious (offensive/non-hazardous waste)
  • Black: Residual/municipal waste, excluding products with a hazard warning/label (non-hazardous)
  • White/Clear: Recyclable waste (non-hazardous)
  • Light Blue: Confidential waste (non-hazardous)

Under no circumstances will any of the waste streams above be combined, as this would result in a breach of our statutory duty of care to avoid the mixing of hazardous waste with non-hazardous waste, or other types of hazardous waste.

Waste segregation

Where the prevention of waste is unachievable, all waste is segregated to comply with the waste hierarchy. It is the responsibility of all persons to familiarise themselves and adhere to the below.

Clinical waste

[Soft waste produced from patients who are suspected to be, or have been identified as infectious, is disposed of in the orange bag/bin.

Soft waste that is medicinally contaminated and from patients who are suspected to be, or have been identified as infectious, is disposed of in the yellow bag/bin.]

Offensive waste

Soft waste produced from patients who are not believed to be infectious is disposed of in the tiger-striped bag/bin, this includes nappies and sanitary waste (unless they are from an infectious person).

Sharps waste (non-cytotoxic/cytostatic)

Sharps are not considered offensive waste regardless of their infectious properties since they could puncture the bag, but instead are treated as hazardous, and are disposed of in a suitable sharps' container:

  • [Sharps that are not contaminated with medicinal products are placed in an orange-lidded sharps bin]
  • [Sharps that are contaminated with medicinal products are placed in a yellow-lidded sharps bin]

Excess liquid that may be present in the syringe is not discharged down the drain but left in the syringe.

Cytotoxic/cytostatic waste

Any sharps contaminated with a medicinal product labelled as 'acute toxicity', 'carcinogenic', 'toxic for reproduction', and/or 'mutagenic', are placed in a purple-lidded sharps bin.

Excess liquid that may be present in the syringe is not discharged down the drain but left in the syringe.

[All other cytotoxic/cytostatic waste items are disposed of in a purple-lidded pharmaceutical bin.]

Medicinal/Pharmaceutical waste

Liquid medicines are not discharged down the drain, instead, the medicines and their containers are disposed of in a designated, blue-lidded pharmaceutical waste bin.

Anatomical waste

Extracted teeth are managed and disposed of as follows:

  • Whole non-infectious teeth are disposed of in the offensive waste bag/bin
  • Jagged or broken teeth and tooth spicules are disposed of in a yellow-lidded sharps bin
  • Teeth containing amalgam are treated as hazardous due to their mercury content, and are disposed of in a designated dental tooth box, with any leftover amalgam disposed of in a separate amalgam pot
  • Teeth containing precious metals such as gold, silver, platinum, and palladium are disposed of in a designated dental bridge and crown pot

Chemical waste

Products labelled with a hazard warning are segregated, packaged, and disposed of in accordance with the accompanying material safety data sheet (MSDS).

  • [X-ray Fixer and Developer: These are not mixed with each other and are stored in their own separate containers that are clearly labelled to identify their contents.]

[Gypsum waste

Although it is unlikely that gypsum waste will be infectious as it should not come into direct contact with a patient, it is still segregated and disposed of as its own waste stream and is stored in a designated dental gypsum container. If, however, the gypsum waste has been assessed and identified as infectious or is suspected to be infectious, then it is stored in a separate gypsum container to that of non-infectious gypsum waste]

Residual/municipal waste

General waste is disposed of in a black bag/bin.

[Recyclable waste

Dry recyclables are separated, kept clear of non-recyclables to avoid cross-contamination, and disposed of in the appropriately labelled bins that are available.]

Electronic waste

Redundant electrical equipment is managed in accordance with the Waste Electrical and Electronic Equipment Regulations 2013 (WEEE) and is stored in a safe, secure area to await collection, taking care not to damage it further if it can be repaired or reused.

Electronic equipment containing sensitive personal data, such as redundant hard drives, laptops, etc. are reformatted, erased, or restored to factory settings, to ensure all data is removed before disposal.

Gas cylinders

Redundant or empty gas cylinders, including medical gases, and portable fire extinguishers, are treated as hazardous and are managed as follows:

  • Gas cylinders are stored in a secure and restricted area away from sources of heat
  • Gas cylinder storage rooms display the appropriate hazard warning signage
  • Where feasible, empty gas cylinders are separated from full ones
  • Full and empty gas cylinders are clearly labelled as such

Batteries

Batteries are not disposed of as residual/municipal waste, but instead, are segregated and disposed of using one of the local supermarket 'takeback' recycling facilities/bins.

Waste storage

When handling clinical and offensive waste bags, the following are adhered to:

  • Bags are not filled more than two-thirds full
  • Bags are tied using a zip-tie, or a secure knot
  • Bags are never opened to examine or retrieve any of the contents
  • Bags are never compressed by force
  • Bags that are split or leaking are not moved until it has been placed inside a new bag

All waste containers are kept secure, leak-proof, puncture-resistant, and clearly labelled, indicating the waste type and its infectious and/or hazardous properties.

Healthcare waste bags and containers are tagged individually with the postcode of the practice before collection.

External waste containers are kept locked and are secured in a manner preventing unauthorised interference.

Waste collection and disposal

All waste streams are collected by a licensed waste carrier to ensure safe and compliant collection, transportation, and disposal.

Electronic equipment is returned to the producer/manufacturer if a collection service is available or collected and disposed of by a licensed WEEE waste management company.

Hazardous waste

Hazardous waste consignment notes (HWCNs) are prepared and completed in full by completing both Parts A and B before any hazardous waste is removed from the premises. The responsibility for this lies with the practice, as the producer of the waste. A copy of the completed consignment note is then provided to the hazardous waste carrier.

Copies of HWCNs are retained for a minimum period of 3 years.

Non-hazardous waste

Waste transfer notes (WTNs) are prepared and completed in full for any non-hazardous waste that is removed from the premises. The responsibility for this falls upon the practice as the producer of the waste, as well as the appointed waste carrier.

Copies of WTNs are retained for a minimum period of 2 years.

Training and education

All team members involved in waste management, including agency staff where recruited, receive training in the proper handling and disposal of healthcare waste, with an emphasis placed on waste segregation based on its infectious properties.

Training is supported by visual aids such as waste segregation posters (M 269B) that are displayed around the practice.

The training is provided for new team members during the induction program and is refreshed on an annual basis during staff meetings for existing team members, or sooner if there are changes to existing procedures, or following a waste-related incident.

Training records are maintained, kept up to date, and held within the team files.

Staff protection

PPE is available and used by all team members involved in the generation, handling, storage, transportation, and disposal of waste.

Team members involved in handling infectious waste are encouraged to undergo vaccinations in line with the Department of Health and Social Care: Green Book chapter 12.

Any person who believes to have been exposed to an infectious disease must notify the practice manager (Murray Pratt) immediately and seek medical advice from the local A&E department or Occupational Health.

Procurement

To achieve a circular economy and minimise our waste footprint, where possible, we prioritise the purchase of products and services that are environmentally friendly.

By adopting a sustainable procurement approach, it is our aim to work towards reducing waste, conserving resources, and minimising energy consumption.

When procuring products, it is the responsibility of all team members to consider the five Rs of sustainable procurement in the following order:

  • Reduce: Only purchase products that are necessary, and avoid bulk buying
  • Reuse: Prioritise the purchase of reusable items and avoid single-use items, especially plastics
  • Reprocessed: Consider reprocessed or refurbished products as an alternative to new
  • Renewable: Consider products that are made of renewable or biodegradable materials
  • Recyclable: Consider products that are recyclable

Audit

Regular audits and inspections are conducted to monitor and implement continuous improvements.

Duty of care waste audit

A 6-monthly audit of the performance of waste management and segregation is undertaken as part of the infection prevention and control audit to ensure compliance with this policy.

Pre-acceptance waste audit

To comply with our legal obligation as a producer of healthcare waste, a 'pre-acceptance waste audit' is undertaken and reviewed every 2 years by the Practice Manager Larisa Zlat and provided to the appointed waste carriers when requested. Where these are not provided by the appointed waste carrier, we use our own pre-acceptance waste audit template (M 269B).

Any non-compliance identified following the above audits is addressed promptly, and corrective actions are taken as appropriate.