4.5 Health care risk waste

4.5(1)
Due to the significant risks associated with Healthcare Risk Waste (HCRW) and the strategic challenges outlined in Section 1.6, this is an area of priority for regulation in terms of the Waste Act’s provisions for listed waste management activities. This will, in turn, impact on the Department’s capacity requirements in terms of its responsibilities for monitoring, compliance and enforcement.

4.5(2)
In terms of implementing the waste hierarchy, the key challenges in terms of health care risk waste management lie in the safe treatment and disposal of this waste.

4.5(3)
These challenges need to be addressed on the basis of accurate information on quantities of HCRW to ensure that scarce government resources are efficiently allocated in addressing capacity shortages. The Department will seek to achieve full compliance of all thermal HCRW treatment facilities within 3 years of the gazetting of the air quality standards. Facilities that are unable to achieve compliance will be required to produce plans for their decommissioning within 1 year of the date on which the air quality standards came into effect.

4.5(4)
Once the standards for non-thermal HCRW have been developed through the HCRW regulations, all permits for non-thermal HCRW treatment facilities will be reviewed to ensure alignment and compliance. Where non-thermal HCRW treatment facilities are not able to comply plans for their decommissioning within one year of the publication of the HCRW regulations with a view to decommission within three years of the gazetting of the HCRW regulations.

4.5(5)
In addition to aligning with the overall objectives of the Waste Act, the regulatory priorities for the HCRW sector are:

• Establish reporting requirements and thresholds for SAWIS for the generation, treatment and disposal of this waste. To this end, HCRW has been included as a primary category in SAWIS.
• HCRW is also considered a pre-classified waste in terms of the WCMS.
• Systems to facilitate segregation within health care institutions have been developed for the rural and urban environment and have been piloted at institutions within these settings. In order to achieve the desired level of segregation these systems are to be rolled out to healthcare institutions nationally.
• Define safe, measurable and achievable minimum standards for the storage, collection, and transport, for HCRW management. These will include standards for new treatment procedures including low-heat thermal treatment, chemical, irradiative and biological processes in addition to incineration.
• Implement the performance standards for thermal treatment technologies which are being formalised through the air quality emission standards process and develop performance standards for non-thermal technologies through the HCRW regulations development process.

4.5(6)
The Policy on Health Care Risk Waste Management being developed by DEA indicates that each health care institution must develop a HCRW management plan to ensure that HCRW is managed in a manner which is protective to third parties and which is environmentally sound.  This plan must include the appointment of healthcare waste officers, provide information on waste quantities and management measures, and awareness and training programmes.

4.5(7)
A differentiated approach that distinguishes between major and minor generators will be adopted to ensure regulation that is both practical and protects the public from exposure to HCRW. Differentiation will be based on the types and quantities of wastes generated, and will take into account the risk posed by even small quantities of HCRW. Individual medical practitioners must be issued with receipts by accredited licensed HCRW facilities that indicate the quantity and type of waste disposed. This will be enforced by the Medical and Dental Council, with the requirement to present such receipts becoming part of annual registration procedures for medical practitioners.