Guide
Sanitary waste disposal rules for UK businesses
Updated
Most of what is sold to employers about sanitary waste is a bit more alarming than the actual rules. Here are the actual rules.
It is offensive waste, not clinical waste
The Environment Agency defines offensive waste as non-clinical waste that is non-infectious and does not contain pharmaceutical or chemical substances, but may be unpleasant to anyone who comes into contact with it. Hygiene waste and sanitary protection such as nappies and incontinence pads is listed as municipal offensive waste, waste status non-hazardous, classification code 20 01 99 (gov.uk: healthcare and related wastes, how to classify).
Healthcare offensive waste, which is a different thing, covers outer dressings and protective clothing contaminated with body fluids and sterilised laboratory waste, and carries codes 18 01 04 and 18 02 03. If your premises is an ordinary office, shop, school or warehouse, the code you are dealing with is 20 01 99.
The 7kg threshold
The same guidance sets a genuine, checkable threshold. Healthcare offensive waste must always be segregated from clinical and mixed municipal waste. For municipal offensive waste, GOV.UK states: if you have produced more than 7kg, or have more than one bag in a collection period, you must segregate it from any mixed municipal waste. If you have produced less, you can dispose of it in your mixed municipal waste, the black bag, using classification code 20 03 01.
That is worth knowing before anyone tells you a two-person office is legally required to hold a hygiene contract. A very small workplace may fall below the threshold. Most workplaces with a women's washroom in regular use will not, and a contract is the practical way to comply.
The duty of care applies either way
- Complete a waste transfer note for each load of waste that leaves your premises, or a document with the same information such as an invoice.
- Both parties sign it and keep a paper or electronic copy for 2 years, and produce it to a local council or Environment Agency officer on request.
- Check your waste carrier is registered, and do not allow them to dispose of your waste illegally.
- Sort and store waste safely and securely, and keep it to a minimum by preventing, reusing, recycling or recovering, in that order.
Source: gov.uk: dispose of business or commercial waste and waste transfer notes.
Season tickets suit a service contract
For a repeating collection you do not need a fresh note every visit. GOV.UK allows a season ticket covering multiple transfers of non-hazardous waste for up to a year, provided the holder of the waste, the carrier and the type of waste all stay the same, supported by a schedule recording the date, time and quantity of each transfer. Keep the season ticket and schedule for 2 years after the last transfer. If your provider is not giving you either, ask why.
Checking the carrier takes a minute
Anyone transporting waste must register, and GOV.UK warns of an unlimited fine for failing to. Registration costs £191.02, or is usually free where a business only transports waste it produces itself, and upper tier registrations are renewed every 3 years for £130.25 (gov.uk). Registered organisations appear in the public register of waste carriers, brokers and dealers. Ask any provider for the registration number that starts with CB, and check it.
Different rules apply in Scotland, Wales and Northern Ireland, and healthcare premises have their own segregation regime. This page states the position for ordinary workplaces in England as published on GOV.UK on the updated date above.