What Is A Clinical Waste Pre-Acceptance Audit?
A clinical waste pre-acceptance audit is a review of the healthcare waste a site produces before it’s accepted by a permitted healthcare waste facility. It confirms what waste is produced, how it’s classified, how it’s segregated, what containers are used, and whether the proposed treatment route is appropriate.
If your business produces the waste, you’re responsible for arranging the audit. The waste receiving operator must obtain and assess the audit before accepting any waste from your site.
At a glance: What is a clinical waste audit?
A clinical waste audit is a structured review of the waste generated by a healthcare or medical site. A pre-acceptance audit specifically provides the information a waste operator needs before taking that waste.
NHS HTM 07-01 guidance distinguishes:
- Waste pre-acceptance audits, carried out by waste producers
- Waste acceptance audits, carried out by waste facility operators.
The audit should reflect actual practice on site, not just written policies. It should be representative of the different departments, wards or activities producing waste.
Why do we audit clinical waste?
Clinical waste can include infectious, medicinal, chemical, sharps and anatomical waste. Different waste often requires separate containers, colour-coding, classifications and treatment routes. The nature of clinical waste means it’s not safe for waste operators to open bags and check what’s inside them. Sharps and infectious materials can cause serious harm when handled.
Accurate pre-acceptance audits help prevent:
- Incorrect segregation
- Wrong treatment
- Non-conforming waste
- Unnecessary incineration
- Contamination between streams
- Health and safety risks
- Regulatory breaches
The audit gives the waste facility confidence that the waste arriving on site matches the description, classification and treatment route agreed in advance.
Who needs a clinical waste pre-acceptance audit?
Environment Agency (EA) guidance requires a clinical waste pre-acceptance audit to be completed by relevant medical practices. Common examples include:
- Hospitals
- GP surgeries and health centres
- Dental practices
- Veterinary practices
- Laboratories
- Community pharmacies
- Ambulance services
- Care homes providing nursing or medical care
- Other healthcare or medical practices producing clinical waste
A pre-acceptance audit is not required if the waste is produced at a domestic premises, or for care homes that do not provide nursing or medical care.
What does a clinical waste pre-acceptance audit check?
The waste producer
The report should record:
- Name and address
- Contact details
- Type of healthcare practice
- Audit dates
- Who carried out the audit and their competence
Areas producing waste
It identifies areas such as:
- Wards
- Departments
- Treatment rooms
- Pharmacies
- Laboratories
- Dental areas
- Other clinical or functional areas
The audit also outlines which activities produce which waste streams.
Waste types
The audit should consider waste including:
- Cytotoxic and cytostatic contaminated waste
- Pharmaceutical waste
- Medicinally contaminated items
- Chemicals
- Human or animal tissue
- Sharps
- Infectious waste
- Dental amalgam
- Offensive waste
- Non-hazardous healthcare waste
- Gypsum waste where relevant
Classification and packaging
For each waste type, record:
- Waste description
- List of Waste code
- Physical form
- Composition
- Hazardous properties
- Container or bag type
- Colour coding
- Labelling
- Proposed treatment route
Actual segregation practice
The auditor should check:
- Whether the right waste is actually going into the right container
- How waste is stored
- Bulk containers and carts
- Any specialist storage requirements
- Staff understanding of segregation
A waste audit is not simply a paperwork exercise, so this step is important.
Is clinical waste colour-coding checked during the audit?
EA HTM 07-01 guidance specifies segregation and colour-coding of packaging. If a specific colour is not prescribed for a waste stream, the facility operators should choose the most appropriate container based on the waste and the authorised treatment route.
Examples of colour-coding clinical waste include:
Yellow: waste requiring incineration
Orange: infectious waste suitable for alternative treatment
Black or black/yellow: waste suitable for municipal incineration in relevant cases
Read further colour-coding guidance on our dedicated clinical waste container page.
How often is a clinical waste pre-acceptance audit required?
EA minimum frequencies are:
- Every 12 months: medical practices producing five tonnes or more of clinical waste in a calendar year.
- Every two years: veterinary practices, dental practices and laboratories producing less than five tonnes per year.
- Every five years: other healthcare waste producers.
If your medical practice produces five tonnes or more, the first audit must cover the whole practice. If this audit is satisfactory, following annual audits can cover one third of wards, units or departments. However, over a three-year cycle, all areas must be audited. If your practice produces less than five tonnes, each audit should cover the whole site.
An audit can become invalid early if there are:
- Significant changes in site practices
- Waste stream changes
- Significant non-conformance between the audit and waste actually received
What happens after a pre-acceptance audit?
The process usually follows a journey:
1: The producer completes the audit.
2: The report is sent to the waste operator.
3: Competent technical staff assess it.
4: The operator checks whether:
- Waste is correctly classified
- Packaging is appropriate
- The facility is permitted to accept it
- The treatment route is suitable
5: If information is missing, the operator requests more detail or another audit.
6: If the waste is suitable, it can be approved for collection and acceptance.
7: The operator then checks incoming loads against the pre-acceptance information.
Note: Passing a pre-acceptance audit does not mean every future load is accepted automatically. Waste operators still have to check incoming waste for non-conformances.
What happens if clinical waste fails an audit?
Possible reasons why clinical waste may fail an audit include:
- Wrong waste in a container
- Incorrect colour coding
- Incorrect List of Waste code
- Missing hazardous properties
- Poor storage
- Staff not following segregation procedures
- Waste generated that was not included in the audit
A failed audit doesn’t automatically lead to enforcement action. However, your business may be required to correct any issues, retrain staff, change container type or re-issue the audit.
Clinical waste audit preparation checklist
- Review every clinical waste stream: Know what is produced in each department or treatment area.
- Check bin and bag colours: Make sure containers match the waste and treatment route.
- Review waste codes: Check that waste descriptions and classifications are accurate.
- Inspect storage areas: Make sure waste is kept securely and appropriately.
- Check labels: Containers should have the required information.
- Speak to staff: Confirm people understand which waste goes where.
- Review previous non-conformances: Make sure earlier issues have been corrected.
- Gather records: Have waste policies, training information and previous audit reports available.
- Estimate quantities: Know typical and annual volumes for each waste stream.
Clinical waste pre-acceptance audit FAQs
-
What is a clinical waste pre-acceptance audit?
A review carried out at a healthcare waste producer’s premises to identify and verify the waste streams generated before they are accepted by a permitted healthcare waste facility.
-
How often do clinical waste audits need to be completed?
It depends on the type of producer and amount of clinical waste generated. Minimum Environment Agency frequencies range from annually to every five years.
-
Can a clinical waste audit be completed online?
Not entirely. Environment Agency guidance requires physical presence at the premises for a pre-acceptance audit.
-
Who carries out a clinical waste audit?
A suitably trained and experienced member of staff or an external competent auditor can carry it out.
-
What happens if my clinical waste changes after an audit?
A new or updated audit may be required if there is a significant change to the waste produced or the way it is managed.
Have your waste collected
Get a fast FREE quote for your waste collection 0800 211 83 90
- Free quote within 1 hr
- Any type of waste
- FREE bins and delivery
- We cover all of the UK