Guidance

Incinerating specified healthcare wastes at a municipal waste incinerator: RPS C4

Published 15 April 2020

This guidance was withdrawn on

This COVID-19 regulatory position statement has expired.

Applies to England

Your environmental permit states the waste types and quantities you can accept. Normally you will breach your permit conditions if you accept waste types or quantities beyond those stated in your permit.

If you follow the conditions in this COVID-19 regulatory position statement (RPS) you can accept and incinerate COVID-19 infectious waste at a municipal waste incinerator without varying your environmental permit.

You must get written agreement from the Environment Agency before you use this COVID-19 RPS. Contact the Environment Agency.

When this COVID-19 RPS applies

This COVID-19 RPS only applies to operators of permitted municipal waste incinerators.

It sets out when you can accept and incinerate COVID-19 infectious waste without varying your environmental permit – provided you comply with its conditions.

Conditions you must comply with

You must comply with all of these conditions.

Condition 1

You must limit the healthcare waste to the following European Waste Catalogue (EWC) classifications. These waste types cannot include sharps waste.

  • 18 01 03* – orange bagged and containerised infectious waste from human healthcare activities

  • 18 01 03* and 18 01 07 – yellow bagged and containerised infectious waste from human activities dual coded with non-hazardous chemicals

  • 18 01 04 and 20 01 99 – offensive hygiene wastes (human)

  • 15 02 02* – absorbents, filter materials (including oil filters not otherwise specified), wiping cloths, protective clothing, contaminated by hazardous substances (COVID-19 cleansing waste)

Condition 2

You can demonstrate the waste producer has used all other appropriate permitted options available for the waste’s treatment or incineration.

Condition 3

You have a written management system and follow its procedures for handling and managing the healthcare waste.

Condition 4

You can identify all the healthcare waste you accept at your site by the date of arrival, original producer details, and type of waste including the EWC code.

Condition 5

You comply with the requirements for waste pre-acceptance, waste acceptance, handling and storage in sector guidance note How to comply with your environmental permit: additional guidance for clinical waste.

Condition 6

You make sure that burning the additional waste types at the plant will not have an adverse impact on plant emissions or the residues it produces.

Condition 7

Where reasonably practicable, you must do at least one round of equivalent emissions monitoring for the healthcare wastes in condition 1 – as specified in the periodically monitored pollutants requirements in your permit. You must do this no later than one month after accepting the healthcare wastes.

Condition 8

You must test your incinerator bottom ash (IBA) and compare it with tests from before you incinerated the healthcare waste to confirm there is no change to the IBA composition.

Where reasonably practicable, you must do this 2 weeks from the date you first incinerated the healthcare waste in the plant, and no later than 4 weeks after.

If there are any changes in the IBA composition you must notify and discuss this with the Environment Agency.

Condition 9

You must not load (known as charge) any waste if the activated carbon abatement system stops, is disturbed or fails, other than under abnormal operating conditions.

Condition 10

You must not store healthcare waste at the facility for longer than 24 hours before incineration except in exceptional circumstances, such as unplanned outages. If you need to store it for more than 24 hours you must notify the Environment Agency immediately.

Condition 11

If you accept hazardous waste under this COVID-19 RPS you must submit quarterly hazardous waste consignee returns to the Environment Agency.

Condition 12

You must submit a monthly report to your local Environment Agency office, detailing the amounts and types of waste burned under this COVID-19 RPS.

Condition 13

You must make sure your activities do not endanger human health or the environment.

You must not:

  • cause a risk to water, air, soil, plants or animals
  • cause a nuisance through noise or odours
  • adversely affect the countryside or places of special interest

Enforcement

A COVID-19 RPS means that the Environment Agency will not normally take enforcement action against you provided:

  • your activity meets the description set out in this COVID-19 RPS
  • you comply with the conditions set out in this COVID-19 RPS
  • your activity does not, and is not likely to, cause environmental pollution or harm human health

When to check back

This COVID-19 RPS will be withdrawn on 30 June 2020. After this date you must have a permit authorising the activity or stop accepting the wastes listed in condition 1 at your facility.

Contact the Environment Agency

You must get written agreement from the Environment Agency before you use this COVID-19 RPS.

Email enquiries@environment-agency.gov.uk

Please put this wording in the title of your email:

Waste COVID-19 RPS C4 – for action