Brilliant Bins The Sanitary Bin Guide for General Practices & Health Centres in England

There is a lot of misunderstanding about what the law requires organisations to provide in the way of sanitary bins, and the classification and disposal of feminine hygiene waste. This sector-specific guide informs managers of GP Practices and Health Centres in England of the options, legislation and regulatory guidance that control: Disposal of feminine hygiene waste Provision of sanitary bins for staff toilets Provision of sanitary bins for service user toilets

General practice managers will be aware of that there are separate commercial and healthcare waste streams generated by the practice, but may not realise that feminine hygiene waste from the womens toilets is assessed not as a healthcare waste, but as commercial waste. Following on from the information specific to a general practice, the guide includes our general information applicable to all organisations. Some of the source legislation for Wales, Scotland and Northern Ireland varies from the guide for England, but the practical results are the same. The guides have been prepared to demonstrate that using our disposable sanitary bins ensures compliance with your responsibilities to provide sanitary bins, and that disposal of feminine hygiene waste in commercial waste complies with waste legislation and the guidance from the Department of Health. If you would like further information or a no-obligation discussion about your own disposal arrangements, please do contact me.

Susan Hofgartner is the inventor of the Brilliant Bin system of completely disposable, self-managed, feminine hygiene waste bins. Launched in 2010 the awardwinning bin offers a low cost and environmentally friendly solution, in full compliance with legislation.

Brilliant Bins is a trading name of Seiquelle Innovation Ltd, 103 High Street, Hungerford, Berkshire RG16 0NB www.BrilliantBins.co.uk sales@BrilliantBins.co.uk Tel: 01488 684850 Seiquelle Innovation Ltd 2013

Summary Key Facts:

Feminine hygiene waste from the womens toilets is a commercial (not healthcare) waste. Up to 7kg of feminine hygiene waste can go into any one commercial collection cycle. The CQC regulates the standards of safety and suitability of practice premises. Separate toilet facilities for staff should be provided in addition to service user toilets. Workplace regulations require provision of sanitary bins in staff toilets used by women. Department of Health Health Building Notes provide guidance on equipment in toilets in healthcare premises. DISPOSAL OF FEMININE HYGIENE WASTE IN COMMERCIAL WASTE The Department of Health The Department of Health publication Safe Management of Healthcare Waste Version 2.0 England, is intended as UK wide guidance, but is most generally applicable in England. It is the prime source of information on waste management for healthcare organisations and incorporates sector-specific guidance for GP Practices and Health Centres on pages 344 to 369. It makes clear that feminine hygiene waste from toilets can be placed in the municipal (commercial) black bag wastes where the total quantity is less than 7kg in a collection interval (see pages 350-351). (Link to document on www.gov.uk/dh) PROVISION OF SANITARY BINS IN WORKPLACE TOILETS The applicable law is the Workplace (Health, Safety and Welfare) Regulations 1992 paragraphs 20 and 21. The Regulations do not specifically mention bins for sanitary waste, but do have an overriding condition that sanitary conveniences (ie washroom facilities) should be suitable and sufficient. The Health and Safety Executive, however, in the Approved Code of Practice related to the above Regulations, issue their interpretation of suitable and sufficient which includes: In the case of water closets used by women, suitable means should be provided for the disposal of sanitary dressings. This regulation is specific to staff toilets, so for guidance on provision of toilets and equipment for all users of the premises it is necessary to look to other legislation and guidance:

PROVISION OF SANITARY BINS IN TOILETS FOR USERS OF THE PRACTICE OR HEALTH CENTRE PREMISES To understand this, it is useful to follow through: The Health and Social Care Act 2008 (Regulated Activities) Regulations 2010 This regulation lays out responsibilities for the quality and safety of service provision in relation to regulated activities, which include healthcare establishments.

Brilliant Bins is a trading name of Seiquelle Innovation Ltd, 103 High Street, Hungerford, Berkshire RG16 0NB www.BrilliantBins.co.uk sales@BrilliantBins.co.uk Tel: 01488 684850 Seiquelle Innovation Ltd 2013

Part 4, regulation 15 covers the Safety and suitability of premises for users of services and people who work in or visit premises where a regulated activity takes place.

The appointed regulator is the: The Care Quality Commission Section 23(1) of the Health and Social Care Act 2008 requires the Care Quality Commission to produce guidance for providers of health and adult social care, to help them comply with the regulations within the Act that govern their activities. They do this in: CQC Publication: Guidance about compliance: Essential standards of quality and safety Outcome 10 Safety and Suitability of Premises for Doctors Consultation Services (DCS) and Doctors Treatment Services (DTS) This includes: Requirements that managers of premises: o o o o Have clear procedures for disposal of waste Comply with Health and Safety Executive guidance Comply with all current Health Building Notes (HBNs) and Health Technical Memorandums (HTMs) published by the Department of Health Have sufficient toilets, and where necessary bathroom facilities, that take into account peoples diverse needs and promote their privacy, dignity and independence.

Health Building Notes: Health Building Notes give best practice guidance on the design and planning of new healthcare buildings and on the adaptation/extension of existing facilities. There are two HTMs relevant to WCs and provision of sanitary bins. HBN 11-01: Facilities for primary and community care services. Its recommendations include separate staff and public zones, each with their own WC facilities. For design of the WCs it refers to HBN 00-02. (link to HBN 11-01 at www.gov.uk/dh)

HBN 00-02: Sanitary spaces Design, equipment and activity requirements for the whole range of WC rooms that may be found at a primary or community care centre can be found in chapter 5 of this HBN. The specification of the majority of WC types mention that users may potentially need to dispose of sanitary towels and wipes. Therefore an appropriate bin should be supplied. (link to HBN 00-02 at www.gov.uk/dh)

Brilliant Bins is a trading name of Seiquelle Innovation Ltd, 103 High Street, Hungerford, Berkshire RG16 0NB www.BrilliantBins.co.uk sales@BrilliantBins.co.uk Tel: 01488 684850 Seiquelle Innovation Ltd 2013

So what sanitary bin options are available to healthcare organisations: No Bin? Not an option under Department of Health, HSE guidance and Workplace regulations. A simple pedal bin. Fulfills the regulations, cheap, but unlikely to be popular with your staff and other premises users or cleaners, and is unlikely to contribute to a good impression of your practice! Buy your own permanent plastic sanitary bins. This will require your cleaners to empty and clean your own bins, and seeing the contents will be unavoidable. Liners can be used, but as they are flimsy will require double bagging before putting in your commercial waste. A service contract exchange bin. Usually costing from around 100 to 250 per year per cubicle. Service operatives visit your location and swap the bins out, or empty and clean them on site. This option may involve additional costs for production of an annual Duty of Care Waste Transfer Note and Pre-treatment certification. Will involve at least an annual contract, and can be time-consuming to avoid roll-over into multi-year contracts. Fixed service intervals may mean problems if the bins fill up sooner than expected, or need cleaning between visits. Larger premises may find this option more economical than disposable bins, although environmental considerations may also come into the decision. Disposable sanitary bins from Brilliant Bins. These are low cost, environmentally friendly bins that can be disposed of in commercial waste. Designed for use in business and healthcare premises, and costing around 50 per cubicle per year. This waste will be included on the commercial waste collection duty of care waste transfer note so no additional costs. No contract negotiations as they are purchased as required just like any other washroom supply. They are supplied flatpacked, so 6 or 12 months requirements will fit easily in your janitorial supplies cupboard. Your cleaning staff will appreciate the fact that they do not have to see the contents of the bins, as the whole bin is disposed of, when full, in a supplied black bin bag. A video demonstrating the operation of the bin from set up to disposal is available on our website www.brilliantbins.co.uk. If you would like to discuss these options in more detail, do please contact me. I can also, with no obligation, review your current contract, and comment on the costs, terms and conditions and cancellation arrangements. Susan Hofgartner BSc (Hons) ARCS ACMA Web: www.BrilliantBins.co.uk LinkedIn: Susan Hofgartner

Brilliant Bins is a trading name of Seiquelle Innovation Ltd, 103 High Street, Hungerford, Berkshire RG16 0NB www.BrilliantBins.co.uk sales@BrilliantBins.co.uk Tel: 01488 684850 Seiquelle Innovation Ltd 2013

Frequently asked questions for all organisations:

How much sanitary waste can go in my main waste collection bin? How easy is it for the cleaning staff to manage your disposable sanitary bins? I have been told our sanitary bin waste is controlled or offensive waste and must be collected by a specialist service. Is this correct? Do you provide guidance on Duty of Care - Waste Transfer Notes? Is Brilliant Bins registered with the Environment Agency? How can I check the registration of my waste collector? How environmentally friendly is a disposable bin? Im concerned about odour. Why dont you have chemical fragrance powder in the bin? What is Cellogreen Eco-print laminate? Id like to provide bags for items to go into before going in the bin. Do you sell these?

So I can put up to 7kg of sanitary waste in one collection?

As noted above, the limit set by the Department of Health means that up to 7kg in any one collection cycle may go in the black bag waste. One full Brilliant Bin is likely to weigh approx. 1.0 kg and so our customers are unlikely to come near the limit. Remember you only need change the bins when full and therefore you will not be replacing all bins at the same time as with a service contract provider. The Waste Code for black bag waste is 20-03-01 and called Mixed Municipal Waste.

How easy is it for the cleaning staff to exchange the bins?

Very easy, very quick, no fuss, and nothing unpleasant to deal with. Each Brilliant Bin has a plastic sleeve, on the reverse, containing a black bin bag. It is easy for the cleaning staff to check whether the bin needs changing by just picking it up theres no need to look inside. When its time to change the bin, the whole bin is placed in the black bin bag and then, securely double wrapped, it is disposed of within the general waste collection.

I have been told our sanitary bin waste is controlled or offensive waste and must be collected by a specialist service. Is this correct?
All household, commercial and industrial waste is controlled waste as defined in the Environmental Protection Act 1990 and further classified in the Controlled Waste Regulations (England & Wales) Regulations 2012. Therefore sanitary waste is indeed controlled waste. However, you dont need a specialist to collect feminine hygiene waste. Controlled waste may only be transferred to a waste carrier registered with the Environment Agency, and the waste management company collecting your commercial waste will be registered as a waste carrier in exactly the same way as any sanitary bin service
Brilliant Bins is a trading name of Seiquelle Innovation Ltd, 103 High Street, Hungerford, Berkshire RG16 0NB www.BrilliantBins.co.uk sales@BrilliantBins.co.uk Tel: 01488 684850 Seiquelle Innovation Ltd 2013

contract collector. This means that it is perfectly acceptable for your main waste to have a proportion of hygiene waste included. The Controlled Waste Regulations (England & Wales) 2012 define offensive waste from non-healthcare sources (including the commercial activities of a general practice or health centre) as waste for which the code 20-01-99 applies. This code would only apply, for example, to hygiene waste collected in bulk by a serviced sanitary bin contractor. When small amounts of hygiene waste are included in commercial waste the waste is all general municipal waste with code 20-03-01 and so is not offensive/hygiene waste.

Is Brilliant Bins registered with the Environment Agency?

Brilliant Bins is registered with the Environment Agency as both a Waste Carrier and Waste Broker under our company name Seiquelle Innovation Ltd ref CB/HN5010CZ.

How can I check the registration of my waste collector?

You can easily check that your waste collector is registered at the Environment Agency: (link to Environment Agency register search)

Do you provide guidance on Duty of Care - Waste Transfer Notes?

With the Brilliant Bin system, you do not need a specific waste transfer note for your sanitary bins. The completion of a waste transfer note is usually completed annually with your waste management company. You should let your waste management company know that you have a small amount of hygiene waste in your collection. Please request our Waste Transfer Note Information Sheet. It includes suggested descriptions, waste code and details to add to your existing waste transfer note content. Should your waste collection company have any questions, we will be very happy to assist. We have positive agreement from major waste collection companies for our system.

How environmentally friendly is a disposable bin?

Using the Brilliant Bin system reduces the vehicle mileage required to dispose of the waste and eliminates the need for water and chemicals to wash out exchange units. Please request our guide the Environmental and Operational Case for Disposable Bins. The Brilliant Bin is inexpensive and so affordable by every business. It therefore helps to ensure that sanitary waste is not flushed down the loo. It is estimated that 2 billion sanitary items are flushed down the loo each year. More on this from the "Bag it and Bin it Don't Flush it" campaign. The Brilliant Bin enables you to buy 6 months or a years supply of bins and store them compactly in your cleaners cupboard. One delivery replaces multiple trips to your site to deliver exchange units reducing vehicle mileage. Sanitary waste in the Brilliant Bin is collected along with your other commercial waste and so no additional vehicle miles are required. The Brilliant Bin is printed and constructed in the UK, so no shipping from the Far East is involved.
Brilliant Bins is a trading name of Seiquelle Innovation Ltd, 103 High Street, Hungerford, Berkshire RG16 0NB www.BrilliantBins.co.uk sales@BrilliantBins.co.uk Tel: 01488 684850 Seiquelle Innovation Ltd 2013

FSC (Forest Stewardship Council) http://www.fsc.org/about-fsc.htmlcertified box board is the principal material making up the bin. The original pulp is bleached using an elemental chlorine free process, and the board produced at an EMAS accredited mill. It can be disposed of by incineration for energy recovery or is bio-degradeable. Not suitable for recycling due to the content of the bin The glossy laminates major raw material, Cellulose, comes predominantly from managed forestry in North America. The pulp suppliers have active replanting programmes and plant more trees than they harvest each year. Thus this film is distinguished from most other thermoplastic films in that it comes from a sustainable source and is not derived from fossil fuels. The secondary raw material is acetic anhydride, a simple derivative of the everyday tabletop chemical acetic acid (vinegar).

Im concerned about odour. Why is there no chemical fragrance in the Brilliant Bin?
The Brilliant Bin is designed to minimise environmental impact, therefore we do not use chemical powders and fragrance inside the bin. Our research shows that the addition of scented chemicals inside a bin does not make a significant difference to odour outside the bin whether on an exchange bin or for the Brilliant Bin. Occasionally there is an issue which would only be dealt with by changing the bin. You can change a Brilliant Bin immediately, with an exchange bin you may need to wait weeks for the next exchange date. You can also provide small disposal bags for sanitary items to be put in before placing the item in the Brilliant Bin. These are available, along with an optional dispenser, on our product page.

Id like to provide small bags for items to go into before going in the bin. Do you sell these?
Yes, we supply attractive printed paper disposal bags and also a clear Perspex holder if needed. See our website product pages.

What is Cellogreen eco-print laminate?

The glossy laminate inside and outside the Brilliant Bin is not made from fossil fuel based plastics. The primary raw material used in the production of the cellulose acetate laminate is sourced from refined wood pulp from Sustainable Forest Initiative managed forestry. We hope this has assisted you to understand that you can handle your own disposal of hygiene waste as well as use service contract exchange-bin providers. Please do call us if you would like to discuss any of this information further. Susan Hofgartner Susan Hofgartner BSc (Hons) ARCS ACMA
All information is provided in good faith, but we do not accept any liability if you use this advice which is summarised and not tailored to any specific situation.
Brilliant Bins is a trading name of Seiquelle Innovation Ltd, 103 High Street, Hungerford, Berkshire RG16 0NB www.BrilliantBins.co.uk sales@BrilliantBins.co.uk Tel: 01488 684850 Seiquelle Innovation Ltd 2013