Brilliant Bins The Sanitary Bin Guide for Maintained and Independent Schools in England

Sanitary bin regulations Brilliant Bins disposable sanitary bins

Answering the big questions.
There is a lot of confusion about the controls and regulations that apply to sanitary bins. This guide contains the answers to the questions that we get asked. Some of the information may surprise you, but this guide will provide you with in depth understanding of the regulations concerning disposal of sanitary waste. For example, most web information would like you to believe that sanitary waste is clinical waste, but this is rarely the case. This guide deals with regulations covering England. Additional guides for Wales, Scotland and Northern Ireland are being prepared, but please contact us if you would like to discuss the situation in the devolved regions. The result is pretty similar, but from different sources. If you would like further information or a no-obligation discussion about your own disposal arrangements, please do contact me.

Is it a legal requirement to provide sanitary waste bins? Sanitary Bin provision for pupils toilets at schools what is ideal? Schools what regulations cover disposal of feminine hygiene waste from schools?

Is feminine hygiene waste classed as clinical or hazardous waste? So I can put up to 7kg of sanitary waste in one collection? How easy is it for the cleaning staff to exchange the 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?

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

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 Edition 7 Feb 2013 Seiquelle Innovation Ltd 2013

Is it a legal requirement to provide sanitary waste bins?

There is no specific reference to sanitary bins, either for staff or pupils in current school premises legislation for England, but the following sections clarify requirements for toilet facilities. It is worth reading the question asked by Baroness Tonge in Parliament on 20th June 2012 about provision of sanitary bins in schools to which the reply was There is no evidence that it is necessary to regulate on this issue. Schools are expected to take a common-sense approach to such provision click here to see this in full. Schools maintained by Local Authorities The School Premises (England) Regulations 2012, which came into force on the 31st October 2012, are the first reference point. However these are extracts of relevance: ..suitable toilet and washing facilities must be provide for the sole use of pupils. Separate toilet facilities for boys and girls aged 8 years and over must be provided except where the toilet facility is provided in a room that can be secured from the inside and that is intended for use by one pupil at a time. School premises and the accommodation and facilities provided therein must be maintained to a standard such that, so far as is reasonably practicable, the health, safety and welfare of pupils is ensured. There is also a provision that if a separate facility is provided for pupils who are disabled, then this may be shared by other pupils, teachers, other school employees and visitors.

Independent Schools The Education (Independent Schools Standards) (England) (Amendment) Regulations 2012, which came into force on the 1st January 2013 amend the Education (Independent Schools Standards) (England) (Amendment) Regulations 2010(2) regulations. The requirements which affect toilet facilities are the same as those in the regulations covering maintained schools, so this is the same extract: ..suitable toilet and washing facilities must be provide for the sole use of pupils. Separate toilet facilities for boys and girls aged 8 years and over must be provided except where the toilet facility is provided in a room that can be secured from the inside and that is intended for use by one pupil at a time. School premises and the accommodation and facilities provided therein must be maintained to a standard such that, so far as is reasonably practicable, the health, safety and welfare of pupils is ensured. There is also a provision that if s separate facility is provided for pupils who are disabled, then this may be shared by other pupils, teachers, other school employees and visitors.

Boarding and Residential Schools Without going into detail, toilet and washing facilities are also covered by the National Minimum Standards for Boarding Schools, and National Minimum Standards for Residential Special Schools which came into force on 1st January 2013 and these can be found at the Department for Education Publications.
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 Edition 7 Feb 2013 Seiquelle Innovation Ltd 2013

All schools staff Therefore, for staff, but not pupils, 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. In practise this could be a covered pedal bin, although this would mean revealing the contents to users and cleaners. Our bin is aimed at providing a better option than the pedal bin, without having the costs and inconvenience of service collection contracts. Note that the Workplace regulations above apply to staff, not pupils.

Sanitary Bin provision for pupils toilets at schools: what is suitable?

For all schools, the excellent Bog Standard Organisation www.bog-standard.org has the serious purpose of promoting better toilet provision in schools. This organisation, its research, charter and aims, is widely quoted. Even the Department of Educations publication Standard specifications, layouts and dimensions: Toilets in Schools" refers to the organisations School Toilet Charter which states that sanitary disposal units should be provided in toilets for girls aged eight and over. Their campaign for better toilets for pupils was officially launched in England in 2004 and is organised by ERIC (Education and Resources for Improving Childhood Continence). It was developed in partnership with School Councils UK, the Community Practitioners and Health Visitors Association (CPHVA) and the British Toilet Association. The Welsh Government published the following excellent guide in January 2012, good reading for any school: School toilets: Good practice guidance for Schools in Wales Primary Schools specifically: It is worth reading comments on Mumsnet.com and NetMums.com from parents concerned about how their daughters will cope at primary school if there are no bins in the pupils loos. Research carried out in 2001 indicated that approximately 1 in 8 girls will start her periods whilst still at primary school. Brilliant Bins are ideal for pupils toilets as well as staff toilets. Primary schools generally have fewer pupils than secondary schools and so generally only one or two bins are required per term per cubicle.

What regulations cover disposal of feminine hygiene waste from schools?

Schools are deemed to be Municipal premises other than domestic for waste purposes, and so the disposal legislation and guidance is exactly as for business premises. See the sections below.

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 Edition 7 Feb 2013 Seiquelle Innovation Ltd 2013

Is Feminine Hygiene Waste clinical or hazardous waste?

The Environment Agencys guidance is that the vast majority of municipal hygiene waste is non-hazardous and non-clinical waste. The example provided by the Environment Agency of a case where the waste could be classified as clinical is not referring to feminine hygiene waste. Staff and pupils at school are not likely to be unwell to the degree that feminine hygiene waste is reclassified. A risk assessment is required for non-domestic premises. The detail, for all kinds of commercial municipal hygiene waste from non-healthcare sources, including feminine hygiene waste from schools: The following guidance is an extract from the Department of Health document: Safe Management of Healthcare Waste, Edition 2 updated Mar 2011, page 108 & 109. Municipal premises other than domestic: This section considers potentially offensive/hygiene waste from non-healthcare activities and premises(for example offices, shops, schools, childcare facilities, animal boarding kennels, dog faeces collection bins, body piercing facilities). These wastes can normally be assumed under this step of the assessment to present no risk of infection unless an indication to the contrary is provided by a healthcare professional. However, those who have a duty of care for such waste should undertake appropriate assessment and segregation where any risk factors indicate that an element of the waste may be infectious. Where there is a risk of infection, the waste is clinical waste and possesses the hazardous property H9: Infectious".The EWC code 20 01 99 should be assigned and the waste disposed of in orange receptacles. (Note added by us: this would only be for a situation such as an outbreak of diarrhea at a daycare nursery leading to the production of potentially infectious nappies) Waste contaminated with non-infectious bodily fluids is capable of causing offence and therefore requires appropriate packaging to alert those in the waste management chain of the contents. It is recommended that such types of waste be classified as offensive/hygiene waste. This waste should be segregated where it is generated in quantity one bag (7 kg or more) in any collection interval. Only quantities less than 7 kg may be placed in the black-bag waste stream.

So up to 7kg of sanitary waste can be included 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.

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 ready for the whole whole bin to be put into for disposal. 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 school general waste.
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 Edition 7 Feb 2013 Seiquelle Innovation Ltd 2013

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 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 also define offensive waste from non-healthcare sources as waste for which the code 20-01-99 applies. When feminine hygiene waste is a small component of general commercial waste, it does not need to be described as offensive waste, does not fall within code 20-01-99, and the whole collection is general municipal waste under code 20-03-01. Only when feminine hygiene waste is collected as a separate fraction and handled in bulk, as done by the contract service collection companies does it need to be handled as offensive waste with the waste code 20-01-99, which then has a more onerous final disposal rules.

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 http://www2.environment-agency.gov.uk/epr/search.asp

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. The Brilliant Bin is inexpensive and so affordable by every school. 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.

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 Edition 7 Feb 2013 Seiquelle Innovation Ltd 2013

Sanitary waste in the Brilliant Bin is collected along with your other commercial waste and so no additional vehicle miles are required. (General waste from Schools is commercial rather than domestic waste.) The Brilliant Bin is printed and constructed in the UK, so no shipping from the Far East is involved. FSC (Forest Stewardship Council) http://www.fsc.org/about-fsc.html certified 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 FSC logo is displayed on the back 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. The lid of our bin is secured closed with a magnetic catch. 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 printed paper bags designed for the purpose 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.
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 Edition 7 Feb 2013 Seiquelle Innovation Ltd 2013

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 carried out 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. We hope this has assisted you to understand that you are allowed to 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 BSc ARCS
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 Edition 7 Feb 2013 Seiquelle Innovation Ltd 2013