Compliance and enforcement are the biggest challenges facing the medical waste/health-care risk waste industry, Stan Jewaskiewitz, past president of IWMSA, tells Chantelle Mattheus.

Fundamentally, the medical waste (health-care risk waste – HCRW) market can be split into two sectors, i.e. public (provincial hospitals, clinics, etc.) and private (private hospitals and clinics, including doctors’ surgeries, etc.). “The removal, transport and treatment including disposal of HCRW is normally carried out by private sector service providers (contractors). All HCRW in the government sector is normally removed or handled via tenders that are put out by the relevant institutions or provincial health departments. The private sector HCRW is also handled via tenders or quotes requested by the relevant institution (hospital, clinic, etc.),” explains Jewaskiewitz.

Additionally, there are a number of laws and by-laws that apply, such as the provincial legislation and regulations that govern the handling of HCRW and the industry standard – SANS 10248. The Department of Environment Affairs (DEA) has been and still is in the process of developing norms and standards in accordance with the National Environment Management: Waste Act No.59 of 2008. Draft Health Care Risk Waste Management Regulations, in terms of the Waste Act, were also gazetted by DEA in June 2012.

“It is estimated that there is about 45 000 t of HCRW generated annually in South Africa. There is a perception that there is insufficient capacity to treat the amount of HCRW produced and this results in illegal storage and dumping,” states Jewaskiewitz, adding that a number of cases of illegal dumping have been reported in the media over the last five years or so.

“There are still some major cases of illegal dumping being prosecuted by the authorities going back some four to five years. Tender irregularities and fraud are also regularly being cited as the cause for many of the problems and challenges facing the HCRW industry.”

Current challenges

According to Jewaskiewitz, there are a number of challenges facing the industry, with the biggest including training, segregation of wastes, transport, disposal and treatment and storage.

When referring to training, Jewaskiewitz indicates that this is specifically for waste generators (hospitals, clinics and doctors), transporters and disposal/treatment. “This includes training on the lack of proper procedures, compliance issues, as well as verification of qualified and experienced service providers.”

When it comes to segregation of waste, Jewaskiewitz says approximately 5 to 10% is actually hazardous or infectious – approximately 45 000 tpais generated of which only 2 500 to 4 500 tis hazardous. The separation at source of general waste and HCRW is therefore critical as the mixing of wastes in hospitals and clinics give rise to larger volumes of waste requiring treatment. “Once mixed, all the waste is treated as hazardous, including general waste.”

This has a knock-on effect when dealing with the disposal and/or treatment of HCRW. “There is still significant overloading of existing facilities due to the “mixing” of wastes,” warns Jewaskiewitz. In addition, when investigating the storage of HCRW, challenges include the use of inadequate facilities that are not compliant with current regulations. “Storage periods are also a problem, especially for small quantities and rural locations.”

The challenge with regards to transport is quite simple –appropriate, purpose-built vehicles with the necessary licences are required.

According to Jewaskiewitz, this has resulted in the industry being fuelled with speculation and allegations of impropriety relating to, among others:

• tender abuse–- “tenderpreneurs” manipulating tenders

–       tender adjudication irregularities

–       fraud and corruption

• compliance issues – license/permit conditions
• court cases – between service providers and with government departments.

Compliance takes centre stage

Jewaskiewitz says the Green Scorpions are currently dealing with many reported cases of directives/prosecutions. “There are very few reports, if any, on the outcomes of these actions. These need to be published as a deterrent to others, also to “name and shame” the transgressors,” says Jewaskiewitz.

In addition, he highlights the Welkom medical waste case that came to light towards the end of 2009, which, according to him, still appears to be in limbo. “The fact that this has not been resolved would indicate to some that the authorities are not capable of successfully prosecuting cases such as these, indicating that it is perhaps easier to hit the smaller private companies,” states Jewaskiewitz.

He believes cases such as these allow individuals to continue operating with impunity and in some cases, as directors of companies who have licences to operate waste management facilities.

Changing the face of HCRW

There is, however, much being done to combat this. Some private health-care facilities are trying to improve on their HCRW handling practices as they realise that proper management of HCRW leads to lower cost of disposal, says Jewaskiewitz, adding that they also tend to take more care in selecting suitable service providers.

Additionally, he adds that some of the service providers are endeavouring to improve the training of their staff and to implement quality management systems in order to achieve ISO accreditation (9001 or 14001). “This should stand them in good stead once the legislation and various regulations are enforced.”

This is also in light of a rapidly changing environment. “In terms of practices, there has been a significant move away from incineration to non-burn technologies for the treatment of HCRW,” continues Jewaskiewitz.

Fundamentally, HCRW can be separated into two fractions, i.e. infectious wastes (swabs, bandages, needles, etc.) and pathological wastes (limbs, placentas, etc.). Infectious wastes can be treated using non-burn technologies rendering the wastes as sterile, which can then be disposed of in a landfill. Pathological wastes are better suited to treatment by thermal means and here the technology must be capable of meeting strict emission standards.

Jewaskiewitz explains that in terms of legislation, the Waste Act and various regulations and standards have already been put in place. “However, there is still a lot of legislation evolving and it may still take some time to put it all in place.” Some of the legislation in place are:

• National Environmental Management: Waste Act No.59 of 2008
• Norms and Standards for Storage of Wastes (draft)
• Western Cape – draft regulations 2011 (Health Care Waste Management Act, 2007)
• Gauteng (GDARD) regulations
• KZN HCRW Policy
• Department of Environment Affairs (DEA) – draft regulations 1/06/2012
• SANS 10248-1: 2008 Management of HCW Ed.1
• SANS 10248-2: 2009 Management of HCW Ed.1 (rural and remote settings)

Facing forward

The changes in treatment technology, especially as regards improved emission standards, can only be beneficial to the environment, says Jewaskiewitz, adding that once legislation, regulations and standards are put in place and enforced, a level playing field will be created and much of the frustrations experienced by service providers will be eliminated. “So, one can safely assume that proper training, adequate treatment capacity and enforcement will lead to a better controlled industry and a minimised impact on the environment.”

The IWMSA is playing a pivotal role in this as it endeavours to promote the science and practice of good waste management. In order to achieve this, the IWMSA has set education and training as one of its main objectives. “In this regard, we have an ongoing development programme of developing appropriate training courses and facilitating the presentation of these courses, both non-accredited and accredited, ”says Jewaskiewitz.

In addition, the IWMSA originally set up an interest group, under its auspices, to identify the needs of the industry and to look at ways of improving standards, including having input in the development of legislation and standards.“This interest group ultimately evolved into the Health Care Waste Forum as we now know it,” concludes Jewaskiewitz.