Environment Protection Act

Question 1

What is waste?

Answer 1

a material, substance or by-product eliminated or discarded as no longer useful or required after completion of a process

Question 2

What is the purpose of the Environment Protection Act? Who does it apply to?

Answer 2

purpose of the act is to regulate the management of controlled waste in order to reduce harm caused by pollution whilst also minimising harm to human health

applies to all pharmacies that handle waste and/or unwanted medicines in the course of their practice
- refers to waste generated in business setting not household waste

Question 3

Who does the ‘duty of care’ apply to?

Answer 3

anyone who does the following to controlled waste:

• imports
• produces
• carries
• stores
• treats
• disposes

Question 4

Who requires a permit when dealing with controlled waste? What are the exceptions?

Answer 4

people involved in the storage, transfer, treatment or disposal of waste are all required to have a permit

exemptions:

• do not require a permit if you are storing waste on the site where it is produced
• temporary storage is allowed at the collection point without the need for a permit

Question 5

What is the essential service in regards to unwanted medicines?

Answer 5

SOP required in all pharmacies to ensure waste is handled appropriately

pharmacies are obliged to accept back unwanted medicines from patients.
- if required by NHS England or the waste contractor, they must sort them into solids (including ampoulesand vials), liquids and aerosols

• the local NHS England team will make arrangements for a waste contractor to collect the medicines from pharmacies at regular intervals.
• additional segregation is also required under theHazardous Waste Regulations

Question 6

What are the responsibilities of the pharmacy in regards to unwanted medicines/waste?

Answer 6

the pharmacy is solely responsible for the ensuring that waste is:

1 - correctly segregated

2 - appropriately labelled

3 - packaged appropriately for transport

4 - stored securely – away from general public

5 - described accurately on accompanying documentation (e-documents)

6 - given to an authorised person to transport to an authorised waste site

Question 7

What are the different groups that pharmacy waste can be segregated into?

Answer 7

cytotoxic waste
- carcinogenic, mutagenic, toxic for reproduction
medicinally contaminated sharps
non-medicinally contaminated sharps
clinical waste 
offensive waste
- bodily fluids, secretions, excretions
domestic/trade waste
waste chemicals 
medicines 
- liquids/tablets/ampoules

Question 8

What is the T28 exemption?

Answer 8

In England and Wales, an exemption is issued by the Environment Agency and is known as the ‘T28 exemption’
- allows pharmacies to sort and dispose of CDs and to comply with the 2001 Regulations by denaturing them prior to disposal

Question 9

What are the special considerations towards sharps?

Answer 9

are not covered by Essential Service framework
- patients should be advised to contact their local council to arrange collection of sharps and replacement of sharps bins from their homes.

Question 10

What records should pharmacies keep? How long should they be retained?

Answer 10

should receive a consignment note every time waste is collected from the premises
- individual collecting the waste is responsible for providing the consignment note, on behalf of their employer

should be retained for 3 years

Question 11

What are the Non-Waste Framework Directive Exemptions (NWFD)? Who can it be applied to? Under what circumstances can it be applied?

Answer 11

exemption allows you to temporarily store waste at a collection point before recovering or disposing of the waste elsewhere.

all pharmacies are exempt so long as/do not need to apply:

• they are only temporarily storing waste (<6 months)
• the waste is stored in secure containers
• the waste will be transferred to an authorised waste disposal company
• no more than 5 cubic meters of waste is stored
• the pharmacy must not receive a payment for accepting waste

Question 12

What does health and safety at work entail?

Answer 12

must take reasonable steps to prevent accidents or harm to employees and the general public

it is a legal requirement to display HSE Health and Safety poster in a visible position within the business
- if this is not possible, employees should be provided with a leaflet about Health and Safety.

Question 13

What must the HSE Health and Safety poster include?

Answer 13

1 - brief outline of British Health and Safety Laws

2 - detail the responsibility of employer and employee

3 - provide contact information for the business Health and Safety Officer

Question 14

What are the requirements for pharmacy managers in regards the health and safety?

Answer 14

they must:

1 - conduct risk assessments

2 - ensure all staff have read SOPs

3 - provide relevant health and safety training (e.g. manual handling, fire safety)

4 - provide protective clothing and appropriate equipment so staff can carry out their duties safely

5 - provide toilets, washing facilities and drinking water

6 - provide first aid equipment and spill kits

7 - record any accidents in Accident Book and report to relevant authorities

8 - indemnity insurance

Question 15

What are the GPhC requirements for health and safety?

Answer 15

the premises must:

• be safe, clean, properly maintained and suitable for the pharmacy services provided
• protect the privacy, dignity and confidentiality of
  patients/public who receive pharmacy services
• be maintained to a level of hygiene appropriate to the pharmacy services provided
• be secure and safeguarded from unauthorised access

pharmacy services must:
- be provided in an environment which is appropriate for the provision of healthcare