FAQs

For Major Clinical Waste Producers

Definition

1. Is expired medicine included in the Clinical Waste Control Scheme ?

   Expired, surplus or unwanted medicine destined for disposal are chemical waste and not clinical waste. It is regulated under the Waste Disposal (Chemical Waste) (General) Regulation. If you operate a clinic, a pharmacy, a residential care home for elderlies or other trade that produces unwanted medicine, read more on chemical waste disposal website.

2. Are surplus pills and drugs classified as clinical waste?

   No. If you operate a healthcare trade and have surplus pharmaceutical products for disposal, they are classified as chemical waste and are regulated under the Waste Disposal (Chemical Waste) (General) Regulation.

3. Is expired clinical equipment clinical waste?

   It depends on the type of medical equipment and the nature of the contaminant. You should make reference to the Code of Practice regarding the definition of clinical waste or Schedule 8 of the Waste Disposal Ordinance. If you need further clarification, please contact us on 2835 1055, giving full description of the degree of contaminated equipment.

4. Are medicine bottles classified as clinical waste?

   If a medicine bottle is empty, it is municipal solid waste. If it contains significant quantities of residual pharmaceutical product, the medicine container is classified as chemical waste, then it should be handled in accordance with the Waste Disposal (Chemical Waste) (General) Regulation.

5. Are syringes used in a patient's home required to be placed in a sharps box?

   For patients doing self-injections, the used syringes is municipal waste. If a healthcare worker conducts the injection, the used syringe is his responsibility and is classified as clinical waste. It should be disposed of properly as required by section 3 of the Waste Disposal (Clinical Waste)(General) Regulation. The basic standard for a sharps container and labelling convention are described in the Code of Practice on the Management of Clinical Waste.

6. Are needles used in blood sugar monitoring classified as clinical waste?

   If you operate a healthcare practice and use lancets in blood sugar monitoring, the used lancets, whether of retractable type or otherwise, are regarded as sharps waste and belong to Group 1 clinical waste. The waste must be placed in a sharps container conforming to the BS7320:1990 standard or equivalent and safely disposed of in compliance with the Clinical Waste Regulation.

7. Is it suitable to separate the needle from the syringe and dispose of the needle to the sharps box only?

   For safety reason, it is not recommended to separate the needle from the syringe since the action is likely to cause needle-stick injury. Even if separated, both parts are classified as Group 1 clinical waste and should go into the sharps container.

8. I work in a residential care home for elderlies. We use syringes for feeding medicine or liquid food, are they still regarded as clinical waste ?

   Feeding syringe is also classified as Group 1 waste.

9. If the 'syringe' does not contain needle, am I still required to put them into sharps box?

   If it is a syringe, it is by definition regarded as Group 1 clinical waste. The Code of Practice recommends healthcare operators to put Group 1 clinical waste in sharps container.

10. Can I discharge the saline from Peritoneal Dialysis directly into the sewer even though it may contain small amount of blood?

    Yes, saline from peritoneal dialysis can be regarded as liquid effluent and discharged into the lavatory.

11. Are urine samples or faeces samples for medical analysis classified as clinical waste?

    Urine and faeces or samples of these are not regarded as Clinical Waste. They can be discharged into the lavatory.

12. Is vomitus from patients classified as clinical waste?

    They are not clinical waste and could be disposed as municipal waste. However, if it is produced by patients with those diseases such as Ebola virus disease listed under Group 4 Clinical Waste, the material contaminated by the virus and destined for disposal is regarded as Clinical Waste. For a full list of the infectious diseases under Group 4, read the Code of Practice or Schedule 8 of the Waste Disposal Ordinance.

13. Should I discard a blood bag into the clinical waste bag after use?

    Yes. It still contains free-flowing blood, it is classified as clinical waste.

14. Is blood plasma clinical waste?

    Blood plasma is a component of blood and, if to be discarded, is regarded as clinical waste.

15. Is tongue press classified as clinical waste?

    Used tongue press does not belong to any group of clinical waste.

16. Is the dressing/gauze used to cover small wounds classified as Group 5 clinical waste?

    Wound dressing with a small amount of blood would not be classified as Group 5 clinical waste. Only dressing/gauze dribbling with blood or caked with blood is clinical waste.

17. Are microscope slides with small amount of tissues classified as Group 1 or Group 3 clinical waste?

    From infection control perspective, the very thin section of tissue after preparation and staining does not warrant handling and disposal as Group 3 Clinical Waste. The glass slide, as it is, is not regarded as a sharp instrument that is used to puncture or cut into skin or tissues. Sharp waste generally includes needles, syringes, lancets, trocars, spikers and scalpel blades. Ampoules and small glass vials are also included in Group 1 Clinical Waste. Laboratory glassware that are not contaminated with groups of clinical waste, i.e. infectious culture, human or animal tissues, group 4 infectious material, free flowing blood or clotted blood should be disposed of as glass waste and packaged safety to avoid harm to waste handlers.

18. Is a small amount of body tissue or cells such as small fragment of skin classified as clinical waste?

    Small fragment of necrosed skin sloughed off from a surface wound could be discarded with the adhesive plaster as municipal waste. However if you are a healthcare professional who operates a practice that regularly removes tissues, cyst or atheroma from customers or patients, you should handle the extracted human tissues as Clinical Waste.

19. Can a patient claim back tissues or organ excised or passed out from an operation ? Is it clinical waste ?

    Excised tissues or organs from surgeries should be handled with due care as clinical waste and destined for disposal in order to safeguard public health. Due to a diversity of situations, you are welcome to write to us with detailed elaboration if you consider it otherwise.

20. Am I a healthcare professional?

    Healthcare professional includes registered dentist, registered medical practitioner, registered or enrolled nurse, registered veterinary surgeon, registered or listed Chinese medicine practitioner. You can refer to Section 6.2 of the Code Of Practice for the Management of Clinical Waste (Small Clinical Waste Producers).

21. Is maternity napkin classified as dressing in the clinical waste definition?

    No. It is sanitary waste for disposal as general refuse and not clinical waste.

22. Is soiled bed linen in hospital classified as clinical waste?

    Normally, laundry items due for cleaning is not a waste. Soiled linen, which is to be handled as laundry material, should follow the practice devised by the administrator of the institution. If the linen is to be discarded, the hospital should determine whether it is clinical waste based on the contaminant, particularly relating to the definition of Group 4 and Group 5 Clinical Waste. You may refer to the Code of Practice which serves as a technical guide.

23. Are protective gowns and surgical gloves contaminated with blood classified as clinical waste?

    Normally they are not regarded as clinical waste, unless it is contaminated by materials from patients with diseases listed in the definition of Group 4 clinical waste. Apart from this, we have no adverse comment if frontline healthcare professionals adopt a precautionary approach and discard the waste in clinical waste bags in pursuit of a stricter infection control standard.

24. Are the needles used in acupuncture treatment classified as clinical waste?

    They are sharps and hence belong to Group 1 clinical waste.

25. Are the animals which died naturally in the university laboratory classified as clinical waste?

    It depends on how animals are traced, transported or exposed to on campus and in the lab or animal breeding house. Cause of death whether natural or due to communicable agents is often not thoroughly determined. A dead animal which was bred in the research lab and, without a history of experimental manipulation may not be classified as clinical waste. But if you are uncertain about it, it is prudent to handle the animal carcass as clinical waste.

26. Are the animal carcasses produced in univeristy classified as Group 3 clinical waste?

    In the university, animal tissue or dead animals arising from experiments, tests or research are classified as Group 3 clinical waste. While it could imply animal carcasses other than from these activities can be disposed of as municipal waste, it could cause confusion or lead to oversight if the two streams are crossed over in the same lab or same building. It is therefore best to handle all dead animals as clinical waste.

27. There are some toothpicks which have been contaminated with faeces samples in the laboratory, can we treat them as clinical waste after sterilization?

    Toothpicks contaminated with faeces are not clinical waste, but we have no objections if the laboratory takes a precautionary approach and treat such items as clinical waste. As they may puncture plastic bags and cause bags to leak, they should be further packaged.

28. We have a human skull sample to dispose. Is it classified as clinical waste?

    If you are handing human remains or skeleton remains, you should confirm with FEHD for any necessary compliance with the Public Health and Municipal Service Ordinance Cap 132,and the police. Only when human body parts arising from healthcare practice and destined for disposal will they belong to Group 3 clinical waste.

29. We have some small glass vials with small amount of vaccine in it. Can we treat them as clinical waste?

    The used ampoules or small glass vials should be placed into the sharps box.

Packaging

1. Is it safe to use empty medicine bottles or other plastic bottles as a sharps container ? Am I allowed to do that ?

   In a clinic, laboratory or other clinical waste producing premises, medicine bottles, water bottles, plastic buckets, cookie boxes, other steel cannisters, glass bottles and other impovised containers are not suitable to hold sharps waste and prevent the sharps from protruding, piercing through, spilling over nor could the impovised container hold the sharps upon a drop from table top or normal handling. Accidents happen and workers, patients, students and waste handlers are vulnerable to injuries.
   Properly designed and manufactured sharps containers are commonly available and could prevent injuries and tampering. They include proper labelling, correct colour code for easy identification, a reminder of the maximum holding capacity as well as safe proprietory closure to prevent tampering after sealing. Acquiring a sharps box with a design that meets the recommendation in the Code of Practice and properly using it will serve to demonstrate that the necessary precautions in packaging sharps waste are fulfilled. Detailed specifications of sharps containers are set out in Annex B of the Code of Practice

2. Where can I buy the sharps boxes and/or clinical waste plastic bags?

   Clinical waste plastic bags and sharps boxes are often provided as part of the service by the Clinical Waste collection company although they are also available for purchase from medical goods supplier or plastic bag suppliers. Healthcare operators can search by internet or telephone directories or check with peers.

3. Does clinical waste have to be stored in red or yellow plastic bags?

   In basic terms, human and animal tissues should be packaged in yellow bags, sharps should be placed into sharps box, while other groups of clinical waste should be packaged in red bags.

4. Can you specifically point out whether the materials of the sharps box should be combustible and capable of being safely incinerated, and should not be made from polyvinylchloride (PVC)?

   Chlorine could form acid gas and favour formation of dioxin in a combustion process. For environmental protection reasons, the plastic materials that make up the sharps container should be free of PVC or other chlorinated plastics.
   Since clinical waste is bound for incineration, the sharps container should be made of combustible material to allow direct incineration of its content.

Labelling

1. Is it a requirement to stick a label on each container?

   Yes, a clear label does allow the container with clinical waste be clearly recognised and identified by all workers, other personnel or visitors, thereby exercising caution. The sharps box and clinical waste plastic bag is often pre-printed with a label. If you have a special container such as a plastic drum, you should make a label following the Code of Practice.
   Individual items going into a clinical waste plastic bag do not have to be labelled. We also recommend the package include a tag stating information of the producers such as name, address and date of seal. This serves to match with the clinical waste trip ticket that records the package of clinical waste.Since clinical waste is bound for incineration, the sharps container should be made of combustible material to allow direct incineration of its content.

2. Do we need to write down the Premises Code on the surface of the containers?

   This is not mandatory but it is a good practice to identify the source of the clinical waste by a tag with name of the waste producer or by the Premises Code.

3. What are the requirements for clinical waste labeling ?

   Please refer to the Code of Practice or our Clinical Waste Management website

Storage

1. Does my hospital have to buy 660-L transit skip for clinical waste disposal?

   The clinical waste collector will haul waste in standard 660-L skips that are designed for clinical waste transportation and waste handling in the treatment plant. They are the property of the Chemical Waste Treatment Centre and will be distributed for use in hospitals through clinical waste collectors.

2. Where can I buy the sharps boxes and/or clinical waste plastic bags?

   The sharps boxes and clinical waste collection bags can be procured from medical goods supplier. Clinical waste producers can search in their convenient way, such as internet or telephone directies for the suppliers.

3. What is the requirement on clinical waste containers?

   You can make reference to section 4.2 of the Code of Practice. It sets out the general requirements, such as specifications and colour code of the storage containers.

4. I have a batch of sharps boxes in my inventory which are printed with a different biohazard sign. Can I still use them and stick a correct biohazard sign on each?

   You can do so and use up the stock. But, in the long run, you should request the supplier to sell products that match with Hong Kong's Code of Practice.

5. Can I put small amount of contaminated dressing into the sharps box?

   We have no objections if the sharps box contains small amount of used dressing, cotton wool, used alcohol swab or packaging material. However sharps box must not include chemical waste, which should be packaged, labelled and handled separately due to their possible ignitability, vaporisation or difference in treatment and disposal method.

6. Is it a statutory requirement to store the packaged clinical waste in locked cabinet for subsequent pick-up by collector ?

   While it is not a specific statutory requirement to lock up clinical waste, it is written in the Code of Practice that it is the healthcare practitioners' duty to ensure that all precautionary measures are taken to avoid safety problems such as by preventing unauthorized personnels from accessing, tampering or handling the waste. Non compliance with Section 7 of the Waste Disposal(Clinical Waste) (General) Regulation commutes fine and imprisonment terms.

7. Are there any requirements that specify the material of the storage cabinet?

   Not specifically, although the cabinet should be easy to clean, lockable and include a conspicuous warning sign on the outside.

8. Do I need to lock the clinical waste storage cabinet?

   The cabinet for storing clinical waste should be locked and it should be properly marked to prevent unauthorized access.

9. Am I required to put the sharps box / clinical waste collection bag which is not full into storage cabinet at the end of the working day?

   This will be subject to the security and access of the workplace. We do not recommend clinical waste be left unattended and be accessible to unauthorized personnel. The consultation room or laboratory should be locked up after work.

10. Can I put the packed and sealed clinical waste bag in the corridor or the lift lobby for collector to pick up after our working hour?

    No. You must not leave your clinical waste unattended atcommon area. It could cause hazard to passers-by, children or the unsuspected. Culprits could remove it without your knowledge and create liability upon you. You should properly store and lock up your clinical waste until picked up by clinical waste collector.

11. What are the specifications of the warning sign of a storage area?

    Material: Durable, weather resistant and rigid, erected on a vertical plane of the storage facility
    Colours: Background – Yellow, Characters and letters – Black
    Size: Characters and letters - Min. height = 40 mm, Plate - Not less than 500 mm (H) x 600 mm (L)
    Biohazard sign - Min. height = 150 mm

12. Is there any regulation from EPD that requires sharps to be stored in yellow sharps boxes?

    The Code of Practice promulgates the healthcare industry, laboratory practitioners and other clinical waste producers to use designated sharp boxes that meets BS7320 or equivalent standard and complete with other features to package sharp waste. This represents the best endeavour to prevent injuries and protect public health. Section 7 of Waste Disposal (Clinical Waste) (General) Regulation imposes a duty of care on the person who handles clinical waste. An offence can commute to a fine and imprisonment.

Collection

1. I want to set up a clinical waste collection point. What should I do?

   A producer of clinical waste may prepare a plan and seek EPD's authorization to set up an on-site collection point to receive clinical waste generated by other waste prodcuers. Due to public health and safety concerns, the pre-requisites and operational level will be demanding. You can call our Clinical Waste Hotline at 28351055 to learn about the details and the requirements. For application procedures, you will need to fill an application form. Upon receiving it, we will arrange a meeting with you to discuss the criteria and how to meet the requirements.

2. How can I know whether the clinical waste collector is licensed or not?

   Please refer to EPD's website with the most updated list of licensed clinical waste collectors. You may also require the waste collection company to present a copy of the licence document for your sight. The licence is issued by EPD and has a validity period.

3. Do I need to hire a licensed clinical waste collector to collect my clinical waste?

   Clinical waste producers must engage a licensed clinical waste collector to collect their clinical waste.

4. Can I deliver the clinical waste by myself?

   Waste producers who are healthcare professionals# may deliver their clinical waste to a collection point or licensed disposal facility. Alternatively, they may ask their employee who is healthcare professional to deliver the waste on their behalf. Under this circumstance, you must obtain the Premises Code and complete the Trip Ticket before the waste delivery. Such waste delivery is subject to fulfilling the following requirements specified in the Regulation :
   • The healthcare professional must not carry more than 5 kg of clinical waste at any one time;
   • No Group 4 waste may be delivered in this manner;
   • Group 1 waste must be packaged in containers that are puncture- resistant, shatter-proof and leak-proof (e.g. sharps boxes);
   • Other groups of clinical waste must be packaged in secondary containers that are made of rigid material, impervious to moisture and leak-proof, and that will not rip, tear or burst under normal conditions of handling in accordance with the specifications set out in Code of Practice;
   • The clinical waste must be properly packaged to prevent spillage, and the secondary containers must be labelled;
   • Only private car## within the meaning of the Road Traffic Ordinance (Cap. 374) must be used as a means of transport in delivering the clinical waste;
   • The clinical waste must be delivered directly to a collection point or licensed disposal facility within 24 hours and must not be left unattended during the delivery;
   • Adequate and appropriate first-aid equipment and cleaning equipment (e.g. spare red bags and sharps boxes) for use in case of injury to any person and spillage of clinical waste. Refer to the Annex D of Code of Practice.
   • if any clinical waste is spilled while it is being delivered, the healthcare professional must remove the spilled clinical waste and clean the area of the spillage.
   # Note: A healthcare professional is a :
   • registered dentist
   • registered medical practitioner
   • registered or enrolled nurse
   • registered veterinary surgeon
   • registered or listed Chinese medicine practitioner
   as defined in the various ordinances detailed in the Waste Disposal (Clinical Waste) (General) Regulation.
   ## Private car means a motor vehicle constructed or adapted for use solely for the carriage of a driver and not more than 7 passengers and their personal effects but does not include an invalid carriage, motor cycle, motor tricycle or taxi.
   

5. What is the definition of private car for self-delivery of clinical waste by healthcare professionals?

   In the context of self-delivery of clinical waste by healthcare professionals, the meaning of private car would be as defined in the Road Traffic Ordinance (Cap. 374). It means a motor vehicle constructed or adapted for use solely for the carriage of a driver and not more than 7 passengers and their personal effects but does not include an invalid carriage, motor cycle, motor tricycle or taxi.

6. What is the cost for disposing clinical waste under the Clinical Waste Control Scheme? Who will be charged?

   Under the Scheme, EPD will charge HK$2.7 per kg of clinical waste (less than 1 kg will be counted as 1 kg) for the disposal of clinical waste. This fee will be paid by the person using the disposal site i.e. licensed waste collectors who deliver the waste to the site.

7. Is there any regulation governing the handling fee charged by the clinical waste collectors?

   The cost of waste collection is subject to the location, the haulage distance, the amount of waste and the dispersion of other healthcare operators nearby. There may not be one fixed rate that fits all situations. We believe the presence of 7 licensed clinical waste collectors in this service sector does provide healthy competition to keep the price reasonable.

8. Does the government provide clinical waste collection service?

   Currently there is no government-operated clinical waste collection service. Producers of clinical waste should engage the service of clinical waste collection companies.

9. Where can I obtain the list of licensed clinical waste collectors?

   A list of most updated licensed clinical waste collectors can be found from the EPD's website. However this list is for reference only and waste producers are free to choose any collector's service.

Disposal

1. How should I handle the needles used in outreach programs?

   Used or contaminated needles generated during outreach healthcare work are clinical wastes. This means their handling, collection, transportation and disposal are subject to legal control. You should safely package the clinical wastes as soon as they are produced and engage the service of licensed clinical waste collector to remove the wastes. Since there is a whole range of outreach healthcare work, you are welcome to write to us with substantive description of your work. We could then provide more comments.

2. Should I put the used sharps box into red clinical waste collection bag before disposal?

   There is not a requirement under normal circumstances. However you may exercise your professional judgement, and based on infection control or public health considerations, to put the sharps box into the bag if the exterior of the sharps box is contaminated.

3. Is there any guideline from EPD regarding the collection/disposal frequency of clinical waste?

   The frequency of clinical waste collection should be agreed between waste producer and licensed collector taking into account the nature and quantity of clinical waste generated. The "Code of Practice for the Management of Clinical Waste - Major Clinical Waste Producers and Waste Collectors" gives an indication on the collection frequency for hospitals, government clinics and government laboratories (section 6.2).
   For small clinical waste producers, the Code of Practice has not specified a collection frequency. However based on hygiene and OSH risk considerations, our general advice is to remove clinical waste from your venue as soon as possible and in any case do not store more than 6 months.

4. Is there any charge for the disposal of clinical waste?

   The government imposes a charge for the use of the clinical waste disposal facility. The rate will be $2.7 per kg of clinical waste. You can refer to the Waste Disposal (Charge for Disposal of Clinical Waste) Regulation (Chapters 354P). However, your clinical waste collector will charge a fee different from the above to cover collection, transportation and other overheads.

Regulations

1. Will inspectors come to check my company frequently?

   Officers from EPD may visit healthcare premises, nursing homes, veterinary clinics, laboratories and research institutions with or without prior notice in order to regularly check for due compliance with the Clinical Waste Regulation or to investigate complaints.
   We will only do so when necessary and will endeavour to complete the checks or the investigation as quickly as possible. Your full cooperation will be greatly appreciated.
   EPD inspectors will also monitor compliance of clinical waste collectors on safe operation.

2. Do you charge for the disposal of clinical waste? By how much ?

   The government imposes a charge for the use of the Chemical Waste Treatment Centre which receives the clinical waste for incineration. The rate will be $2.70 per kg of clinical waste. You can refer to the Waste Disposal (Charge for Disposal of Clinical Waste) Regulation (Chapter 354P).　However, it is understood that clinical waste collectors seek a service charge different to this rate to cover manual collection, transportation, administration and other overheads.

3. What is the Clinical Waste Control Scheme ?

   The Clinical Waste Control Scheme aims to promote a high standard of public health in Hong Kong through better management of Clinical Waste from the source of its production to the site of its final disposal. The scheme comprises 5 key elements : 1. Establishing a licensing framework for all clinical waste collectors and disposal facility operators; 2. Requiring waste producers to properly manage their clinical waste by consigning the clinical waste to licensed clinical waste collectors for delivery to a licensed disposal facility for disposal; 3. Promulgating Codes of Practice to provide guidance for clinical waste producers and waste collectors; 4. Setting up a trip ticket system to track the movement of clinical waste from source to disposal facility; 5. Designating the Chemical Waste Treatment Centre (CWTC) as the facility to treat clinical waste and levying a disposal charge for use of the facility.

4. When did the Clinical Waste Control Scheme begin ? Is it going to continue for some time ?

   The Clinical Waste Control Scheme became effective as from 1st August 2011. The framework of management of the waste is written into law, namely the Waste Disposal Ordinance and its subsidiary legislations. There is not an end date. Healthcare and veterinary practices, lab practices and research establishments should identify whether they produce clinical waste and incorporate waste segregation, packaging, labelling, storage and safe disposal of clinical waste into their operation. Cleaning companies must obtain a licence from EPD before they can provide clinical waste collection service.

5. What is the maximum penalty of clinical waste offences ?

   Offence provisions are contained in the Waste Disposal Ordinance (Cap 354) and Waste Disposal(Clinical Waste)(General)Regulation (Cap 354 O). You can browse the law at the Bilingual Law Information System website maintained by the Department of Justice http://www.legislation.gov.hk/eng/home.htm. Clauses vary in penalty limit. The maximum penalty for the offence in causing danger to public health or safety, pollution to the environment or nuisance to the neighbouring area due to improper handling, storage, transportation or disposal of clinical waste is a fine of $200,000 and 6 months imprisonment.

6. How did the content of the control scheme developed into its present form ?

   The clinical waste control scheme is the result of studies and elaborate discussion among the government, the healthcare associations and a wide range of stakeholders. Legislative provisions were well debated and then passed into law in LegCo. It fulfills the need for a robust and excellent public health standard in Hong Kong through sensible management of clinical waste among healthcare professionals, lab analysts and research scientists.

Producers

1. What are the responsibilities of clinical waste producers under the Clinical Waste Control Scheme? Is it an offence if the condition of my storage area does not match up with the Code of Practice ?

   Producers of clinical waste have a duty of care to ensure that their waste are handled, stored and disposed of in a safe and proper manner. As a minimum, they should take all necessary precautions in handling and storage of the clinical waste, ensure its safe disposal and keep record of each disposal. You can refer to Section 3, 7 and 12 of the Waste Disposal (Clinical Waste)(General)Regulation for reference. Healthcare operators should:
   1. Provide adequate and proper containers, storage area, staff guidance and safety instructions within your premises to handle clinical waste. Monitor and enforce the system.
   2. Carefully select and engage the service of a licensed collector who can provide quality clinical waste collection service;
   3. Monitor the collector's service and promptly investigate problems and take remedial actions on mis-handling of clinical waste;
   4. Keep records of the clinical waste consigned to licensed collectors. Promptly produce such records for inspection upon request by EPD.
   In the event of an investigation into an alleged offence, waste producers who cannot provide evidence in support of their attempt to apply the Code of Practice will not have a reasonable defence if being prosecuted.

2. Where can I get the Code of Practice?

   The Resources section of our Clinical Waste Management website allows browsing and downloads. http://www.epd.gov.hk/epd/clinicalwaste/nonflash/tc_chi/downloads/document.html

3. How are major and small clinical waste producers distinguished?

   This is set out in Annex A of the Code of Practice. Examples of major producers are: Hospitals, Government clinics, dental hospital, registered nursing homes and maternity homes. Examples of Small Clinical Waste Producers are: private medical clinics, dental clinics, medical laboratories, Chinese medicine practitioners, residential care homes for the elderly, labs conducting medical or pharmaceutical research, vet clinics, and other locations with medical practice.

4. I have already commenced business at my new location and we are already producing clinical waste. How could I obtain a premises code ?

   You can download and fill the form Premises Code Request Form (New Application)”from the Clinical Waste Management website for applying Premises Code. (Website: http://www.epd.gov.hk/epd/clinicalwaste/nonflash/tc_chi/downloads/document.html) Please fill in the form and attach a copy of the BRC (if applicable) and fax it to the relevant EPD regional office of your area.

5. In case I need to change some particular information in my Premises Code, what shall I do?

   You can download and fill in the form : “Premises Code Request Form (Change in Particulars)”from the Clinical Waste Management website for amending information connected with your Premises Code. (Website: http://www.epd.gov.hk/epd/clinicalwaste/nonflash/tc_chi/downloads/document.html) Please tick the right box and fax the completed form to the EPD regional office of your area.

6. I have been assigned a premises code but I do not produce clinical waste any more. Can I cancel it?

   You are welcome to cancel the premises code if you do not produce clinical waste at that venue any more. You can download and fill in the form : “Cancellation of Premises Code” from the Clinical Waste Management website. Please fax the completed form to EPD regional office to cancel your Premises Code.

7. My clinic will begin operation in the next few days. Do I need a blank trip ticket to fill in and how can I get one ?

   Usually the licensed clinical waste collector will begin his collection round with a trip ticket with his details printed before leaving office. As you handover the waste to him, you should confirm information on the clinical waste trip ticket before the sign and stamp the company chop on it. If you want to begin a self-delivery of clinical waste by private car to the Chemical Waste Treatment Centre, you can obtain blank trip ticket from our Regional Office. For details, please browse our website.

8. Why is there a barcode on the trip ticket?

   The barcode provides machine-reading opportunity for data automation purposes. Producers of Clinical Waste should still properly enter complete information and sign on the trip ticket.

9. Am I required to fill in the trip ticket every time when i consign my waste to a waste collector ?

   Yes, it is a statutory requirement to retain the trip ticket upon consigning the waste. By law, you should also keep such records for not less than 12 months.

10. How long should I keep the records of waste consignment or delivery?

    Such records may include copy of trip ticket or receipt of waste consignment issued by the clinical waste collector or licensed disposal facility i.e. the Chemical Waste Treatment Centre at Tsing Yi. Waste producers must keep such records on their premises for at least 12 months from the date of collection, and produce the record to EPD for inspection when so required.

11. Can practitioners from the same company/organization/establishment, but not in the same premises, gather all the waste at one point to store before collection?

    If the building is wholly occupied by the organization, the practitioners from the same organization in the same building can use one Premises Code. They can centralize their clinical waste at one location within the same complex/building before collection. However, where the operations are split apart in different premises and the building is occupied by multiple users of different companies or institutions, discrete premises should obtain their individual premises code. The clinical waste collector should do door-to-door collection of clinical waste. We impose strict operational safety standard upon licensed clinical waste collectors to avoid hazard in conveying waste in communal areas and public place. Healthcare operators should be mindful of their liability.

12. Can practitioners sharing the same premises use one Premises Code? Who will be responsible for any non-compliance issues in this situation?

    Practitioners sharing the use of the same premises can use one Premises Code when consigning the clinical waste to a licensed collector. They can agree among themselves the representation or responsibility that the premises code corresponds to. All practitioners sharing the same Premises Code could be liable in a prosecution case. Responsibility could be more clearly defined if each practitioner obtains and uses his/her own Premises Code to dispose of clinical waste and keep records accordingly. Producers in different premises, or a company with many premises should all acquire separate Premises Codes, i.e. one location one code.

13. If my rehabilitation centre span a few continuous floors and all the facilities are solely owned by my organization, can I use one permises code and centralize all the clinical waste in one refuse room?

    We have no objection to one premises code representing all continuous floors which your organisation solely occupies. If you prefer, you may obtain different premises codes to suit different offices in the same organisation, e.g. differentiating residential care homes from outreach home care services. However we do not recommend that you move clinical waste from floor to floor, since this involves communal elevator and stairways. Clinical Waste collector should collect directly from each floor.

14. Can my property management company collect the clinical waste for me?

    For safety reasons, we only issue clinical waste collection licence to competent operators to remove clinical waste from producers of clinical waste. Any company can apply. This is a feature of the Clinical Waste Control Scheme that aims to prevent incidents caused by clinical waste in public areas. Without such licence, a property management company should not arrange cleansing staff to remove clinical waste from clinics, labs, medical beauty establishments or residential care homes because that will constitute an offence under the Waste Disposal Ordinance. Further, the producer of waste will also be liable to offence under Section 3 of the Clinical Waste Regulation. Clinical waste collection should only be carried out by licensed clinical waste collectors who operate with competent staff and a range of safeguards.

15. Am I required to contact EPD if my clinics moves to a new location ?

    Yes, you should change your premises code for disposal of clinical waste. It is a unique number for each location. If you relocate your clinic, you should cancel the old premises code and obtain a new one. Simply fill in a form and fax it to our Regional Office and we will generate a new Premises Code for your new site and cancel the old one.

16. Are all medical doctors regarded as Clinical Waste Producers ?

    It depends on the practice. The organisation that causes to produce clinical waste is the producer. For example, a hospital will be responsible for proper disposal of clinical waste generated on site or in outreach healthcare services. Some practices that do not conduct injections, other invasive procedures, wound care or others may not generate any group of clinical waste such as sharps, lab culture, human or animal tissues, infectious material, dressing or blood at all. The healthcare organisation should determine that. To know more, browse our Resources Section and read the Code of Practice.

For Small Clinical Waste Producers

Definition/Classification

1. Is expired medicine included in the Clinical Waste Control Scheme ?

   Expired, surplus or unwanted medicine destined for disposal are chemical waste and not clinical waste. It is regulated under the Waste Disposal (Chemical Waste) (General) Regulation. If you operate a clinic, a pharmacy, a residential care home for elderlies or other trade that produces unwanted medicine, read more on chemical waste disposal website.

2. Are surplus pills and drugs classified as clinical waste?

   No. If you operate a healthcare trade and have surplus pharmaceutical products for disposal, they are classified as chemical waste and are regulated under the Waste Disposal (Chemical Waste) (General) Regulation.

3. Is expired clinical equipment clinical waste?

   It depends on the type of medical equipment and the nature of the contaminant. You should make reference to the Code of Practice regarding the definition of clinical waste or Schedule 8 of the Waste Disposal Ordinance. If you need further clarification, please contact us on 2835 1055, giving full description of the degree of contaminated equipment.

4. Are medicine bottles classified as clinical waste?

   If a medicine bottle is empty, it is municipal solid waste. If it contains significant quantities of residual pharmaceutical product, the medicine container is classified as chemical waste, then it should be handled in accordance with the Waste Disposal (Chemical Waste) (General) Regulation.

5. Are syringes used in a patient's home required to be placed in a sharps box?

   For patients doing self-injections, the used syringes is municipal waste. If a healthcare worker conducts the injection, the used syringe is his responsibility and is classified as clinical waste. It should be disposed of properly as required by section 3 of the Waste Disposal (Clinical Waste)(General) Regulation. The basic standard for a sharps container and labelling convention are described in the Code of Practice on the Management of Clinical Waste.

6. Are needles used in blood sugar monitoring classified as clinical waste?

   If you operate a healthcare practice and use lancets in blood sugar monitoring, the used lancets, whether of retractable type or otherwise, are regarded as sharps waste and belong to Group 1 clinical waste. The waste must be placed in a sharps container conforming to the BS7320:1990 standard or equivalent and safely disposed of in compliance with the Clinical Waste Regulation.

7. Is it suitable to separate the needle from the syringe and dispose of the needle to the sharps box only?

   For safety reason, it is not recommended to separate the needle from the syringe since the action is likely to cause needle-stick injury. Even if separated, both parts are classified as Group 1 clinical waste and should go into the sharps container.

8. I work in a residential care home for elderlies. We use syringes for feeding medicine or liquid food, are they still regarded as clinical waste ?

   Feeding syringe is also classified as Group 1 waste.

9. If the 'syringe' does not contain needle, am I still required to put them into sharps box?

   If it is a syringe, it is by definition regarded as Group 1 clinical waste. The Code of Practice recommends healthcare operators to put Group 1 clinical waste in sharps container.

10. Can I discharge the saline from Peritoneal Dialysis directly into the sewer even though it may contain small amount of blood?

    Yes, saline from peritoneal dialysis can be regarded as liquid effluent and discharged into the lavatory.

11. Are urine samples or faeces samples for medical analysis classified as clinical waste?

    Urine and faeces or samples of these are not regarded as Clinical Waste. They can be discharged into the lavatory.

12. Is vomitus from patients classified as clinical waste?

    They are not clinical waste and could be disposed as municipal waste. However, if it is produced by patients with those diseases such as Ebola virus disease listed under Group 4 Clinical Waste, the material contaminated by the virus and destined for disposal is regarded as Clinical Waste. For a full list of the infectious diseases under Group 4, read the Code of Practice or Schedule 8 of the Waste Disposal Ordinance.

13. Should I discard a blood bag into the clinical waste bag after use?

    Yes. It still contains free-flowing blood, it is classified as clinical waste.

14. Is blood plasma clinical waste?

    Blood plasma is a component of blood and, if to be discarded, is regarded as clinical waste.

15. Is tongue press classified as clinical waste?

    Used tongue press does not belong to any group of clinical waste.

16. Is the dressing/gauze used to cover small wounds classified as Group 5 clinical waste?

    Wound dressing with a small amount of blood would not be classified as Group 5 clinical waste. Only dressing/gauze dribbling with blood or caked with blood is clinical waste.

17. Are microscope slides with small amount of tissues classified as Group 1 or Group 3 clinical waste?

    From infection control perspective, the very thin section of tissue after preparation and staining does not warrant handling and disposal as Group 3 Clinical Waste. The glass slide, as it is, is not regarded as a sharp instrument that is used to puncture or cut into skin or tissues. Sharp waste generally includes needles, syringes, lancets, trocars, spikers and scalpel blades. Ampoules and small glass vials are also included in Group 1 Clinical Waste. Laboratory glassware that are not contaminated with groups of clinical waste, i.e. infectious culture, human or animal tissues, group 4 infectious material, free flowing blood or clotted blood should be disposed of as glass waste and packaged safety to avoid harm to waste handlers.

18. Is a small amount of body tissue or cells such as small fragment of skin classified as clinical waste?

    Small fragment of necrosed skin sloughed off from a surface wound could be discarded with the adhesive plaster as municipal waste. However if you are a healthcare professional who operates a practice that regularly removes tissues, cyst or atheroma from customers or patients, you should handle the extracted human tissues as Clinical Waste.

19. Can a patient claim back tissues or organ excised or passed out from an operation ? Is it clinical waste ?

    Excised tissues or organs from surgeries should be handled with due care as clinical waste and destined for disposal in order to safeguard public health. Due to a diversity of situations, you are welcome to write to us with detailed elaboration if you consider it otherwise.

20. Am I a healthcare professional?

    Healthcare professional includes registered dentist, registered medical practitioner, registered or enrolled nurse, registered veterinary surgeon, registered or listed Chinese medicine practitioner. You can refer to Section 6.2 of the Code Of Practice for the Management of Clinical Waste (Small Clinical Waste Producers).

21. Is maternity napkin classified as dressing in the clinical waste definition?

    No. It is sanitary waste for disposal as general refuse and not clinical waste.

22. Is soiled bed linen in hospital classified as clinical waste?

    Normally, laundry items due for cleaning is not a waste. Soiled linen, which is to be handled as laundry material, should follow the practice devised by the administrator of the institution. If the linen is to be discarded, the hospital should determine whether it is clinical waste based on the contaminant, particularly relating to the definition of Group 4 and Group 5 Clinical Waste. You may refer to the Code of Practice which serves as a technical guide.

23. Are protective gowns and surgical gloves contaminated with blood classified as clinical waste?

    Normally they are not regarded as clinical waste, unless it is contaminated by materials from patients with diseases listed in the definition of Group 4 clinical waste. Apart from this, we have no adverse comment if frontline healthcare professionals adopt a precautionary approach and discard the waste in clinical waste bags in pursuit of a stricter infection control standard.

24. Are the needles used in acupuncture treatment classified as clinical waste?

    They are sharps and hence belong to Group 1 clinical waste.

25. There are some toothpicks which have been contaminated with faeces samples in the laboratory, can we treat them as clinical waste after sterilization?

    Toothpicks contaminated with faeces are not clinical waste, but we have no objections if the laboratory takes a precautionary approach and treat such items as clinical waste. As they may puncture plastic bags and cause bags to leak, they should be further packaged.

26. We have a human skull sample to dispose. Is it classified as clinical waste?

    If you are handing human remains or skeleton remains, you should confirm with FEHD for any necessary compliance with the Public Health and Municipal Service Ordinance Cap 132,and the police. Only when human body parts arising from healthcare practice and destined for disposal will they belong to Group 3 clinical waste.

27. We have some small glass vials with small amount of vaccine in it. Can we treat them as clinical waste?

    The used ampoules or small glass vials should be placed into the sharps box.

Packaging

1. When I issue medications to patients, can I provide them with a plastic bag to hold the pills without charging them for the bag ?

   Where there are no retail sales of goods, plastic bags given out will not be subject to the plastic shopping bag charge under the Product Eco-responsibility Ordinance (Chapter 603). Medical consultation is not regarded as a retail activity and plastic bags provided in relation to medical consultation are exempted from the charge. For further information on the Full Implementation of the Plastic Shopping Bag Charging, please visit our dedicated website. Alternatively you can reach our hotline at 3152 2299 , our service agent will endeavour to answer your enquiry

2. Does clinical waste have to be stored in red or yellow plastic bags?

   In basic terms, human and animal tissues should be packaged in yellow bags, sharps should be placed into sharps box, while other groups of clinical waste should be packaged in red bags.

3. Is it safe to use empty medicine bottles or other plastic bottles as a sharps container ? Am I allowed to do that ?

   In a clinic, laboratory or other clinical waste producing premises, medicine bottles, water bottles, plastic buckets, cookie boxes, other steel cannisters, glass bottles and other impovised containers are not suitable to hold sharps waste and prevent the sharps from protruding, piercing through, spilling over nor could the impovised container hold the sharps upon a drop from table top or normal handling. Accidents happen and workers, patients, students and waste handlers are vulnerable to injuries. Properly designed and manufactured sharps containers are commonly available and could prevent injuries and tampering. They include proper labelling, correct colour code for easy identification, a reminder of the maximum holding capacity as well as safe proprietory closure to prevent tampering after sealing. Acquiring a sharps box with a design that meets the recommendation in the Code of Practice and properly using it will serve to demonstrate that the necessary precautions in packaging sharps waste are fulfilled. Detailed specifications of sharps containers are set out in Annex B of the Code of Practice

4. I am a small producer of clinical waste. Can I simply use any container that is rigid, non-fragile, puncture-resistant, shatter-proof and leak-proof to hold sharps. It seems the Code of Practice does not restrict that.

   The Code of Practice serves as a guidance to waste producers for safe handling and management of clinical waste so as to minimize the potential danger to waste handlers and the general public. Ultimately though, it is the waste producer who has the obligation to ensure the sharps container used is up to a standard and performing its function, for being rigid in construction and is not fragile, puncture-resistant, shatter-proof and leak-proof such that it renders the sharps safe from causing harm once deposited into the container. Section 7 of the Waste Disposal (Clinical Waste)(General) Regulation is relevant. To this end, we strongly recommend the waste producer uses the best available containers which are dedicatedly designed, manufactured, labelled and easily recognised to take sharps waste and conform with the standard as stated in the CoP. Models that are built to other well recognised international standards (e.g AS4031-1992) are also suitable. The use of untested alternatives or products that are non-compliant with recognised standard will open the waste producer to liabilities in causing danger to public health or safety.

5. Licensed waste collectors often supply and charge waste producers for the waste containers that they provide. They tend not to accept the so-called 'other containers' from waste producers. In such a case, can and should waste producers obtain formal and prior approval from EPD for their selected kind of 'other container' ?

   That could be due to occupational safety risk or sub-standard design that could cause spillage which is contrary to the Code of Practice or Section 7 of the Clinical Waste Regulation. You could check the quality of the container (plastic bags or sharp boxes) that you use against the Code of Practice e.g. whether the sharps box indicates it is manufactured to BS7320 or equivalent standard. If you or your waste collector has any doubt in the meaning or the use of "other containers", he can call our Clinical Waste Hotline 2835 1055 for details.

6. Can you specifically point out whether the materials of the sharps box should be combustible and capable of being safely incinerated, and should not be made from polyvinylchloride (PVC)?

   On the type of material making up the sharps container, it is the intention to protect our environment to avoid acid gas and dioxin formation upon combustioin that the material (of the sharps container) should be PVC-free and safe for incineration.
   Since clinical waste is bound for incineration, the sharps container should be made of combustible material to allow direct incineration of its content.

7. Where can I buy the sharps boxes and/or clinical waste plastic bags?

   The sharps boxes and clinical waste collection bags can be procured from medical goods supplier. Clinical waste producers can search in their convenient way, such as internet or yellow pages for the suppliers.

8. I operate a clinical waste collection company and regularly distribute clinical waste plastic bags to clinics to hold waste. Starting from 1.4.2015, must I collect 50 cents for each bag from the clinic as the plastic shopping bag charge?

   Where the service provider, namely the clinical waste collection company, distributes the plastic bag to the client to enable the waste be packaged for subsequent collection, it is not regarded as retail sale of goods and therefore a plastic shopping bag charge as prescribed in Product Eco-responsibility Ordinance (Chapter 603) is not applicable.

   If the bags are sold to the client as a product, each pre-packaged pack of 10 or more bags should be sold at a price not less than 50 cents. However, at least 50 cents should be charged for each bag should the pre-packaged pack has 9 or fewer bags.

   For further information on the Full Implementation of the Plastic Shopping Bag Charging, please visit our dedicated website. Alternatively you can reach our hotline at 3152 2299, our service agent will endeavour to answer your enquiry.

Labelling

1. Is it a requirement to stick a label on each container?

   Yes, a clear label does allow the container with clinical waste be clearly recognised and identified by all workers, other personnel or visitors, thereby exercising caution. The sharps box and clinical waste plastic bag is often pre-printed with a label. If you have a special container such as a plastic drum, you should make a label following the Code of Practice.
   Individual items going into a clinical waste plastic bag do not have to be labelled. We also recommend the package include a tag stating information of the producers such as name, address and date of seal. This serves to match with the clinical waste trip ticket that records the package of clinical waste.Since clinical waste is bound for incineration, the sharps container should be made of combustible material to allow direct incineration of its content.Since clinical waste is bound for incineration, the sharps container should be made of combustible material to allow direct incineration of its content.

2. Do we need to write down the Premises Code on the surface of the containers?

   This is not mandatory but it is a good practice to identify the source of the clinical waste by a tag with name of the waste producer or by the Premises Code.

3. What are the requirements for clinical waste labeling ?

   Please refer to the Code of Practice or our Clinical Waste Management website

Storage

1. Where can I buy the sharps boxes and/or clinical waste plastic bags?

   The sharps boxes and clinical waste collection bags can be procured from medical goods supplier. Clinical waste producers can search in their convenient way, such as internet or telephone directies for the suppliers.

2. What is the requirement on clinical waste containers?

   You can make reference to section 4.2 of the Code of Practice. It sets out the general requirements, such as specifications and colour code of the storage containers.

3. I have a batch of sharps boxes in my inventory which are printed with a different biohazard sign. Can I still use them and stick a correct biohazard sign on each?

   You can do so and use up the stock. But, in the long run, you should request the supplier to sell products that match with Hong Kong's Code of Practice.

4. Can I put small amount of contaminated dressing into the sharps box?

   We have no objections if the sharps box contains small amount of used dressing, cotton wool, used alcohol swab or packaging material. However sharps box must not include chemical waste, which should be packaged, labelled and handled separately due to their possible ignitability, vaporisation or difference in treatment and disposal method.

5. Is it a statutory requirement to store the packaged clinical waste in locked cabinet for subsequent pick-up by collector ?

   While it is not a specific statutory requirement to lock up clinical waste, it is written in the Code of Practice that it is the healthcare practitioners' duty to ensure that all precautionary measures are taken to avoid safety problems such as by preventing unauthorized personnels from accessing, tampering or handling the waste. Non compliance with Section 7 of the Waste Disposal(Clinical Waste) (General) Regulation commutes fine and imprisonment terms.

6. Are there any requirements that specify the material of the storage cabinet?

   Not specifically, although the cabinet should be easy to clean, lockable and include a conspicuous warning sign on the outside.

7. Do I need to lock the clinical waste storage cabinet?

   The cabinet for storing clinical waste should be locked and it should be properly marked to prevent unauthorized access.

8. Am I required to put the sharps box / clinical waste collection bag which is not full into storage cabinet at the end of the working day?

   This will be subject to the security and access of the workplace. We do not recommend clinical waste be left unattended and be accessible to unauthorized personnel. The consultation room or laboratory should be locked up after work.

9. Can I put the packed and sealed clinical waste bag in the corridor or the lift lobby for collector to pick up after our working hour?

   No. You must not leave your clinical waste unattended atcommon area. It could cause hazard to passers-by, children or the unsuspected. Culprits could remove it without your knowledge and create liability upon you. You should properly store and lock up your clinical waste until picked up by clinical waste collector.

10. What are the specifications of the warning sign of a storage area?

    Material: Durable, weather resistant and rigid, erected on a vertical plane of the storage facility
    Colours: Background – Yellow, Characters and letters – Black
    Size: Characters and letters - Min. height = 40 mm, Plate - Not less than 500 mm (H) x 600 mm (L)
    Biohazard sign - Min. height = 150 mm

11. Is there any regulation from EPD that requires sharps to be stored in yellow sharps boxes?

    The Code of Practice promulgates the healthcare industry, laboratory practitioners and other clinical waste producers to use designated sharp boxes that meets BS7320 or equivalent standard and complete with other features to package sharp waste. This represents the best endeavour to prevent injuries and protect public health. Section 7 of Waste Disposal (Clinical Waste) (General) Regulation imposes a duty of care on the person who handles clinical waste. An offence can commute to a fine and imprisonment.

12. Based on the Code of Practice for small clinical waste producers, am I required to use a clinical waste storage cabinet ?

    Yes, clinical waste produced in your premises should be safely and securely locked away to prevent tampering and improper handling to await for collection by licensed clinical waste collectors. They should be separated stored from other materials. The Code of Practice provides a guide to the healthcare industry to help them operate safely and in compliance with the Waste Disposal Ordinance (Cap 354) and Waste Disposal (Clinical Waste)(General) Regulation.

13. We only produce small amount of clinical waste, do we still need to set aside a specific storage area?

    Yes, you should. The healthcare practice should determine the size of the storage area according to the turnover. For hygiene and safety reasons, avoid stockpiling clinical waste and call for waste collection service frequently and as soon as practicable.

14. Can I put the clinical waste into the refuse room and ask the waste collector to collect from there?

    No. To maintain responsibility, every clinic should separately keep and lock up their own clinical waste. In that manner, you can account for every package of your clinical waste. The clinical waste collector should come to your premises to collect the waste, which you can confirm by checking the correctness on the record of consignment (the Clinical Waste Trip Ticket) before signature.

Collection

1. How can I know whether the clinical waste collector is licensed or not?

   Please refer to EPD's website with the most updated list of licensed clinical waste collectors. You may also require the waste collection company to present a copy of the licence document for your sight. The licence is issued by EPD and has a validity period.

2. Do I need to hire a licensed clinical waste collector to collect my clinical waste?

   Clinical waste producers must engage a licensed clinical waste collector to collect their clinical waste.

3. Can I deliver the clinical waste by myself?

   Waste producers who are healthcare professionals# may deliver their clinical waste to a collection point or licensed disposal facility. Alternatively, they may ask their employee who is healthcare professional to deliver the waste on their behalf. Under this circumstance, you must obtain the Premises Code and complete the Trip Ticket before the waste delivery. Such waste delivery is subject to fulfilling the following requirements specified in the Regulation :
   • The healthcare professional must not carry more than 5 kg of clinical waste at any one time;
   • No Group 4 waste may be delivered in this manner;
   • Group 1 waste must be packaged in containers that are puncture- resistant, shatter-proof and leak-proof (e.g. sharps boxes);
   • Other groups of clinical waste must be packaged in secondary containers that are made of rigid material, impervious to moisture and leak-proof, and that will not rip, tear or burst under normal conditions of handling in accordance with the specifications set out in Code of Practice;
   • The clinical waste must be properly packaged to prevent spillage, and the secondary containers must be labelled;
   • Only private car## within the meaning of the Road Traffic Ordinance (Cap. 374) must be used as a means of transport in delivering the clinical waste;
   • The clinical waste must be delivered directly to a collection point or licensed disposal facility within 24 hours and must not be left unattended during the delivery;
   • Adequate and appropriate first-aid equipment and cleaning equipment (e.g. spare red bags and sharps boxes) for use in case of injury to any person and spillage of clinical waste. Refer to the Annex D of Code of Practice.
   • if any clinical waste is spilled while it is being delivered, the healthcare professional must remove the spilled clinical waste and clean the area of the spillage.
   
   # Note: A healthcare professional is a :
   • registered dentist
   • registered medical practitioner
   • registered or enrolled nurse
   • registered veterinary surgeon
   • registered or listed Chinese medicine practitioner
   as defined in the various ordinances detailed in the Waste Disposal (Clinical Waste) (General) Regulation.
   ## Private car means a motor vehicle constructed or adapted for use solely for the carriage of a driver and not more than 7 passengers and their personal effects but does not include an invalid carriage, motor cycle, motor tricycle or taxi.
   

4. What is the definition of private car for self-delivery of clinical waste by healthcare professionals?

   In the context of self-delivery of clinical waste by healthcare professionals, the meaning of private car would be as defined in the Road Traffic Ordinance (Cap. 374). It means a motor vehicle constructed or adapted for use solely for the carriage of a driver and not more than 7 passengers and their personal effects but does not include an invalid carriage, motor cycle, motor tricycle or taxi.

5. What is the cost for disposing clinical waste under the Clinical Waste Control Scheme? Who will be charged?

   Under the Scheme, EPD will charge HK$2.7 per kg of clinical waste (less than 1 kg will be counted as 1 kg) for the disposal of clinical waste. This fee will be paid by the person using the disposal site i.e. licensed waste collectors who deliver the waste to the site.

6. Is there any regulation governing the handling fee charged by the clinical waste collectors?

   The cost of waste collection is subject to the location, the haulage distance, the amount of waste and the dispersion of other healthcare operators nearby. There may not be one fixed rate that fits all situations. We believe the presence of 7 licensed clinical waste collectors in this service sector does provide healthy competition to keep the price reasonable.

7. Does the government provide clinical waste collection service?

   Currently there is no government-operated clinical waste collection service. Producers of clinical waste should engage the service of clinical waste collection companies.

8. Where can I obtain the list of licensed clinical waste collectors?

   A list of most updated licensed clinical waste collectors can be found from the EPD's website. However this list is for reference only and waste producers are free to choose any collector's service.

Disposal

1. How should I handle the needles used in outreach programs?

   Used or contaminated needles generated during outreach healthcare work are clinical wastes. This means their handling, collection, transportation and disposal are subject to legal control. You should safely package the clinical wastes as soon as they are produced and engage the service of licensed clinical waste collector to remove the wastes. Since there is a whole range of outreach healthcare work, you are welcome to write to us with substantive description of your work. We could then provide more comments.

2. Should I put the used sharps box into red clinical waste collection bag before disposal?

   There is not a requirement under normal circumstances. However you may exercise your professional judgement, and based on infection control or public health considerations, to put the sharps box into the bag if the exterior of the sharps box is contaminated.

3. Is there any guideline from EPD regarding the collection/disposal frequency of clinical waste?

   The frequency of clinical waste collection should be agreed between waste producer and licensed collector taking into account the nature and quantity of clinical waste generated. The Code of Practice for the Management of Clinical Waste - Major Clinical Waste Producers and Waste Collectors gives an indication on the collection frequency for hospitals, government clinics and government laboratories (section 6.2).
   For small clinical waste producers, the Code of Practice has not specified a collection frequency. However based on hygiene and OSH risk considerations, our general advice is to remove clinical waste from your venue as soon as possible and in any case do not store more than 6 months.

4. Is there any charge for the disposal of clinical waste?

   The government imposes a charge for the use of the clinical waste disposal facility. The rate will be $2.7 per kg of clinical waste. You can refer to the Waste Disposal (Charge for Disposal of Clinical Waste) Regulation (Chapters 354P). However, your clinical waste collector will charge a fee different from the above to cover collection, transportation and other overheads.

Regulations

1. Will inspectors come to check my company frequently?

   Officers from EPD may visit healthcare premises, nursing homes, veterinary clinics, laboratories and research institutions with or without prior notice in order to regularly check for due compliance with the Clinical Waste Regulation or to investigate complaints.
   We will only do so when necessary and will endeavour to complete the checks or the investigation as quickly as possible. Your full cooperation will be greatly appreciated.
   EPD inspectors will also monitor compliance of clinical waste collectors on safe operation.

2. Do you charge for the disposal of clinical waste? By how much ?

   The government imposes a charge for the use of the Chemical Waste Treatment Centre which receives the clinical waste for incineration. The rate will be $2.70 per kg of clinical waste. You can refer to the Waste Disposal (Charge for Disposal of Clinical Waste) Regulation (Chapter 354P).　However, it is understood that clinical waste collectors seek a service charge different to this rate to cover manual collection, transportation, administration and other overheads.

3. What is the Clinical Waste Control Scheme ?

   The Clinical Waste Control Scheme aims to promote a high standard of public health in Hong Kong through better management of Clinical Waste from the source of its production to the site of its final disposal. The scheme comprises 5 key elements : 1. Establishing a licensing framework for all clinical waste collectors and disposal facility operators; 2. Requiring waste producers to properly manage their clinical waste by consigning the clinical waste to licensed clinical waste collectors for delivery to a licensed disposal facility for disposal; 3. Promulgating Codes of Practice to provide guidance for clinical waste producers and waste collectors; 4. Setting up a trip ticket system to track the movement of clinical waste from source to disposal facility; 5. Designating the Chemical Waste Treatment Centre (CWTC) as the facility to treat clinical waste and levying a disposal charge for use of the facility.

4. When did the Clinical Waste Control Scheme begin ? Is it going to continue for some time ?

   The Clinical Waste Control Scheme became effective as from 1st August 2011. The framework of management of the waste is written into law, namely the Waste Disposal Ordinance and its subsidiary legislations. There is not an end date. Healthcare and veterinary practices, lab practices and research establishments should identify whether they produce clinical waste and incorporate waste segregation, packaging, labelling, storage and safe disposal of clinical waste into their operation. Cleaning companies must obtain a licence from EPD before they can provide clinical waste collection service.

5. What is the maximum penalty of clinical waste offences ?

   Offence provisions are contained in the Waste Disposal Ordinance (Cap 354) and Waste Disposal(Clinical Waste)(General)Regulation (Cap 354 O). You can browse the law at the Bilingual Law Information System website maintained by the Department of Justice http://www.legislation.gov.hk/eng/home.htm. Clauses vary in penalty limit. The maximum penalty for the offence in causing danger to public health or safety, pollution to the environment or nuisance to the neighbouring area due to improper handling, storage, transportation or disposal of clinical waste is a fine of $200,000 and 6 months imprisonment.

6. How did the content of the control scheme developed into its present form ?

   The clinical waste control scheme is the result of studies and elaborate discussion among the government, the healthcare associations and a wide range of stakeholders. Legislative provisions were well debated and then passed into law in LegCo. It fulfills the need for a robust and excellent public health standard in Hong Kong through sensible management of clinical waste among healthcare professionals, lab analysts and research scientists.

Producers

1. What are the responsibilities of clinical waste producers under the Clinical Waste Control Scheme? Is it an offence if the condition of my storage area does not match up with the Code of Practice ?

   Producers of clinical waste have a duty of care to ensure that their waste are handled, stored and disposed of in a safe and proper manner. As a minimum, they should take all necessary precautions in handling and storage of the clinical waste, ensure its safe disposal and keep record of each disposal. You can refer to Section 3, 7 and 12 of the Waste Disposal (Clinical Waste)(General)Regulation for reference. Healthcare operators should:
   1. Provide adequate and proper containers, storage area, staff guidance and safety instructions within your premises to handle clinical waste. Monitor and enforce the system.
   2. Carefully select and engage the service of a licensed collector who can provide quality clinical waste collection service;
   3. Monitor the collector's service and promptly investigate problems and take remedial actions on mis-handling of clinical waste;
   4. Keep records of the clinical waste consigned to licensed collectors. Promptly produce such records for inspection upon request by EPD.
   In the event of an investigation into an alleged offence, waste producers who cannot provide evidence in support of their attempt to apply the Code of Practice will not have a reasonable defence if being prosecuted.

2. Where can I get the Code of Practice?

   The Resources section of our Clinical Waste Management website allows browsing and downloads. http://www.epd.gov.hk/epd/clinicalwaste/nonflash/tc_chi/downloads/document.html

3. How are major and small clinical waste producers distinguished?

   This is set out in Annex A of the Code of Practice. Examples of major producers are: Hospitals, Government clinics, dental hospital, registered nursing homes and maternity homes. Examples of Small Clinical Waste Producers are: private medical clinics, dental clinics, medical laboratories, Chinese medicine practitioners, residential care homes for the elderly, labs conducting medical or pharmaceutical research, vet clinics, and other locations with medical practice.

4. I have already commenced business at my new location and we are already producing clinical waste. How could I obtain a premises code ?

   You can download and fill the form Premises Code Request Form (New Application)”from the Clinical Waste Management website for applying Premises Code. (Website: http://www.epd.gov.hk/epd/clinicalwaste/nonflash/tc_chi/downloads/document.html) Please fill in the form and attach a copy of the BRC (if applicable) and fax it to the relevant EPD regional office of your area.

5. In case I need to change some particular information in my Premises Code, what shall I do?

   You can download and fill in the form : “Premises Code Request Form (Change in Particulars)”from the Clinical Waste Management website for amending information connected with your Premises Code. (Website: http://www.epd.gov.hk/epd/clinicalwaste/nonflash/tc_chi/downloads/document.html) Please tick the right box and fax the completed form to the EPD regional office of your area.

6. I have been assigned a premises code but I do not produce clinical waste any more. Can I cancel it?

   You are welcome to cancel the premises code if you do not produce clinical waste at that venue any more. You can download and fill in the form : “Cancellation of Premises Code” from the Clinical Waste Management website. Please fax the completed form to EPD regional office to cancel your Premises Code.

7. My clinic will begin operation in the next few days. Do I need a blank trip ticket to fill in and how can I get one ?

   Usually the licensed clinical waste collector will begin his collection round with a trip ticket with his details printed before leaving office. As you handover the waste to him, you should confirm information on the clinical waste trip ticket before the sign and stamp the company chop on it. If you want to begin a self-delivery of clinical waste by private car to the Chemical Waste Treatment Centre, you can obtain blank trip ticket from our Regional Office. For details, please browse our website.

8. Why is there a barcode on the trip ticket?

   The barcode provides machine-reading opportunity for data automation purposes. Producers of Clinical Waste should still properly enter complete information and sign on the trip ticket.

9. Am I required to fill in the trip ticket every time when i consign my waste to a waste collector ?

   Yes, it is a statutory requirement to retain the trip ticket upon consigning the waste. By law, you should also keep such records for not less than 12 months.

10. How long should I keep the records of waste consignment or delivery?

    Such records may include copy of trip ticket or receipt of waste consignment issued by the clinical waste collector or licensed disposal facility i.e. the Chemical Waste Treatment Centre at Tsing Yi. Waste producers must keep such records on their premises for at least 12 months from the date of collection, and produce the record to EPD for inspection when so required.

11. Can practitioners from the same company/organization/establishment, but not in the same premises, gather all the waste at one point to store before collection?

    If the building is wholly occupied by the organization, the practitioners from the same organization in the same building can use one Premises Code. They can centralize their clinical waste at one location within the same complex/building before collection. However, where the operations are split apart in different premises and the building is occupied by multiple users of different companies or institutions, discrete premises should obtain their individual premises code. The clinical waste collector should do door-to-door collection of clinical waste. We impose strict operational safety standard upon licensed clinical waste collectors to avoid hazard in conveying waste in communal areas and public place. Healthcare operators should be mindful of their liability.

12. Can practitioners sharing the same premises use one Premises Code? Who will be responsible for any non-compliance issues in this situation?

    Practitioners sharing the use of the same premises can use one Premises Code when consigning the clinical waste to a licensed collector. They can agree among themselves the representation or responsibility that the premises code corresponds to. All practitioners sharing the same Premises Code could be liable in a prosecution case. Responsibility could be more clearly defined if each practitioner obtains and uses his/her own Premises Code to dispose of clinical waste and keep records accordingly. Producers in different premises, or a company with many premises should all acquire separate Premises Codes, i.e. one location one code.

13. If my rehabilitation centre span a few continuous floors and all the facilities are solely owned by my organization, can I use one permises code and centralize all the clinical waste in one refuse room?

    We have no objection to one premises code representing all continuous floors which your organisation solely occupies. If you prefer, you may obtain different premises codes to suit different offices in the same organisation, e.g. differentiating residential care homes from outreach home care services. However we do not recommend that you move clinical waste from floor to floor, since this involves communal elevator and stairways. Clinical Waste collector should collect directly from each floor.

14. Can my property management company collect the clinical waste for me?

    For safety reasons, we only issue clinical waste collection licence to competent operators to remove clinical waste from producers of clinical waste. Any company can apply. This is a feature of the Clinical Waste Control Scheme that aims to prevent incidents caused by clinical waste in public areas. Without such licence, a property management company should not arrange cleansing staff to remove clinical waste from clinics, labs, medical beauty establishments or residential care homes because that will constitute an offence under the Waste Disposal Ordinance. Further, the producer of waste will also be liable to offence under Section 3 of the Clinical Waste Regulation. Clinical waste collection should only be carried out by licensed clinical waste collectors who operate with competent staff and a range of safeguards.

15. Am I required to contact EPD if my clinics moves to a new location ?

    Yes, you should change your premises code for disposal of clinical waste. It is a unique number for each location. If you relocate your clinic, you should cancel the old premises code and obtain a new one. Simply fill in a form and fax it to our Regional Office and we will generate a new Premises Code for your new site and cancel the old one.

16. Are all medical doctors regarded as Clinical Waste Producers ?

    It depends on the practice. The organisation that causes to produce clinical waste is the producer. For example, a hospital will be responsible for proper disposal of clinical waste generated on site or in outreach healthcare services. Some practices that do not conduct injections, other invasive procedures, wound care or others may not generate any group of clinical waste such as sharps, lab culture, human or animal tissues, infectious material, dressing or blood at all. The healthcare organisation should determine that. To know more, browse our Resources Section and read the Code of Practice.

17. I run two clinics in the same commercial building but on different floors, can I centralize the waste in one clinic for disposal?

    The direct answer is no. We assert strict safety requirements on the carriage of clinical waste in public areas. Companies conducting a collection service of clinical waste must apply for and obtain a licence from EPD and operate with a range of safeguards. Apart from this, healthcare professionals directly delivering clinical waste to the treatment plant in Tsing Yi, or a clinical waste collection point outside of their premises, have to fulfill all requirements laid down in Section 4 of the Clinical Waste Regulation. Without an authorization from EPD, a clinic cannot receive clinical waste from another premises. Neither can a clinic send staff to deliver clinical waste to a clinic or a lab which is not an authorized clinical waste collection point.

18. Our company operates a clinic on 3rd floor and another on 12th floor of the same building. Can you register us as one producer ?

    Each unit will be a separate entity. EPD will assign Premises Code to each location.

19. I am a doctor who works in a medical centre. Should the medical centre register as a Clinical Waste Producer ?

    The organisation that is responsible for the medical practice is the producer of the clinical waste. It should engage the service of a clinical waste collector for proper removal of clinical waste. To allow record be registered in EPD's system, the organisation should obtain a Clinical Waste Producer Premises Code.

20. My clinic is bidding a job to provide flu vaccination for elderlies at a community hall, can I take the sharps waste back to the clinic ?

    By law, this is a waste collection service that can only operate under a licence issued by EPD. A licensed waste collector could remove clinical waste from the site in a waste skip and transport it on dedicated vehicle. The healthcare personnels conducting vaccination in a community hall, inside a company or elsewhere should not transport the sharps but should engage the service of a licensed clinical waste collector to remove the clinical waste.

21. My school also conducts experiments on animals in the lab as part of teaching on biology. It is a secondary school. Is my school a producer of clinical waste ?

    Education practice in secondary schools is not within the scope of the Clinical Waste Control Scheme. The animal carcasses, sharps waste or cultures of microorganisms produced in secondary school biology lessons or interest classes are not classified as clinical waste.

22. Our school has recently designated a healthcare room in case students or staff encounter minor wounds or have a medical condition. Is the school regarded as clinical waste producer and do we require a premises code ?

    If a healthcare professional such as a nurse conducts nursing practice at the site AND generate sharps waste and other clinical waste on the premises, the school would become a producer of clinical waste. It should engage the service of a clinical waste collector to remove clinical waste. However it is understood that few schools will provide such service on site. If ambulance is called upon to handle a medical emergency at the school, the paramedic will be responsible for any sharps waste or used wound dressing that are produced. The paramedic will remove the clinical waste to his ambulance. In school immunization exercise for primary school pupils, the immunization team will be responsible for the sharps and other clinical waste that are produced and they will engage licensed clinical waste collector to remove the waste after the end of the session based on the team's premises code.

Supplementary Medical Professionals

1. We are a physiotherapy centre and we have a therapist that practises dry needling on customers to release muscle tension as part of their treatment. We would like to dispose of the sharps in a safe and hygienic manner. Please advise how to proceed ?　

   If the physiotherpist at your venue conducts treatment of musculoskeletal dysfunction for patients or provide pain management, we consider it relevant that the sharps waste and others belong to Clinical Waste as stipulated in Waste Disposal Ordinance. To this end, you should safely package, label, store Clinical Waste and arrange for its collection as recommended in the "Code Of Practice for the Management of Clinical Waste - Small Clinical Waste Producers" You should also ensure proper disposal of the clinical waste in accordance with Waste Disposal(Clinical Waste)(General)Regulation. You could satisfy this latter requirement by engaging the service of licensed clinical waste collector to collect the clinical waste directly from your venue and you should keep a record of the waste consignment for not less than 12 months. You should obtain a clinical waste producer premises code from EPD.

2. We are a comprehensive medical centre that provides chiropractic treatment and occupational therapy. Our therapists are trained to assess and treat movement disabilities, pain and functional disorders of the human body by needling and acupuncture. Are the sharps and syringes regarded as clinical waste ? Are we a clinical waste producer ?

   If Chiropractors or occupational therapists operate at your venue to conduct treatment of disabilities, pain and functional disorders for patients, we consider it relevant that the sharps waste be handled as Clinical Waste as stipulated in Section 2, Waste Disposal Ordinance. The operator of the venue or the practitioner is a producer of clinical waste. The waste should be safely handled as clinical waste and without causing danger to public health or public safety, pollution to the environment or nuisance. The clinical waste should be disposed of in accordance with the Waste Disposal (Clinical Waste)(General) Regulation. Specifically this means arranging for waste collection by licensed clinical waste collectors and keep the record of the waste consignment for not less than one year. You should obtain a clinical waste producer premises code from EPD.

Veterinary Clinics

1. Are the organs of animanls excised during veterinary operations classified as clinical waste?

   Excised tissues or organs from veterinary operations are outside the scope of the Clinical Waste Control Scheme. You may refer to Schedule 8 of the Waste Disposal Ordinance (Cap 354). Likewise, animal carcasses from veterinary practice are not clinical waste and do not have to be handled as such. The vet clinic could produce clinical waste such as sharps waste and heavily blooded dressings. In rare circumstances, if the veterinary surgeon comes across animals contacted with pathogens listed in Group 4, e.g. Nipah virus or B virus, materials contaminated by those viruses will be regarded as clinical waste.

2. I am a vet. My team may use tranquilizer darts to sedate mammals. Are the used darts under control ?

   You should handle used tranquilizer darts as sharps waste under Group 1 clinical waste and adopt safe packaging, labelling and storage and organize their proper disposal as clinical waste.

3. A vet regularly comes to our riding school to check the health of horses. How shall I comply with clinical waste laws ?

   If veterinary practice is conducted at your premises, in this case a horse riding school, you should ensure that the stable is complete with all the necessary clinical waste packaging, labelling and storage facilities, and you acquire a clinical waste producer premises code from EPD. You can then arrange the service of a licensed clinical waste collector to remove waste from your premises. You should retain the waste producer copy of the clinical waste trip ticket for not less than one year as record of safe disposal.

Medical Beauty Treatment

1. Our company provides beauty enhancement service that involves Botox injections, skin whitening injections and liposuction for clients. Are the sharps and syringes regarded as clinical waste ? Are we a clinical waste producer ?

   Where a medical practititioner or other healthcare professional conducts an injection and produces sharps waste and dressings, the operator of the venue or the healthcare professional is a producer of clinical waste. The waste should be safely handled as clinical waste and without causing danger to public health or public safety, pollution to the environment or nuisance. The clinical waste should be disposed of in accordance with the Waste Disposal (Clinical Waste)(General) Regulation. Specifically this means arranging for waste collection by licensed clinical waste collectors and keep the record of the waste consignment. You should obtain a clinical waste producer premises code from EPD.

2. I am a manager of a beauty care centre. Our attendants only conduct facial cleansing for clients using sterilized needles. Do we have to comply with clinical waste laws ?

   If the attendants are not healthcare professionals or hygienists and that the procedure does not produce sharps waste or dressings, the operator is not a clinical waste producer. If in doubt, you are most welcome to call our hotline or write to us with specific information.

Nursing Homes

1. We operate a residential care home for the elderlies. Some elderlies have diabetes. Please confirm whether we are clinical waste producers or not.

   If your staff conduct injections or carry out an i.v. Drip to provide medical attention to your clients and therefore generate used syringes or other sharps, or produce heavily blooded dressings in wound care, the establishment is a producer of clinical waste. The clinical waste must be handled safely and properly in accordance with the Waste Disposal (Clinical Waste)(General) Regulation. You should also arrange a licensed clinical waste collector for removal of the waste from the venue.

2. Is expired medicine in elderly home classified as clinical waste?

   Expired drugs are not clinical waste but chemical waste. It is regulated under the Waste Disposal (Chemical Waste) (General) Regulation.

3. We organize healthcare people to come to our residential care home to conduct influenza vaccination once a year, who has responsibility of the waste syringes ?

   The waste from this healthcare practice - the immunization injection is clinical waste. The liability should be agreed between the two parties. Either the party conducting the vaccination or the elderly home can arrange a licensed clinical waste collector to remove the waste from your venue. Without a licence, the company conducting the injections must not transport the sharps boxes on their vehicle to their office.

4. I am the operation manager of a nursing home. We have arranged a doctor to come here to do medical consultation once a month. He may use lancets or do injections for our client on-site. What should I do ?

   Since your venue involves medical practice, you should obtain a clinical waste producer premises code from EPD and ensure that you have suitable sharps containers, proper clinical waste storage cabinet and the service of a licensed clinical waste collector to safely remove clinical waste from your premises.

5. Are needles used for blood sugar monitoring regulated in your law ?

   Lancets and retractable lancets for extraction of blood to determine blood sugar level constitute sharps waste. If you provide a healthcare service to support diabetes sufferers and produce this waste, the waste is clinical waste and they are your responsibility. They should be put into a sharps container that conforms to BS7320:1990 or an equivalent standard and you should seek the service of a licensed clinical waste collector to safely remove it from your venue. If you are only do so for caring your family member, the waste is household waste. For safety, you should put the used sharps into a puncture resistant, leak proof, shatter proof container that could be securely sealed. Mark it and keep the container away from children or other vulnerable persons. You can dispose of the container as municipal waste.

6. If the syringes are only for feeding purpose, is it a Group 1 clinical waste?

   If you are operating a nursing home and provide medical care for the infirm, the feeding syringe is regarded as Group 1 clinical waste.

For Clinical Waste Collectors

Packaging

1. I operate a clinical waste collection company and regularly distribute clinical waste plastic bags to clinics to hold waste. Starting from 1.4.2015, must I collect 50 cents for each bag from the clinic as the plastic shopping bag charge?

   Where the service provider, namely the clinical waste collection company, distributes the plastic bag to the client to enable the waste be packaged for subsequent collection, it is not regarded as retail sale of goods and therefore a plastic shopping bag charge as prescribed in Product Eco-responsibility Ordinance (Chapter 603) is not applicable. If the bags are sold to the client as a product, each pre-packaged pack of 10 or more bags should be sold at a price not less than 50 cents. However, at least 50 cents should be charged for each bag should the pre-packaged pack has 9 or fewer bags. For further information on the Full Implementation of the Plastic Shopping Bag Charging, please visit our dedicated website. Alternatively you can reach our hotline at 3152 2299, our service agent will endeavour to answer your enquiry.

2. Where can I buy the sharps boxes and/or clinical waste plastic bags?

   Clinical waste plastic bags and sharps boxes are often provided as part of the service by the Clinical Waste collection company although they are also available for purchase from medical goods supplier or plastic bag suppliers. Healthcare operators can search by internet or telephone directories or check with peers.

3. Does clinical waste have to be stored in red or yellow plastic bags?

   In basic terms, human and animal tissues should be packaged in yellow bags, sharps should be placed into sharps box, while other groups of clinical waste should be packaged in red bags.

4. Can you specifically point out whether the materials of the sharps box should be combustible and capable of being safely incinerated, and should not be made from polyvinylchloride (PVC)?

   Chlorine could form acid gas and favour formation of dioxin in a combustion process. For environmental protection reasons, the plastic materials that make up the sharps container should be free of PVC or other chlorinated plastics.
   Since clinical waste is bound for incineration, the sharps container should be made of combustible material to allow direct incineration of its content.

Collection

1. Can I get 2 warning panels for my clinical waste collection vehicle from EPD?

   Each clinical waste collection vehicle should display a proper warning panel at both the front and rear. The size, colour, texts and construction of the panel are specified in the Code of Practice for the Management of Clinical Waste - Major Clinical Waste Producers and Waste Collectors, and EPD's licensing office also provides details. The same applies for marine vessel engaged in the collection of clinical waste. However, waste collectors should acquire warning panel from vendors and properly fix them on their vehicles/vessels.

2. If I want to apply for a clinical waste collection licence, where can I apply for the relevant training courses?

   Operatives in clinical waste collection team must be competent in handling clinical waste and able to deal with spillage situations. Each individual should complete relevant safety training. The Occupational Safety and Health Council as well as major educational institutions would offer relevant courses specific to clinical waste. You can contact them directly for further information.

3. I want to set up a clinical waste collection point. What should I do?

   A producer of clinical waste may prepare a plan and seek EPD's authorization to set up an on-site collection point to receive clinical waste generated by other waste prodcuers. Due to public health and safety concerns, the pre-requisites and operational level will be demanding. You can call our Clinical Waste Hotline at 28351055 to learn about the details and the requirements. For application procedures, you will need to fill an application form. Upon receiving it, we will arrange a meeting with you to discuss the criteria and how to meet the requirements.

4. Where can I obtain the list of licensed clinical waste collectors?

   A list of most updated licensed clinical waste collectors can be found from the EPD's website. However this list is for reference only and waste producers are free to choose any collector's service.

Regulations

1. Will inspectors come to check my company frequently?

   Officers from EPD may visit healthcare premises, nursing homes, veterinary clinics, laboratories and research institutions with or without prior notice in order to regularly check for due compliance with the Clinical Waste Regulation or to investigate complaints.
   We will only do so when necessary and will endeavour to complete the checks or the investigation as quickly as possible. Your full cooperation will be greatly appreciated.
   EPD inspectors will also monitor compliance of clinical waste collectors on safe operation.

2. Do you charge for the disposal of clinical waste? By how much ?

   The government imposes a charge for the use of the Chemical Waste Treatment Centre which receives the clinical waste for incineration. The rate will be $2.70 per kg of clinical waste. You can refer to the Waste Disposal (Charge for Disposal of Clinical Waste) Regulation (Chapter 354P).　However, it is understood that clinical waste collectors seek a service charge different to this rate to cover manual collection, transportation, administration and other overheads.

3. What is the Clinical Waste Control Scheme ?

   The Clinical Waste Control Scheme aims to promote a high standard of public health in Hong Kong through better management of Clinical Waste from the source of its production to the site of its final disposal. The scheme comprises 5 key elements : 1. Establishing a licensing framework for all clinical waste collectors and disposal facility operators; 2. Requiring waste producers to properly manage their clinical waste by consigning the clinical waste to licensed clinical waste collectors for delivery to a licensed disposal facility for disposal; 3. Promulgating Codes of Practice to provide guidance for clinical waste producers and waste collectors; 4. Setting up a trip ticket system to track the movement of clinical waste from source to disposal facility; 5. Designating the Chemical Waste Treatment Centre (CWTC) as the facility to treat clinical waste and levying a disposal charge for use of the facility.

4. When did the Clinical Waste Control Scheme begin ? Is it going to continue for some time ?

   The Clinical Waste Control Scheme became effective as from 1st August 2011. The framework of management of the waste is written into law, namely the Waste Disposal Ordinance and its subsidiary legislations. There is not an end date. Healthcare and veterinary practices, lab practices and research establishments should identify whether they produce clinical waste and incorporate waste segregation, packaging, labelling, storage and safe disposal of clinical waste into their operation. Cleaning companies must obtain a licence from EPD before they can provide clinical waste collection service.

5. What is the maximum penalty of clinical waste offences ?

   Offence provisions are contained in the Waste Disposal Ordinance (Cap 354) and Waste Disposal(Clinical Waste)(General)Regulation (Cap 354 O). You can browse the law at the Bilingual Law Information System website maintained by the Department of Justice http://www.legislation.gov.hk/eng/home.htm. Clauses vary in penalty limit. The maximum penalty for the offence in causing danger to public health or safety, pollution to the environment or nuisance to the neighbouring area due to improper handling, storage, transportation or disposal of clinical waste is a fine of $200,000 and 6 months imprisonment.

General

Packaging

1. I operate a clinical waste collection company and regularly distribute clinical waste plastic bags to clinics to hold waste. Starting from 1.4.2015, must I collect 50 cents for each bag from the clinic as the plastic shopping bag charge?

   Where the service provider, namely the clinical waste collection company, distributes the plastic bag to the client to enable the waste be packaged for subsequent collection, it is not regarded as retail sale of goods and therefore a plastic shopping bag charge as prescribed in Product Eco-responsibility Ordinance (Chapter 603) is not applicable. If the bags are sold to the client as a product, each pre-packaged pack of 10 or more bags should be sold at a price not less than 50 cents. However, at least 50 cents should be charged for each bag should the pre-packaged pack has 9 or fewer bags. For further information on the Full Implementation of the Plastic Shopping Bag Charging, please visit our dedicated website. Alternatively you can reach our hotline at 3152 2299, our service agent will endeavour to answer your enquiry.

2. When I issue medications to patients, can I provide them with a plastic bag to hold the pills without charging them for the bag ?

   Where there are no retail sales of goods, plastic bags given out will not be subject to the plastic shopping bag charge under the Product Eco-responsibility Ordinance (Chapter 603). Medical consultation is not regarded as a retail activity and plastic bags provided in relation to medical consultation are exempted from the charge. For further information on the Full Implementation of the Plastic Shopping Bag Charging, please visit our dedicated website. Alternatively you can reach our hotline at 3152 2299 , our service agent will endeavour to answer your enquiry

3. Does clinical waste have to be stored in red or yellow plastic bags?

   In basic terms, human and animal tissues should be packaged in yellow bags, sharps should be placed into sharps box, while other groups of clinical waste should be packaged in red bags.

4. Can you specifically point out whether the materials of the sharps box should be combustible and capable of being safely incinerated, and should not be made from polyvinylchloride (PVC)?

   Chlorine could form acid gas and favour formation of dioxin in a combustion process. For environmental protection reasons, the plastic materials that make up the sharps container should be free of PVC or other chlorinated plastics.
   Since clinical waste is bound for incineration, the sharps container should be made of combustible material to allow direct incineration of its content.

Definition

1. How to treat the clinical waste generated in domestic premises ? My family member needs to do dialysis and injections at home.

   If your family member needs to do dialysis and injections at home, the waste generated is household waste. For safety, you should put the used sharps into a puncture resistant, leak proof, shatter proof container that could be securely sealed. Mark it and keep the container away from children or other vulnerable persons. You can dispose of the container as municipal waste.

2. Are needles used in blood sugar monitoring classified as clinical waste?

   If you operate a healthcare practice and use lancets in blood sugar monitoring, the used lancets, whether of retractable type or otherwise, are regarded as sharps waste and belong to Group 1 clinical waste. The waste must be placed in a sharps container conforming to the BS7320:1990 standard or equivalent and safely disposed of in compliance with the Clinical Waste Regulation.

3. Are urine samples or faeces samples for medical analysis classified as clinical waste?

   Urine and faeces or samples of these are not regarded as Clinical Waste. They can be discharged into the lavatory.

4. Is vomitus from patients classified as clinical waste?

   They are not clinical waste and could be disposed as municipal waste. However, if it is produced by patients with those diseases such as Ebola virus disease listed under Group 4 Clinical Waste, the material contaminated by the virus and destined for disposal is regarded as Clinical Waste. For a full list of the infectious diseases under Group 4, read the Code of Practice or Schedule 8 of the Waste Disposal Ordinance.

5. Are the animals which died naturally in the university laboratory classified as clinical waste?

   It depends on how animals are traced, transported or exposed to on campus and in the lab or animal breeding house. Cause of death whether natural or due to communicable agents is often not thoroughly determined. A dead animal which was bred in the research lab and, without a history of experimental manipulation may not be classified as clinical waste. But if you are uncertain about it, it is prudent to handle the animal carcass as clinical waste.

6. Are the animal carcasses produced in univeristy classified as Group 3 clinical waste?

   In the university, animal tissue or dead animals arising from experiments, tests or research are classified as Group 3 clinical waste. While it could imply animal carcasses other than from these activities can be disposed of as municipal waste, it could cause confusion or lead to oversight if the two streams are crossed over in the same lab or same building. It is therefore best to handle all dead animals as clinical waste.

7. Are the sharps used in school medical room classified as clinical waste?

   Normally in a school, only healthcare professionals would handle sharps on pupils. Sharps produced by a healthcare professional is classified as clinical waste.

Regulations

1. What is the Clinical Waste Control Scheme ?

   The Clinical Waste Control Scheme aims to promote a high standard of public health in Hong Kong through better management of Clinical Waste from the source of its production to the site of its final disposal. The scheme comprises 5 key elements : 1. Establishing a licensing framework for all clinical waste collectors and disposal facility operators; 2. Requiring waste producers to properly manage their clinical waste by consigning the clinical waste to licensed clinical waste collectors for delivery to a licensed disposal facility for disposal; 3. Promulgating Codes of Practice to provide guidance for clinical waste producers and waste collectors; 4. Setting up a trip ticket system to track the movement of clinical waste from source to disposal facility; 5. Designating the Chemical Waste Treatment Centre (CWTC) as the facility to treat clinical waste and levying a disposal charge for use of the facility.

2. When did the Clinical Waste Control Scheme begin ? Is it going to continue for some time ?

   The Clinical Waste Control Scheme became effective as from 1st August 2011. The framework of management of the waste is written into law, namely the Waste Disposal Ordinance and its subsidiary legislations. There is not an end date. Healthcare and veterinary practices, lab practices and research establishments should identify whether they produce clinical waste and incorporate waste segregation, packaging, labelling, storage and safe disposal of clinical waste into their operation. Cleaning companies must obtain a licence from EPD before they can provide clinical waste collection service.

3. What is the maximum penalty of clinical waste offences ?

   Offence provisions are contained in the Waste Disposal Ordinance (Cap 354) and Waste Disposal(Clinical Waste)(General)Regulation (Cap 354 O). You can browse the law at the Bilingual Law Information System website maintained by the Department of Justice http://www.legislation.gov.hk/eng/home.htm. Clauses vary in penalty limit. The maximum penalty for the offence in causing danger to public health or safety, pollution to the environment or nuisance to the neighbouring area due to improper handling, storage, transportation or disposal of clinical waste is a fine of $200,000 and 6 months imprisonment.

4. How did the content of the control scheme developed into its present form ?

   The clinical waste control scheme is the result of studies and elaborate discussion among the government, the healthcare associations and a wide range of stakeholders. Legislative provisions were well debated and then passed into law in LegCo. It fulfills the need for a robust and excellent public health standard in Hong Kong through sensible management of clinical waste among healthcare professionals, lab analysts and research scientists.

Producers

1. My school also conducts experiments on animals in the lab as part of teaching on biology. It is a secondary school. Is my school a producer of clinical waste ?

   Education practice in secondary schools is not within the scope of the Clinical Waste Control Scheme. The animal carcasses, sharps waste or cultures of microorganisms produced in secondary school biology lessons or interest classes are not classified as clinical waste.

2. Our school has recently designated a healthcare room in case students or staff encounter minor wounds or have a medical condition. Is the school regarded as clinical waste producer and do we require a premises code ?

   If a healthcare professional such as a nurse conducts nursing practice at the site AND generate sharps waste and other clinical waste on the premises, the school would become a producer of clinical waste. It should engage the service of a clinical waste collector to remove clinical waste. However it is understood that few schools will provide such service on site. If ambulance is called upon to handle a medical emergency at the school, the paramedic will be responsible for any sharps waste or used wound dressing that are produced. The paramedic will remove the clinical waste to his ambulance. In school immunization exercise for primary school pupils, the immunization team will be responsible for the sharps and other clinical waste that are produced and they will engage licensed clinical waste collector to remove the waste after the end of the session based on the team's premises code.

Property Management Company

1. My company is responsible for property management. What should I do in case our security guard finds clinical waste abandoned in the common areas of the building ?

   For general safety, you should first cordon off the area where clinical waste is found and try to identify who deposited the waste and request him to arrange for proper disposal of the waste. Usually, surveillence cameras, asking nearby occupiers and narrowing down those units that usually produce clinical waste would offer clues. If the means are exhausted and the depositor of the waste cannot be identified, the property management company has the responsibility to arrange for a licensed clinical waste collector to remove the abandoned waste for proper disposal. Before engaging the service of clinical waste collector, the management company should first obtain a one-off Clinical Waste Producer Premises Code from EPD for the waste collector to complete the waste collection procedures. To obtain a code, you should complete a Clinical Waste Producer Premises Code Request Form and return it by fax to the EPD Regional Office corresponding to the location of the premises where clinical waste is abandoned. The Request Form can be downloaded here.
   After you obtained a P-Code, you should urgently arrange a licensed clinical waste collector to remove the clinical waste within the validity period of the P-Code. The P-Code that is issued to you is for a one-time use only and it cannot be used again. You must keep the Waste Producer copy of Clinical Waste Trip Ticket in the building for at least 12 months. You should also take follow up actions to avoid recurrence of similar incidents in the building, e.g. advise the tenants/occupiers to properly handle clinical waste, put up notices, increase patrol frequency particularly to the blackspot of waste abandonment, suitably install cameras and track down culprits.

2. Will EPD provide service to remove the clinical waste abandoned in the building managed by my company?

   No. It is the responsibility of the concerned management company and the owners to guard the communal areas and assure the safety of the occupiers and users within their property. If hazardous materials are found, it is the co-op owners or the property manager's responsibility to arrange for safe handling and removal.

3. Where can I obtain the list of licensed clinical waste collectors?

   A list of most updated licensed clinical waste collectors can be found from the EPD's website. However this list is for reference only and waste producers are free to choose any collector's service.

4. I am the estate manager of a commercial building and I need to remove a bag of clinical waste abandoned in the stairway of the building. But in Part B of the Clinical Waste Producer Premises Code Request Form, there is no business type that is relevant to my company. How do I complete this Part of the form?

   Since property management is not a healthcare practice, the manager should tick Others” and then specify “Property Management Company” in the space provided. Be reminded that the request is only for a single-use premises code.

5. As the property management, can I temporarily store the abandoned clinical waste before the clinical waste collector arrives and what are the storage requirements?

   In your situation, you need to put the clinical waste away at a safe location and lock it up to prevent tampering by unsuspecting passers-by or unauthorized personnel. It will be best to mark the area with a caution sign. Avoid mixing it up with other waste or recyclables.

6. There are a number of medical clinics and laboratories in the building that I manage. Can I provide storage facility inside the building for them to store the clinical waste they produced?

   No, this could cause confusion in responsibility and also constitutes an offence for lack of EPD authorization. Property management companies cannot provide clinical waste storage facility in the building to store clinical waste generated by clinical waste producers (e.g. clinics, laboratories). Clinical waste producers must keep the clinical waste they produced within the waste producing premises. They should arrange proper disposal of their clinical waste, e.g. by engaging licensed clinical waste collectors to collect the waste directly from their premises.

7. We are a property management company. Many clinics operate in our building. Can you register me as a waste producer ?

   The operator of a medical practice is the producer of clinical waste. Since your business is limited to maintaining the services of the building or shopping arcade, rather than a medical practice, you are not a producer of clinical waste. Each individual clinic is legally responsible for the clinical waste they produce.

8. I am manager of a club house in a residential estate, we have organized a doctor to do medical consultation at the club house once a week. What shall we do with the waste syringes that he would produce ?

   The doctor should obtain a clinical waste producer premises code at the club house to arrange for removal of the sharps waste that he produces.