Healthcare Providers – Hospitals

Who are Healthcare providers?

This guide is for organisations that are involved in healthcare such as hospitals. However, there are separate Binny™ guides if you are part of the Ambulance Service, Research & Laboratory Facilities, Community Healthcare (Care Homes and Hospices), Community Pharmacies, General Practices/Health Centres and Dental Practices. Binny™ disposable sanitary bins are already in use within NHS Trusts.

By correctly classifying your sanitary bin waste will mean your organisation can utilise Binny™ and obtain all the Binny™ benefitsThis Disposal guide explains the legislation, explains how your organisation can utilise Binny™ and puts you in control. We would recommend reading The Department of Health – “Health Technical Memorandum 07-01: Safe management of healthcare waste 2013” (DOH 2013 Memorandum) and also the The Health and Safety Executive “Managing Offensive/Hygiene Waste” 2009.

Q: What is offensive/hygienic waste?

A. The Health and Safety Executive in “Managing Offensive/Hygiene Waste” 2009 classifies typical sanitary waste as offensive/hygiene waste and is the product of a healthy population (not known to be infectious). Offensive/hygiene waste “includes waste previously described as human hygiene waste and sanpro.”  (4.116, page 40, DOH 2013 Memorandum). The 2013 Memorandum specifically states,

“Offensive/hygiene waste may include
• Incontinence and other waste produced from human hygiene;
• Sanitary waste”

Page 40 of the DOH 2013 Memorandum also states that classifying sanitary and personal waste correctly..

“..and separating them out is probably the biggest saving that can be made in waste management. This is possibly one of the biggest opportunities to reduce wasted energy used in unnecessary treatment of non-infectious wastes and potentially introduces significant cost savings.”

Therefore, sanitary bin contractors are not required as offensive/hygiene waste can usually be classed as non-clinical and non-hazardous waste and this offensive/hygiene waste classification is shown in the DOH 2013 guidance, p.21.

Healthcare waste

It also is important to note that the memorandum provides specific guidance in this area for certain organisations which shows the DOH’s view that sanitary waste is offensive waste. For example, for General Practices and Health Centres section 24 (p.144) states that these organisations can “assign feminine hygiene wastes from toilets (as well as nappies from otherwise healthy children) into tiger bags as (offensive waste) 20 01 99 waste or if less than 7kgs per collection than can be placed in the municipal black bag.” For pharmacies it states in section 48, “Community pharmacies may produce offensive waste streams including: feminine hygiene wastes from staff or public toilets.” Section 49 continues, “Feminine hygiene wastes from toilets should be placed in a yellow/black receptacle and classified as 20 01 99.” This clearly shows that the Department of Health’s view of feminine hygiene waste is that it is offensive waste (which means you do not need a specialist sanitary bin contractor).

Q: So what does my organisation need to do in order to classify sanitary/personal material as offensive/hygiene waste?

For healthcare organisations a short assessment needs to be conducted. There are two charts that are useful within the DOH 2013 Memorandum. Both charts generally lead to the same result in classification (i.e. offensive waste) but it is worth reading through both charts and information as the supporting text is helpful. The first is detailed on p.24 of the DOH 2013 Memorandum.

Assessment framework for healthcare and similar wastes

The second chart is detailed on page 40 of the DOH 2013 memorandum (see below diagram). It is worth bearing in mind that, as we have seen earlier, both the HSE and the DOH have clearly stated that sanitary/personal waste can be classed as offensive/hygienic waste which demonstrates their intention that these waste types are classified correctly into this category i.e. not clinical/infectious/hazardous.

Healthcare assessment


The above process can be completed fairly quickly and we would recommend you follow the DOH 2013 Memorandum. However, we have provided a summary below which draws initially on the second chart and also then references the first chart.

i) Does the waste contain any items excluded from assessment?

These items are detailed on page 41 and includes sharps, pet carcasses etc. So assuming this is sanitary bin waste then the answer is “No”.

ii-a) Is the waste healthcare waste (4.124)?

The second question (4.124) is whether the waste is healthcare waste as classified under chapter 18 of the EWC (European Waste Catalogue 2009). 4.20 (p.24) of the DOH memorandum states that:

Healthcare waste is listed in chapter 18 of the EWC and relates to waste that is both:

  • Produced by healthcare activities; and
  • Of a type specifically associated with such activities


Feminine sanitary waste would be typically be considered domestic/household/municipal waste as the waste is arising from municipal sources (toilet facilities) rather than as a result of healthcare operations.

Therefore, the answer here is “No”. (Note: However, even if your organisation deems the waste as healthcare waste, then the sanitary/personal waste can still be classified as offensive/hygienic waste although the assessment process is slightly longer and shown in Answer 2. For example, this may be due to the sanitary waste being as a result of a surgical treatment for a specific patient on a ward).

ii-b) Assuming your assessment is that this is not healthcare waste, the next question asks “Is the waste a municipal waste that is similar to a healthcare waste?”. In section 4.24 (p.25), the Memorandum states that,

“Specifically included (as healthcare) are the following: Human hygiene wastes (sanitary products, nappies, incontinence waste etc);”

Therefore, the answer is yes and so leads us to iii-b.

iii-b) Has any risk of infection been identified by risk assessment

Again, as this is sanitary waste from general toilets then this will be a “No”, unless specific information is known that users are infectious which would not be known when they are general sanitary waste.  Also, it is worth noting that pages 42-44 in the DOH 2013 Memorandum states that sanitary waste arising from municipal activities is assumed to be non-infectious unless a healthcare practitioner indicates otherwise. Furthermore, the DOH’s view that sanitary/personal waste can often be regarded as offensive/hygienic waste is evident in the additional guidance in the Memorandum to General Practices, Health Centres, Pharmacies and Dental Surgeries. These organisations do not have to undertake an assessment. For example, for GPs and Health Centres section 24 (p.144) states that can “assign feminine hygiene wastes from toilets (as well as nappies from otherwise healthy children) into tiger bags as (offensive waste) 20 01 99 waste or if less than 7kgs per collection than can be placed in the municipal black bag.” This clearly shows that the DOH general view of feminine hygiene waste is that it is offensive waste unless there is evidence that it is infectious/hazardous.

Following the above process, the waste is therefore classified as Offensive/Hygienic under the code EWC 20 01 99.

Answer 2  – This assumes your assessment in i-a is that the sanitary waste is healthcare waste

If, when conducting your assessment under ii-a, your assessment is that the waste is healthcare waste then we now move onto iii-a. This states “Has the waste item been specifically assessed as indicated in the assessment framework (Steps 1-4) and determined to be a non-infectious and non-hazardous waste?”

To complete this section we are referred back to the first chart in the DOH 2013 Memorandum (p.24) and should proceed through steps 1-4 (although we have already completed step 1 as this was simply “Is the waste a healthcare waste?).

Step 2 – Assess for the medicinal waste properties of a waste
Step 3 – Assess for the chemical waste properties of a waste
Step 4 – Assess for the infectious waste properties of a waste


The methods of assessing the above steps are detailed in pp.25-. However, this will be straight forward for general sanitary waste. The only time this would be different would be if specific aspects were known about the sanitary/personal waste. For example, for the waste to be deemed infectious, it would need to be known that the waste “arises from a specific patient with a specific disease caused by a microorganism or its toxin” (table 2, p.34).  On p.35 the DOH states that judgement can be used to apply across the board. They provide the example of an elderly person in a care ward. Extending this example, it is acceptable to assume that as most women using the toilets are not suspected of having a disease caused by a microorganism, then the waste can be deemed non-infectious. The guidance even states in table 3 (p.35) that this non-infectious waste might include sanitary waste which again indicates the DOH’s belief that sanitary waste can be classed as offensive/hygiene waste.

Following the above process, the general sanitary/personal waste is therefore classified as Offensive/hygienic under code 18 01 04.

Q: So how to I dispose of Binny™?

bag binny binAs outlined above Binny™ when containing sanitary or personal waste will usually classified as Offensive waste. There assigned waste code will depend upon your above assessment and will be either 20 01 99 or 18 01 04. The rules for disposal depend on this classification and your volumes of Offensive waste. The DOH 2013 memorandum on p.44 states:

  1. 18 01 04 – A yellow bag with black strip should be used (the tiger bag).
  2. 20 01 99 – You can put upto 7kg of offensive waste in any bin collection in the black bag waste. Once completely full, Binny weighs less than 1kg. So you simply put Binny in your black bin bags. The Waste Code for black bag waste is 20-03-01 and is known as Mixed Municipal Waste. Volumes over 7kg should be placed in a tiger bag.


Q: So what type of waste management can take away Binny™

A: This depends on your volumes.

  1. For volumes under 7kg in any one collection cycle you simply use the black bag waste so you just use your current provider. This covers most organisations.
  2. For volumes over 7kg in any one collection cycle, collection is also simple and we recommend you discuss this with your waste management company regarding the collection of bulk offensive waste. However, this will be at least 40% cheaper than for hazardous/clinical waste (there are case studies within the DOH 2013 Memorandum on this area).


v small pdfDownload this page as a pdf

Leave a Comment