Disposing of Expired Reagents and Sharps in the UK: Hazardous Waste Rules for Small Quantities

An expired reagent does not become harmless on its expiry date, and a small quantity is not exempt from the waste rules. If a discarded laboratory chemical has hazardous properties it is hazardous waste. In England it leaves the premises with a registered carrier, under a consignment note, and the records are kept for three years ^[1]. The rules are the same for one crate as for a lorry load; only the cost changes.

This article covers the waste side only: classifying what is being thrown away, the paperwork, who may collect it, sharps and clinical waste, and the records. It picks up where a COSHH register line closes, when material leaves the store. England is described first, with Wales, Scotland and Northern Ireland set out afterwards.

Step one: classify

The producer's first duty in England is to classify the waste to check whether it is hazardous ^[1]. The technical guidance for doing so is WM3, which sets out the List of Waste codes and how to assess hazardous properties ^[6]. Laboratory chemicals have their own entries: laboratory chemicals consisting of or containing hazardous substances, including mixtures of laboratory chemicals, are coded 16 05 06*, where the asterisk marks a hazardous entry.

WM3 is specific about mixed containers. Its worked example of a crate holding bottles of three different laboratory chemicals says each chemical needs to be assessed as a separate waste ^[6]. A clear-out box is not one waste stream, and the carrier will ask what is in it.

The safety data sheet is the starting point and the COSHH register is the list. A lab that already knows what it holds, and how much, has done most of the classification work before the carrier asks. One that does not will do it under time pressure with the van waiting outside.

Whether the date on a label means the contents have actually changed is a separate, scientific question, and the reference network covers whether a peptide actually expires. For disposal, the date matters only as the trigger for clearing the shelf.

Storing it while it waits

Hazardous waste has to be separated and stored safely until it is collected ^[1]. For a small lab that means a labelled, segregated area away from in-use stock, with incompatible materials kept apart, in containers the carrier will accept. Waste awaiting collection is still covered by the COSHH assessment for the store, and it should be obvious to anyone opening the cupboard which items are waste.

Step two: a registered carrier

Hazardous waste must go to authorised businesses: carriers that are registered and sites that hold environmental permits, and the producer is expected to check both ^[1]. In England the Environment Agency's public register lets you search registered waste carriers, brokers and dealers by business name, registration number or postcode ^[3].

Two practical points. First, a general commercial waste contractor is not automatically set up for laboratory chemicals. Ask specifically whether it collects small-quantity laboratory hazardous waste, and whether it packs the items on site or expects them packed and listed. Second, a council household waste recycling centre is for household waste. Check your council's policy before assuming it will take anything from a business, and expect hazardous items to need a commercial arrangement made in advance.

Step three: the consignment note

In England you must use a consignment note to move hazardous waste, and it stays with the waste until it reaches its final destination ^[2]. You can use a note from your waste contractor, write your own, or buy notes from the Environment Agency, which come with three colour-coded copies. Each party completes its own part.

The producer fills in the parts that apply to it, keeps one copy and gives two copies to the carrier collecting the waste ^[1]. Check the carrier's registration on the day, not only when the contract was set up.

Non-hazardous waste moves under a waste transfer note instead, or under a document carrying the same information such as an invoice, and a copy is kept for two years ^[11]. A lab clearing a store usually produces both kinds: the hazardous chemicals on a consignment note, and the empty outer packaging and general waste on a transfer note.

Step four: the register

Records, known as a register, are kept for three years at the premises that produced or stored the waste. They include copies of consignment notes, consignee returns and related documents ^[1]. The consignee return is the receiving site's account of what it accepted, and it closes the loop: without it, the producer can show that the waste left, but not where it went.

• The consignment note code and date for each collection.
• The List of Waste code and a plain description of each item.
• The carrier's name and registration number, checked on the day.
• The consignee return when it arrives, filed with its note.
• A cross-reference to the COSHH register lines that were closed.

The Hazardous Waste (England and Wales) Regulations 2005 are the legal basis for all of this in England ^[4]. Despite the title, almost none of those regulations now applies in Wales, which has its own ^[5].

Sharps and clinical waste

Needles, blades and broken glass contaminated with biological material belong neither in the chemical waste route nor in the general bin. The NHS guidance HTM 07-01, Safe and sustainable management of healthcare waste, is the reference in England and Wales, and it states that it covers waste produced by laboratories and veterinary surgeries as well as healthcare settings ^[10].

HTM 07-01 colour-codes sharps receptacles by what the sharps are contaminated with, and says containers should be manufactured to BS EN ISO 23907-1 for single use or BS EN ISO 23907-2 for reusable containers ^[10]:

• Purple-lidded: sharps contaminated with cytotoxic or cytostatic medicines.
• Yellow-lidded: sharps contaminated with other medicines.
• Orange-lidded: sharps not contaminated with medicines.

Sharps are collected by a clinical waste contractor, who will specify the containers, the labelling and which stream applies. In Scotland and Northern Ireland, NetRegs states that infected sharps are hazardous or special waste, that consignment notes are needed for any that leave the site, and that the register of notes and consignee returns is kept for three years ^[9].

Wales, Scotland and Northern Ireland

In Scotland, all special waste produced there must be consigned on a special waste consignment note bearing a unique code issued by SEPA, whatever its destination in the UK ^[7]. In Northern Ireland, each movement uses a consignment note with a unique code, the NIEA is pre-notified before the movement, and fees for the codes vary with the type of movement: £24, £10, or in certain cases nothing ^[8].

Plan disposal at the point of purchase

The cheapest waste is the waste never produced. Ordering quantities the lab will actually use before the retest date, recording receipt dates, and rotating stock so the oldest is used first keeps the clear-out box small and the consignment notes few.

When the box does fill, the order of work is the one set out above: classify from the data sheets, separate and store, check the carrier, complete your parts of the note, and file the consignee return when it comes. None of it is complicated. All of it is expected to be on paper.