What is offensive/hygiene waste?
Offensive/hygiene waste (previously known as ‘sanpro’ or human
hygiene waste) is not ‘clinical waste’, ‘hazardous’ or ‘special waste’ (in
Scotland) under environmental legislation and not dangerous goods
under transport legislation if it:
■ is considered non-infectious;
■ does not require specialist treatment or disposal.
See Schedule 1 of the Controlled Waste (England and Wales)
which describes offensive waste as waste that:
■ is not clinical waste;
■ contains body fluids, secretions or excretions, and falls within code
18 01 04, 18 02 03 or 20 01 99 in Schedule 1, List of Wastes Health and Safety
Managing offensive/hygiene waste safely Page 3 of 10
(England) Regulations 2005,4
in relation to England, or the List of
Wastes (Wales) Regulations 2005, in relation to Wales.5
Offensive/hygiene wastes are the product of a population which is not
known to be infectious. The waste can also be offensive in appearance
and smell. When handled, there is a residual health risk, which should be
assessed, and appropriate precautions should be implemented.
However, provided the waste is appropriately wrapped, properly handled
and free from excess liquid, the risk of ill health is considered to be low.
Offensive/hygiene waste includes:
■ human and animal waste (faeces);
■ incontinence pads;
■ catheter and stoma bags;
■ sanitary waste;
■ nasal secretions;
■ vomit and soiled human bedding from a non-infectious source;
■ medical/veterinary items of disposable equipment such as gowns etc;
■ plasters (minor first aid or self care) generated by personal use;
■ animal hygiene waste (eg animal bedding);
■ waste from non-healthcare activities, eg waste from body piercing or
application of tattoos (excluding sharps).
Municipal waste from domestic first aid and self care – of a type that
does not involve the need for a healthcare practitioner – is assumed to
be non-infectious unless a healthcare practitioner indicates otherwise.
This includes nappies and sanitary products.
Where waste management organisations have any doubt about the
classification of materials collected they should consult the waste
producers and, if necessary, refer to the Environment Agency, Natural
Resources Wales or Scottish Environment Protection Agency (SEPA) as
Guidance on the classification of healthcare waste can be found in
Hazardous waste: Interpretation of the definition and classification of
and Safe management of healthcare waste.
Managing the risks
Every year, thousands of workers have the potential to be ill following
exposure to harmful microorganisms or other hazardous substances.
Employers are responsible for taking effective measures to control
exposure and protect health. The main relevant legal requirements are
contained in the Control of Substances Hazardous to Health Regulations
These include assessing the risk from harmful
substances and preventing or controlling exposure to them.
This means employers should consider how employees (and others) may
be exposed to harmful substances or microorganisms and decide
whether they are doing enough to prevent this from happening.
Employers should always try to prevent exposure at source. If exposure
cannot be prevented, put suitable measures in place to control it
COSHH requires employers to take the following general steps to assess
and manage the risk of ill health by preventing or reducing workers’
exposure to hazardous substances:
■ find out what the health hazards are from harmful substances and
■ identify who might be harmed and how;
■ decide how to prevent or reduce that harm;
■ implement appropriate control measures;
■ make sure those control measures are used and kept in good order;
■ monitor and review the risk assessment regularly or if there is a
More information on assessing health risks in accordance with COSHH
can be found at www.hse.gov.uk/coshh/index.htm.
What hazards are associated with offensive/hygiene waste?
Offensive/hygiene waste has the potential to harm the health of those
exposed to it.
Typical effects can be:
■ skin/eye infections (eg conjunctivitis);
■ gastroenteritis (symptoms include stomach cramps, diarrhoea and
Further information on this can be found in Health and hazardous
substances in waste and recycling.
Who it is at risk?
People who may be exposed to offensive/hygiene wastes include:
■ collection workers/loaders;
■ pickers hand sorting on picking lines/conveyor belts in materials
recovery facilities (MRFs);
■ maintenance engineers/employees working on equipment in facilities
where waste is sorted;
■ health and social care workers;
■ waste transfer facility operators;
■ washroom waste collection service workers;
■ vulnerable members of the public (eg children or elderly people).
Communication and coordination
Good communication and coordination is essential between producers
and others in the waste management chain to ensure that offensive/
hygiene waste is handled and treated in a way that will ensure the health
and safety of workers. Producers, clients and contractors may all have
responsibilities to ensure the health and safety of their own employees
and others. This should include:
■ discussion with waste contractors or the relevant local authority to
identify the best way to manage this waste type on an individual site
■ operating separate/segregated collections for this waste type, and
adopting the same colour-coded system identified in Safe
management of healthcare waste to bag/box this waste.
Safe systems of work
There should be clear procedures for the identification, segregation,
storage collection, transport, handling and disposal of offensive/hygiene
waste. Further guidance on this is provided below.
Identification of the offensive/hygiene waste
It is important that the waste producers (eg healthcare professionals or
those operating commercial/industrial premises) are aware of the need
for proper identification and handling of this waste.
Offensive/hygiene waste should be identified and adequately contained
before it enters the waste management stream. Use of the colour-coded
segregation system outlined in Safe management of healthcare waste is
recommended. Note: Yellow bags with black stripes (‘tiger bags’) are
used for offensive/hygiene waste.
Where wastes are not adequately identified, waste management
organisations should contact the waste producers to clarify the type of
waste and to seek improvements in future. It may also be necessary to
contact the relevant environment agency if wastes remain unidentified.
Producers of offensive/hygiene wastes should make sure there is robust
segregation of materials. This will enable materials to be properly
labelled, stored, transported and treated.
Where waste management organisations find that wastes are not properly
segregated, producers should be notified and improvement sought.
Storage and opening bags
The following practices will help ensure the safe storage and opening of
■ Offensive/hygiene waste should be stored in designated areas before
treatment or disposal.
■ Avoid opening bags. Effective segregation at source will eliminate/
reduce the need to open bags.
■ Where bags have to be opened, mechanical aids or handled tools
can reduce the risk of injury and contact with potentially harmful
Procedures should be in place for handling and packaging sharps and
other contra-materials that have been incorrectly placed in the offensive/
hygiene waste stream. This will include providing dedicated/labelled
receptacles, tools and personal protective equipment. Further guidance
on this can be found in Health and hazardous substances in waste and
Collection/safe transport of offensive/hygiene waste
A safe system of work should include:
■ bag/receptacle collection procedures and clear roles and
responsibilities for all staff;
■ collections frequent enough to ensure the storage capacity of the site
is not exceeded;
■ effective recording of the receipt and transfer of waste materials (this
can help in the identification of poor segregation and labelling by
producers and clients);
■ handling of bags kept to a minimum and materials transferred,
transported or handled to prevent rupturing of bags. Bags should not
be manually compacted to increase capacity;
■ collectors/loaders only removing bags that are clearly marked/
■ arrangements for reporting spillages, inadequate or incorrect
packaging and labelling of excessively heavy consignments –
collectors/loaders need to know who to tell and how to contact them;
■ a safe system for avoiding spillages during transportation. Placing
bags within wheeled bins or other suitable rigid containers, or loading
them directly into leak-proof vehicles or containers, can reduce the
risk of spillage. Spillages/leakage of waste stored at the customer’s
site should be dealt with by site staff following their own
organisation’s clean-up procedures;
■ providing appropriate personal protective equipment;
■ what to do in an emergency, eg sharps found in offensive/hygiene
waste and injury sustained, as well as fire and first-aid procedures.
Bags should not be overfilled, eg be more than three-quarters full, and
should be tied at the neck. Contents should be double bagged if there is
a possibility of leakage.
■ handle offensive (and domestic) waste bags by the neck and should
not drop, drag or throw bags;
■ not accept or remove overfilled or leaking bags.
Handling aids such as wheeled bins can be used to reduce the risk of
manual handling injuries when there is frequent handling of bags.
Wheeled bins also have the benefit of containment and protection of the
bags. However some disposal sites (eg some energy from waste plants
and landfill sites) may not have facilities for accepting bins and your risk
assessment should identify how the bags should be handled safely.
Offensive/hygiene waste may be recycled, incinerated (including energy
from waste facilities) or landfilled in suitably permitted/licensed facilities.
This waste should not be compacted unless in accordance with the
conditions of an environmental permit or relevant waste exemption.
Where compaction is undertaken, a COSHH assessment should be
carried out to establish whether there is a risk of exposure to bioaerosols
and, if necessary, procedures put in place to contain, minimise, and
Liquid offensive/hygiene waste cannot be sent for disposal to landfill, but
should be disposed of through the normal sewage system.
Provide appropriate equipment such as litter-picking tongs, hand
brushes, shovels and rigid containers (for the removal of sharps and
other hazardous/infectious waste) to deal with spills, unexpected waste
etc. It may be necessary to implement procedures for cleaning and
disinfecting equipment (eg picking tongs).
The most common way that microorganisms and other harmful
substances enter the body is:
■ by eating, drinking or wiping the face with contaminated hands or
■ through cuts, scratches or penetrating wounds such as injuries from
■ through the surfaces of the eyes, nose and mouth;
■ by breathing them.
Good personal hygiene when handling offensive/hygiene waste is crucial
and will reduce the residual hazards that can lead to ill health. This is
likely to include:
■ a clearly defined personal hygiene regime for all employees. It is
essential that employees wash their hands before eating, drinking,
smoking or using the phone, taking medication, inserting contact
lenses or before and after wearing gloves, using the toilet or after
becoming contaminated with infected material;
■ providing adequate hand washing facilities including mild soap. Avoid
strong or abrasive cleansers that can cause irritant dermatitis;
■ provision and use of appropriate protective clothing, especially gloves
and safety boots. Select appropriate personal protective clothing for
the job and ensure that employees use it.
Employers should consider offering vaccinations against:
■ hepatitis A, where a risk assessment reveals exposure to, including
contamination with, human faecal matter is likely;
■ hepatitis B, where a risk assessment reveals direct contact with
contaminated body fluids is likely.Health and Safety
Managing offensive/hygiene waste safely Page 8 of 10
Ensure that all employees and managers understand the risks through
proper instruction, training and supervision. All staff should be aware of
the procedures to follow to minimise the risk of ill health and know what
to do if unexpected hazardous waste is encountered. They should be
able to recognise the different coloured containers and bags, know why
the different waste types should be kept separate and know that
offensive/hygiene waste should not be compacted on site (unless in
accordance with the conditions of an environmental permit or relevant
Awareness of the hazards and the need to exercise good personal
hygiene should regularly be emphasised to staff. Encourage employees
to keep vaccinations up to date (periodic reminders with pay notifications
etc can help).
■ report any cases of ill health to their manager or the organisation’s
occupational health department;
■ let their doctor know about their work activities when they visit them.
■ record and monitor cases of ill health with a view to identifying
patterns/trends of ill health in the workforce that may be work related.
Procedures for dealing with unexpected offensive/hygiene
There may be occasions when offensive/hygiene waste is found
unexpectedly, eg on picking lines at material recovery facilities (MRFs), in
energy from waste (EFW) plants and at landfill sites. This can expose
workers to a risk to their health from offensive/hygiene waste either by
direct or indirect contact. Procedures should be in place to reduce the
risk of ill health. These should include:
■ having a system in place to deal with spills, seepage or contaminants
if unexpected offensive/hygiene waste is identified. This could
▬ safely removing contaminants using appropriate equipment;
▬ wearing suitable protective gloves;
▬ disposing of them safely;
▬ recording the incident in accordance with company procedures;
■ tracing back to the waste producer (where possible) when
unacceptable quantities of offensive/hygiene waste are found, to
resolve waste classification and disposal issues.