Waste services can keep operating
Some aspects of the waste and recycling industry are essential services. Their facilities remain open.
Councils and the waste and recycling industry should continue to provide critical waste services to the public.
Keeping these facilities open will help to reduce the potential for illegal dumping of waste. Illegal dumping can cost millions of dollars to clean up.
The risk of coronavirus transmission when handling waste is low. Waste handlers should continue using routine hygiene procedures. For example, wearing gloves and washing hands regularly.
EPA position on authorisation of discharges or disposal (emergency/temporary relief) for clinical waste
The coronavirus (COVID-19) pandemic has seen a significant increase in clinical waste volumes from vaccination clinics and testing sites, aged care and other facilities. This places pressure on waste transport and treatment capacity in metropolitan Melbourne and regional areas.
Clinical waste presents significant hazards to the environment and human health, requiring specialised management and treatment.
The preferred approach for managing clinical waste is thermal destruction and/or sterilisation. In extraordinary circumstances, disposal to a Type 1 double composite lined landfill may be considered as an alternative approach where the risks presented by increased storage outweigh pre-treatment prior to disposal.
EPA recognises the pandemic has created operational challenges that need to be addressed practically to ensure human health and environmental risks from clinical waste are effectively managed.
EPA’s position
To reduce pressure on the clinical waste supply chain and ensure risks are managed, EPA will consider applications for an Authorised Disposal and Discharge (ADD) for temporary storage of clinical waste (waste code R100) at some facilities.
Any approval of an ADD application will be no longer than three months in duration to bring this peak service demand under control. This also aligns to the provision under the Environment Protection Act 2017 where an ADD application may not be granted for longer than 120 days.
Proposals for alternative disposal methods will be considered in extraordinary circumstances.
Purpose of authorised disposal and discharges
EPA may authorise discharge, emission, or deposit of waste from any place or premises into the environment, or the storage, treatment, handling, or disposal of waste on or from any place or premises if it will not have an adverse effect on the environment and the authorisation is for:
- meeting a temporary emergency; or
- providing for the temporary relief of a public nuisance or community hardship.
These authorisations:
- must be applied for
- require any prescribed fee to be paid
- can be valid for up to 120 days.
These authorisations enable EPA to minimise regulatory burden while minimising the effect on the environment.
Note that EPA can also grant ADDs for enabling the commissioning, repair, decommissioning or dismantling of any item of plant or equipment. This is not in scope for this position.
Approval process
EPA will only approve an ADD as a means for addressing current issues with increased clinical waste volumes due to the pandemic in the following circumstances:
The duty holder must demonstrate:
- the approval is required to address a temporary emergency or provide temporary relief in ensuring Victoria’s clinical waste is appropriately managed
- the approval is required to address the additional operational challenges faced due to Victoria’s increase in clinical waste
- an assessment of the increase in risk/s associated with proposed activity (for example, exceeding the current licence limit to accept additional clinical waste)
- consideration of additional controls to manage and mitigate risks to human health and the environment (for example, fit for purpose disposal or storage infrastructure)
- all relevant, commercially available options to address the issue have been explored. These may include:
- moving the waste to another one of their own licenced premises for clinical waste
- using or applying for a A12 permit for movement of clinical waste interstate out of Victoria
- moving the waste to another third party licenced premises for clinical waste.
EPA will not approve an ADD proposal where the situation was foreseeable, has been caused by carelessness, poor management, operator negligence or non-compliance with policies or guidelines or will provide a duty holder with an unfair market advantage.
If you are constructing or modifying a facility to accept clinical waste, you are required to follow the requirements of the permissioning scheme.
An ADD can be applied for online by submitting Form F1028 via the EPA Portal.
Compliance with ADDs
When issued, an ADD includes conditions the approval holder must follow to ensure the discharge or handling of waste is managed appropriately and does not result in any long-term impacts to the environment, whilst considering the needs of the community and requirements of other stakeholders.
If any of the conditions are not met, you may be liable for a pollution offence under the act. These conditions may include monitoring requirements, consultation with stakeholders, maintaining records and reporting. EPA authorised officers may inspect your site following and during the issue of an ADD to check compliance against these conditions.
Requirements to store clinical waste in preparation for pick-up
Wastes should be stored in a dedicated storage area to ensure there are no environmental impacts, including appropriate bunding to contain any potential spills. It is essential that clinical and related wastes are properly segregated, packaged, labelled, handled and transported to minimise risk to waste handlers and the community.
Wastes should be stored in a container that is:
- rigid
- water-tight
- and preferably with a closeable lid.
If the container does not have a lid, it should be stored in an appropriately bunded area that is undercover.
Place clinical waste directly into a rigid clinical waste bin or in a double-layered yellow plastic bag (double-bagging), and clearly label it as clinical waste.
Wastes should not be stored in plastic liners that have been placed directly on floors. To assist waste transporters and treaters with the increased demand for clinical wastes, please ensure clinical waste bins are full before requesting collection. EPA provides guidance on management of clinical wastes in Clinical and related waste – operational guidance (IWRG612.1).
Transporting clinical waste
Clinical waste is classified as a reportable priority waste (RPW) and can be dangerous to people and the environment.
You must control RPW to prevent harm, especially when you transport it for disposal or treatment.
The laws and regulations that set out your obligations when transporting PIW are:
If you don’t transport RPW the right way, you could get a fine or penalty.
The Permit to transport prescribed industrial waste (IWRG811) explains EPA’s vehicle permitting application process in relation to the transport of RPW in Victoria.
If you produce, transport or receive RPW, you must use Waste Tracker to complete transactions.
For information on how to prepare clinical waste for collection please refer to Clinical and related waste - operational guidance (IWRG 612).
Facilities authorised to accept clinical waste
Clinical wastes are a RPW under the EPA Regulations. They must be transported by a permitted vehicle, and disposed of at a premises authorised to receive it. You can call EPA on 300 372 842 and ask for information on local RPW treaters and transporters.
Requirements to temporarily store clinical waste
EPA may authorise emergency storage of waste at a premises for up to 120 days under Section 157 of the Environment Protection Act 2017. You may apply to EPA for an authorisation in accordance with F1028: Application for authorisation to discharge or dispose.
Premises are required to store waste in accordance with the Clinical and related waste – operational guidance (IWRG612.1). Temporary storage areas should be:
- Hygienically managed, adequately lit and have restricted access.
- Signposted with the biohazard symbol and other labelling appropriate to the types of waste stored in the area (e.g. clinical).
- Weather-proof (i.e. with walls and a roof) and with adequate containment measures (e.g. container bund and/or sump) to contain any spills. This should also prevent any waste entering stormwater or drainage systems.
- Where cold storage units are hired from contractors, it is recommended that contractors of cold storage units are advised on what substances have been stored within the units, how and if they have been adequately cleaned.
- All received waste on site is managed on a strict rotation basis (first in, first out), so waste received at the site first is first removed and wastes of different storage age are managed appropriately.
- Information on those that attend the site or handle the waste containers is kept on record.
Certain wastes require additional management controls. For example, R110 waste should be refrigerated below room temperature if it is unable to be treated or disposed of within 24hrs. For further information on waste codes please refer to the Waste Code Guidance (IWRG822.3).
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Reviewed 12 January 2022
