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What is a clinical waste pre-acceptance audit?

Paperwork · By Clinical Waste Disposal Company · Updated · 3 min read

The short answer

A pre-acceptance audit is a written survey of the clinical waste your practice produces, done in person, which the treatment site must have before it accepts your waste. Environment Agency guidance asks for one at least every 12 months for medical practices producing 5 tonnes or more a year, every 2 years for dental, veterinary and laboratory producers under 5 tonnes, and every 5 years for other healthcare producers.

On this page

At some point your contractor will ask for a pre-acceptance audit, sometimes with a warning that collections could stop without one. Here is what it is and how to deal with it.

What the audit is

Sites that treat clinical waste operate under environmental permits. The Environment Agency’s appropriate measures for healthcare waste require them to know exactly what they are receiving before they accept it. The pre-acceptance audit is how they find out.

It is a written report, based on a visit to your premises, describing every type of waste your practice produces, how it is classified and coded, what containers it goes in and how well it is segregated and stored.

How often you need one

Type of producer Minimum frequency
Medical practices producing 5 tonnes or more of clinical waste a year Every 12 months
Veterinary, dental and laboratory producers under 5 tonnes a year Every 2 years
Other healthcare waste producers Every 5 years

The treatment site must have a report before it accepts your first collection, then at those intervals. The BMA notes that most GP practices fall into the five-yearly group, but advises completing one whenever the contractor asks.

What the audit covers

The Environment Agency guidance lists what the report should include. In plain terms:

  • your practice details, the date and how the audit was done;
  • who carried it out and their competence;
  • every room, department or area and what waste each produces;
  • for each waste type, its classification and List of Waste code, container and colour, labelling, form, contents and hazards;
  • how waste is segregated and stored, including conversations with staff;
  • a comparison with HTM 07-01 and the Environment Agency’s technical guidance on waste classification;
  • your waste policy, staff training and quantities;
  • confirmation about radioactive waste, and safety data sheets where relevant.

For practices producing 5 tonnes or more, the first audit covers the whole site and later yearly audits can cover at least a third of the areas each time. Smaller practices are audited in full every time.

Who can do it

The audit must involve someone physically visiting the practice. It cannot be done wholly by phone or online. It can be carried out by:

  • an appropriately trained and experienced member of your own staff; or
  • an external auditor, often provided by your waste contractor.

Contractors often offer to do it. Some include it in the contract price and some charge separately, so ask before you sign.

How to prepare

Walk the practice first

List every room and what waste it produces. Check each has the right containers in the right colours.

Check your paperwork

Gather recent consignment and transfer notes, your waste policy and training records.

Look at what is in the bags

Auditors may check that orange bags hold only infectious waste with no medicines, and that ordinary waste is not going in clinical bags. Fix obvious mistakes before the visit.

What happens if you do not have one

The treatment site cannot lawfully accept waste without the information it needs. Your contractor may refuse to collect until an audit is in place, which leaves clinical waste building up at the practice. That is a much bigger problem than the audit itself.

Questions people ask

It is a condition the treatment site must meet under its permit and the Environment Agency’s appropriate measures. In practice that makes it a requirement for every producer.

Does a tattoo studio need one?

Yes. Any producer sending clinical waste for treatment needs one, normally on the five-yearly cycle for smaller non-medical producers.

Can we use the same audit if we change contractor?

Often yes, if it is still in date and accurate. Give the new contractor a copy and let them confirm it meets their treatment site’s needs.

Practice-specific notes are on our dental, veterinary and GP surgery pages. If you need a contractor that carries out the audit, use the form below.

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