Process efficiency appropriate measures
These are the appropriate measures for process efficiency at regulated facilities with an environmental permit for treating or transferring healthcare waste.
1. For your facility, you must monitor and review the annual quantity of:
- water, energy and raw materials used
- residues and waste water produced
You must do this at least once every year.
1. You must create and implement an energy efficiency plan at your facility. This must:
- define and calculate the specific energy consumption of the activity (or activities) you carry out and waste stream(s) you treat
- set annual key performance indicators – for example, specific energy consumption (expressed in kWh/tonne of waste processed)
- plan periodic improvement targets and related actions
2. You must regularly review and update your energy efficiency plan as part of your facility’s management system.
3. You must have and maintain an energy balance record for your facility. This must provide a breakdown of your energy consumption and generation (including any energy or heat exported) by the type of source (electricity, gas, conventional liquid fuels, conventional solid fuels and waste). You should provide Sankey diagrams or energy balances to show how energy is used in your waste treatment processes.
4. You must regularly review and update your energy balance record as part of your facility’s management system, alongside the energy efficiency plan.
5. You must have operating, maintenance and housekeeping measures in place in relevant areas, for example, for:
- air conditioning, process refrigeration and cooling systems (leaks, seals, temperature control, evaporator or condenser maintenance)
- the operation of motors and drives
- compressed gas systems (leaks, procedures for use)
- steam distribution systems (leaks, traps, insulation)
- space heating and hot water systems
- lubrication to avoid high friction losses
- boiler operation and maintenance, for example, optimising excess air
- other maintenance relevant to the activities within the facility
6. You must have measures in place to avoid gross energy inefficiencies. These should include, for example:
- insulation
- containment methods (such as seals and self-closing doors)
- avoiding unnecessary discharge of heated water or air (for example, by fitting simple control systems such as timers and sensors)
7. For alternative treatment plant that thermally disinfect waste, we do not consider treating non-infectious waste appropriate unless you provide detailed justification. This should take into account the purpose and benefit of the treatment process and its energy consumption.
8. You should implement additional energy efficiency measures at the facility as appropriate, following our guidance.
1. You must maintain a list of the raw materials used at your facility and their properties. This includes auxiliary materials and other substances that could have an environmental impact.
2. You must regularly review the availability of alternative raw materials and use any suitable ones that are less hazardous or polluting. This should include, where possible, substituting raw materials with waste or waste-derived products.
3. You must justify the continued use of any substance for which there is a less hazardous alternative.
4. You must have quality assurance procedures in place to control the content of raw materials.
5. For facilities that treat waste using chemical disinfection, you must consider the following when you select and use raw materials:
- using the optimum amount of disinfectant that maintains effective treatment
- disinfectants that might have a lower environmental impact (for example hazardous properties, bioaccumulation, degradability, emissions)
- minimising or reducing the quantity of, or neutralising, the residual active disinfectant in the outputs from the treatment process
- the potential for components of the waste, for example organic matter, to inhibit or react with the chemical disinfectant
6. Processing waste that is not infectious with disinfectant is not consistent with minimising the use of raw materials. If you want to disinfect non-infectious waste you need to support your application to treat such waste. You must provide a detailed justification demonstrating that you meet the requirement to minimise raw material use.
1. You must take measures to make sure you optimise water consumption to:
- reduce the volume of waste water generated
- prevent or, where that is not practicable, reduce emissions to soil and water
2. Measures you must take include:
- implementing a water saving plan (involving establishing water efficiency objectives, flow diagrams and water mass balances)
- optimising the use of washing water (for example, dry cleaning instead of hosing down, using trigger control on all washing equipment)
- recirculating and reusing water streams within the plant or facility, if necessary after treatment
- reducing the use of water for vacuum generation (for example, using liquid ring pumps with high boiling point liquids), where relevant
3. You must carry out a regular review of water use (a water efficiency audit) at least every 4 years.
4. You must also:
- produce flow diagrams and water mass balances for your activities
- establish water efficiency objectives and identify constraints on reducing water use beyond a certain level (usually this will be site specific)
- identify the opportunities for maximising reuse and minimising use of water
- have a timetabled improvement plan for implementing additional water reduction measures
5. To reduce water use and associated emissions to water, you should apply these general principles in sequence:
- use water efficient techniques at source where possible
- reuse water within the process, by treating it first if necessary – if not practicable, use it in another part of the process or facility that has a lower water quality requirement
- if you cannot use uncontaminated roof and surface water in the process, you should keep it separate from other discharge streams – at least until after you have treated the contaminated streams in an effluent treatment system and have carried out final monitoring
6. You should establish the water quality requirements associated with each activity and identify whether you can substitute water from recycled sources. Where you can, include it in your improvement plan.
7. Where there is scope for reuse (possibly after some form of treatment) you should keep less contaminated water streams, such as cooling waters, separate from more contaminated streams.
8. You must minimise the volume of water you use for cleaning and washing down by:
- vacuuming, scraping or mopping in preference to hosing down
- reusing wash-water (or recycled water) where practicable
- using trigger controls on all hoses, hand lances and washing equipment
9. You must directly measure fresh water consumption and record it regularly at every significant usage point, ideally on a daily basis.
1. You must create and implement a residues management plan that:
- minimises the generation of residues arising from waste treatment
- optimises the reuse, regeneration, recycling or energy recovery of residues, including packaging
- ensures the proper disposal of residues where recovery is technically or economically impractical
2. Where you must dispose of waste, you must carry out a detailed assessment identifying the best environmental options for waste disposal.
3. You must review options for recovering and disposing of waste produced at the facility on a regular basis. You must do this as part of your management system to make sure you are still using the best environmental options and promoting the recovery of waste where technically and economically viable.
4. If you provide or advise producers on healthcare waste packaging, consider:
- reducing the quantity of packaging accompanying the waste, for example making sure that containers are being used efficiently
- using packaging that is either reusable or suitable for recycling