DENR - Proper Handling of Hazardous Waste

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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES


DEPARTMENT OF HEALTH


August 24, 2005

JOINT DENR-DOH
ADMINISTRATIVE ORDER
No. 02, series of 2005


SUBJECT : Policies and Guidelines on effective and proper
handling, collection, transport, treatment, storage
and disposal of health care wastes.

I. RATIONALE

The Department of Environment and Natural Resources (DENR) and the
Department of Health (DOH) hereby jointly provide the following guidelines on
the management of health care wastes pursuant to, among others, the
following laws, rules and regulations:

Clean Air Act of 1999 (Republic Act 8749);
Toxic Substances, Hazardous Waste, and Nuclear Waste
Control Act of 1990 (Republic Act 6969);
Ecological Solid Waste Management Act of 2000 [Republic
Act 9003)
Refuse Disposal of the Sanitation Code of the Philippines
[Chapter XVIII, Implementing Rules and Regulations,
Presidential Decree 856);
Clean Water Act of 2004 [Republic Act 9275];
Environmental Impact Statement (EIS) System
(Presidential Decree 1586);
Hospital Licensure Act [Republic Act 4226]


II. OBJECTIVES

A. To provide guidelines to generators, transporters and owners or
operators of treatment, storage, disposal (TSD) facilities of health
care waste on the proper handling, collection, transport, treatment,
storage and disposal thereof;

B. To clarify the jurisdiction, authority and responsibilities of the DENR
and DOH with regard to health care waste management; and

C. To harmonize efforts of the DENR and DOH on proper health care
waste management.


III. SCOPE AND COVERAGE

These policies and guidelines shall apply to health care waste generators,
transporters and owners or operators of TSD and final disposal facilities.


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IV. DEFINITION OF TERMS

A. Health Care Wastes - include all wastes generated as a result of the
following:

1. Diagnosis, treatment, management and immunization of humans
or animals;
2. Research pertaining to the above activities;
3. Producing or testing of biological products; and
4. Waste originating from minor or scattered sources (i.e. dental
clinics. alternative medicine clinics, etc.)

The categories of health care wastes are enumerated in Annex A.

B. Health Care Waste Generators - include health care facilities,
institutions, business establishments and other similar health care
services with activities or work processes that generate health care
waste.

1. Hospitals (Primary Care, Secondary Care and Tertiary Care)
2. Infirmaries
3. Birthing homes
4. Clinics

[a] Medical [e] Surgical
[b] Ambulatory [f] Alternative medicine
[c] Dialysis [g] Dental
[d] Health care centers and
dispensaries
[h] Veterinary

5. Laboratories and Research Centers

[a] Medical and biomedical
laboratories
[e] Nuclear medicine
laboratories
[b] Medical research centers [f] Biotechnology laboratories
[c] Blood banks and blood
collection services
[g] Animal research and
testing
[d] Dental prosthetic
laboratories
[h] Drug testing laboratories
[i] HIV testing laboratories

6. Drug Manufacturers
7. Institutions

[a] Drug rehabilitation
center
[d] Schools of Radiologic
Technology
[b] Training centers for
embalmers
[e] Medical Schools
[c] Med-tech intern training
centers
[f] Nursing Homes
[g] Dental Schools

8. Mortuary and Autopsy Centers



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C. Health Care Waste Transporter - a person licensed by the DENR
Environmental Management Bureau to convey health care waste through
air, water or land.

D. Treatment, Storage and Disposal (TSD) Facilities - facilities where
hazardous wastes are stored, treated, recycled, reprocessed and/or
disposed of, as prescribed under DENR AO No. 2004-36, Chapter 6-2
(Categories of TSD Facilities).


V. RESPONSIBILITIES OF IMPLEMENTING & COOPERATING AGENCIES

This Joint Administrative Order shall be implemented by the DENR
through the Environmental Management Bureau (EMB) and its Regional
Offices, the National Solid Waste Management Commission (NSWMC), and by
the DOH through its Centers for Health Development (CHD), Bureau of Health
Facilities and Services (BHFS), Bureau of Health Devices and Technology
(BHDT), Environmental and Occupational Health Office (EOHO) of the National
Center for Disease Prevention and Control (NCDPC), the National Center for
Health Facility Development (NCHFD), and the National Reference Laboratory
(NRL)-East Avenue Medical Center, Quezon City.

A. The DENR-EMB shall:

1. Be the primary government agency responsible for implementing
pertinent rules and regulations on the management of health care
waste in the Philippines, particularly concerning the issuance of
necessary permits and clearances for the Transport, Treatment,
Storage, and Disposal of such wastes, as governed by RA 6969, RA
8749, RA 9275, RA 9003 and PD 1586;

2. Formulate policies, standards, and guidelines on the transport,
treatment, storage, and disposal of health care wastes.

3. Oversee compliance by generators, transporters, TSD facility
operators, and/or final disposal facility operators with the proper
transport, treatment, storage, and disposal of health care wastes;

4. Conduct regular sampling and monitoring of wastewater in health
care and TSD facilities to determine compliance with the provisions
of RA 9275;

5. Require TSD facility operators and on-site treaters to present to the
DENR copies of the results of microbiological tests on the health
care waste treated using autoclave, microwave, hydroclave and
other disinfection facilities prior to the renewal of their Permits
under RA 6969;

6. Provide technical assistance and support to the advocacy programs
on health care waste management; and

7. Notify DOH on cases of non-compliance or notice of violation
issued to health care facilities, institutions and establishments
licensed by the DOH.


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B. The DOH shall:

1. Regulate all hospitals and other health facilities through licensure
and accreditation under the Hospital Licensure Act (Republic Act
No. 4226);

2. Formulate policies, standards, guidelines, systems and procedures
on the management of health care waste;

3. Develop training programs and corresponding modules on health
care waste management;

4. Provide technical assistance in the preparation of health care
waste management plan as a requirement for licensing or the
renewal thereof;

5. Provide technical assistance to ensure an effective and efficient
implementation of health care waste management program;

6. Require all health care waste TSD facility operators and health
care waste generators with on-site waste treatment facilities to use
DOH-BHDT registered equipment or devices used for the treatment
of health care wastes;

7. Conduct regular performance evaluation of equipment/devices
used for the treatment of health care wastes by the DOH-BHDT;

8. Monitor the microbiological test of treated wastes to ensure
compliance with DOH standards;

9. Evaluate DOH hospitals compliance with proper health care waste
management program;

10. Issue Department Circulars to ensure that all environmental
requirements are complied with; and

11. Notify DENR on actions taken on cases of non-compliance or
notice of violation issued to health care facilities, institutions, and
business establishments.

C. The DOH-Centers for Health Development shall:

1. Advocate health care waste management [HCWM] practices to the
Local Chief Executives, key leaders and other stakeholders;

2. Monitor health care waste management practices in all hospitals
and other health care facilities;

3. Provide technical assistance on health care waste management
[HCWM) through:

a. Training
b. Advisory on the preparation of HCWM plans as a requirement for
licensing or the renewal thereof
c. Dissemination of policies, guidelines and information


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d. Monitoring and validation of the implementation of HCWM
e. Develop, reproduce, and disseminate HCWM IEC materials
f. Participation in any public hearings related to HCWM
4. Ensure compliance by health care waste generators with all pertinent
laws, rules and regulations on HCWM.


VI. GUIDELINES AND PROCEDURES

A. ENVIRONMENTAL COMPLIANCE REQUIREMENTS

A.1 Documentary Requirements

A.1.1 Health Care Waste Generators

Health care waste generators are required, based on existing
laws, rules and regulations, to register and secure the following permits:

A.1.1.1 From the DENR-Environmental Management Bureau

1. Environmental Compliance Certificate (ECC) - for the
establishment of hospitals, health care facilities covered
by the provisions of PD 1586 from the EMB Central Office
or its Regional Offices.

2. Permit to Operate (P/O) for Air Pollution Source and
Control Installation from the EMB Regional Office.

3. Discharge Permit will be issued by the EMB Regional
Office and the Laguna Lake Development Authority
(LLDA) based on RA 9275 or the Clean Water Act of 2004
(See Annex B LLDA Jurisdiction)

4. Hazardous Waste Generators Registration in
compliance with the implementing rules and regulations
of RA 6969 (DAO 29 series of 1992 and DAO 36 series of
2004) from the EMB Regional Office.

A.1.1.2 From the DOH-Bureau of Health Facilities and
Services:

1. Licenses for hospitals, laboratories, dialysis clinics,
birthing homes, infirmaries, psychiatric hospitals, dental
prosthetic laboratories, blood banks, ambulatory clinics,
and drug treatment and rehabilitation centers.

2. Certificate of Accreditation for Overseas Filipino
Workers (OFW) medical clinics, surgical clinics, drug
testing laboratories, HIV testing laboratories, water
testing laboratories, medical technologist intern training
centers and training centers for embalmers.







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A.1.2 Health Care Waste Transporters

Health care waste transporters are required, based on existing
laws, rules, and regulations, to undertake the following:

1. Register with EMB Central Office as healthcare waste
transporter;

2. Secure Transport Permit from the DENR-EMB Regional
Office;

3. Comply with the DENR Manifest System; and

4. Comply with other requirements specified in the Implementing
Rules and Regulations of RA 6969.

A.1.3 TSD Facilities

Owners or Operators of TSD facilities are required based on
existing rules and regulations to secure the following permits and
clearances from DENR-EMB and DOH:

1. Environmental Compliance Certificate (ECC) for the
Sanitary Landfill (SLF) and TSD Facility from the EMB Central
Office or Regional Office

2. Notice to Proceed for controlled dump facility to be used as
repository of health care waste from the EMB Regional Office

3. Registration as TSD facility based on the Implementing Rules
and Regulations of RA 6969 from EMB Central Office

4. Technology Approval for non-burn technologies from the
EMB Central Office prior to the issuance of Permit to Operate.

5. Permit to Operate (P/O) Air Pollution Source and Control
Installation from EMB Regional Office

6. Discharge Permit from the EMB Regional Office or LLDA

7. Certificate of Product Registration for equipment or devices
used for treating health care wastes from the DOH- BHDT

8. Certificate of Technical Evaluation for equipment or devices
used for treating health care wastes from the NRL-EAMC


B. PROCEDURES FOR SECURING PERMITS AND LICENSES

Permits and licenses shall be secured following the established
procedures of the DENR and DOH.






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C. SPECIFIC CRITERIA, STANDARDS, AND GUIDELINES


C.1 Handling, Collection, Storage and Transport

Handling, collection, storage and transport of health care wastes
shall be in accordance with the provisions of RA 8749, RA 6969, and RA
9003, and the DOH Health Care Waste Management Manual (Chapter 5).

C.2 Treatment

1. Facilities shall consider technologies and processes used in
health care waste treatment such as (1) thermal, (2) chemical,
(3) irradiation, (4) biological processes, (5) encapsulation, and
(6) inertization, as outlined in the DOH Health Care Waste
Management Manual and subject to compliance with the
provisions of RA 8749, RA 6969, and RA 9003.

2. Autoclave, microwave and hydroclave facilities shall use
microbiological test to determine the treatment efficiency of the
units. The results of the microbiological test shall be recorded
and reported to DENR under RA 6969 and RA 9003.

3. Health care waste generators and TSD facilities shall observe a
level of microbial inactivation of 6log
10
reduction or greater than
the most resistant microorganism of concern in a given process.

4. Treated wastes and inert residues from TSD facilities must be
disposed in controlled disposal or sanitary landfill facilities duly
licensed by the DENR to handle the same.

5. Inertization is a suitable treatment for pharmaceutical wastes
while encapsulation and other immobilization techniques are
treatment methods considered for sharps, chemicals and
pharmaceutical wastes and should therefore be placed in final
disposal facilities indicated under the subsequent Section.

C.3 Final Waste Disposal Systems and Facilities

The use of the proceeding disposal facilities should only be limited
to health care wastes which have undergone the necessary treatment
provided under the prescribed standards stipulated in the DOH Health
Care Waste Management Manual.

C.3.1 Controlled Dump Facility

1. A Controlled Dump Facility (CDF) is an interim
1
disposal facility
for municipal solid waste or those that are considered as non-
hazardous and non-toxic substances. In the absence of a
sanitary landfill, a controlled dumpsite could accept health care
waste after the indicative treatment thereof.

1
As stipulated in Section 37 of RA 9003, no open dumps shall be established and operated, nor
any practice or disposal of solid waste by any person, including LGUs, which constitutes the use
of open dumps for solid waste, be allowed after the effectivity of this Act (February 16, 2001):
Provided, that within three (3) years after the effectivity of this Act (February 16, 2004), every
LGU shall convert its open dumps into controlled dumps, in accordance with the guidelines set in


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2. In addition to the operational guidelines stipulated under
Section 2 of Rule XIII of the Implementing Rules and
Regulations of RA 9003 or as indicated in the conditions
stipulated in the issuance of the NTP, a CDF that is
commissioned to accept treated health care waste should also
be operated in accordance with the following specific
requirements:

a. Identify a particular cell within the facility to serve as a site
for the disposal of treated health care waste. The capacity of
the allotted cell/cell(s) should be measured in order to
determine the actual volume of wastes that can be
accommodated in the facility.

b. Adequate signage should be placed in the health care waste
deposition area.

c. The cell should be lined with a material of low permeability,
such as clay or a geo-membrane such as a high-density
polyethylene (HDPE) plastic liner to contain the leachate and
prevent contamination of groundwater sources within the
area.

d. Ensure that adequate soil cover is placed on the cells right
after each waste spreading.

e. Basic record keeping of the incoming wastes indicating the
time of receipt, volume or weight, source identification (i.e.
name of generator or source), certification of treatment (or
any similar form indicating that the waste have undergone
the necessary treatment) and the general condition of the
waste to be disposed.


C.3.2 Sanitary Landfill Facility

1. A Sanitary Landfill Facility [SLF] is a disposal site designed,
constructed, operated and maintained in a manner that exerts
engineering control over significant potential environmental
impacts arising from the development and operation thereof.

2. The required dedicated cells for treated health care wastes
should be built or developed prior to its operation to prevent the
mixing thereof with municipal solid wastes and other wastes.

3. Aside from the ECC, which is required for such facility, the
construction and development of an SLF must conform to RA
9003 and its Implementing Rules and Regulations, particularly
Sections 1 and 2, Rule XIV.


Section 41 of the Act: Provided, further, that no controlled dumps shall be allowed five (5) years
following effectivity of the Act (February 16, 2006).



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4. Existing sanitary landfill with approved ECC for the disposal of
municipal solid waste must secure an amendment of their ECC
before accepting health care waste for disposal thereat.


C.3.3 Safe Burial on Healthcare Facility Premises

1. Safe burial within the premises of healthcare facilities shall be
allowed in remote locations and rural areas where no TSD facilities
are available. In such activity of safe burial, the health care facility
must ensure that the load or capacity of the on-site burial pit is
not exceeded.

2. Chemical treatment or disinfection is required prior to safe burial
on hospital premises.

3. The standards for safe burial within the healthcare facility
premises shall follow the guidelines specified in the DOH Health
Care Waste Management Manual (See Annex C).

4. Relative to the guidelines provided by DOH, the operation of safe
burial should be in accordance with the minimum requirements
for landfill.


C.3.4 Sharps and Syringes Disposal Through Concrete Vault

1. Disposal using concrete vault shall be allowed only as an
alternative means of disposal of used sharps and syringes.

2. Concrete vault shall be marked with proper signage: CAUTION:
HAZARDOUS WASTE OR SHARPS DISPOSAL AREA-
UNAUTHORIZED PERSONS KEEP OUT.

3. Concrete vault should be watertight and must be constructed at
least 1.5 meters above the groundwater level.

4. The procedures for the safe burial of sharps and syringes through
concrete vault shall follow the guidelines in the DOH Health Care
Waste Management Manual (See Annex D).


C.4 Wastewater Treatment Facility

Healthcare facilities shall have their own Wastewater Treatment
Facilities (WTF) or maybe connected into a sewage treatment plant.
However, facilities with laboratories shall be required to pre-treat their
wastewater prior to discharge into a sewage treatment plant.


VII. REPEALING CLAUSE

All other issuances whose provisions of DENR and DOH Administrative
Order, Memorandum Circulars or other issuances inconsistent herewith are
hereby repealed or modified accordingly.



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VIII. PENALTY CLAUSE

Failure to comply with the policies/guidelines shall be subject to the
penalty provision(s) of the applicable laws stated herein.


IX. EFFECTIVITY

This Order shall take effect immediately.





MICHAEL T. DEFENSOR FRANCISCO T. DUQUE III, MD, MSc
Secretary Secretary
Department of Environment and Department of Health
Natural Resources







Published: Manila Standard Today
September 1, 2005






























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ANNEX A - Categories of Health Care Waste


1. General Waste - Comparable to domestic waste, this type of waste does not
pose special handling problem or hazard to human health or to the
environment. It comes mostly from the administrative and housekeeping
functions of health care establishments and may also include waste
generated during maintenance of health care premises. General waste
should be dealt with by the municipal waste disposal system.

2. Infectious Waste This type of waste is suspected to contain pathogens
(bacteria, viruses, parasites, or fungi) in sufficient concentration or quantity
to cause disease in susceptible hosts. This includes:

2.1 Cultures and stocks of infectious agents from laboratory work;
2.2 Waste from surgery and autopsies on patients with infectious diseases
(e.g. tissues, materials or equipment that have been in contact with
blood or other body fluids);
2.3 Waste from infected patients in isolation wards (e.g. excreta, dressings
from infected or surgical wounds, clothes heavily soiled with human
blood or other body fluids);
2.4 Waste that has been in contact with infected patients undergoing
hemodialysis (e.g. dialysis equipment such as tubing and filters,
disposable towels, gowns, aprons, gloves, and laboratory coats);
2.5 Infected animals from laboratories; and
2.6 Any other instruments or materials that have been in contact with
infected persons or animals.

3. Pathological Waste - Pathological waste consists of tissues, organs, body
parts, human fetus and animal carcasses, blood and body fluids. Within
this category, recognizable human or animal body parts are also called
anatomical waste. This category should be considered as a subcategory of
infectious waste, even though it may also include healthy body parts.

4. Sharps - Include needles, syringes, scalpels, saws, blades, broken glass,
infusion sets, knives, nails and any other items that can cause a cut or
puncture wounds. Whether or not they are infected, such items are usually
considered as highly hazardous health care waste.

5. Pharmaceutical waste - Includes expired, unused, spilt, and contaminated
pharmaceutical products, drugs, vaccines, and sera that are no longer
required and need to be disposed of appropriately. This category also
includes discarded items used in handling of pharmaceuticals such as
bottles or boxes with residues, gloves, masks, connecting tubing and drug
vials.

6. Genotoxic Waste - Genotoxic waste may include certain cytostatic drugs,
vomit, urine, or feces from patients treated with cytostatic drugs, chemicals,
and radioactive materials. This type of waste is highly hazardous and may
have mutagenic, teratogenic, or carcinogenic properties.

6.1 Harmful cytostatic drugs can be categorized as follows:


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6.1.1 Alkylating agents: cause alkylation of DNA nucleotides, which
leads to cross-linking and miscoding of the genetic stock;
6.1.2 Anti-metabolites: inhibit the biosynthesis of nucleic acids in the
cell; mitotic inhibitors: prevent cell replication

6.2 Cytotoxic wastes are generated from several sources and include the
following:

6.2.1 Contaminated materials from drug preparation and
administration, such as syringes, needles, gauges, vials,
packaging; outdated drugs, excess (left over) solutions, and drugs
returned from the wards;

6.2.2 Urine, feces, and vomit from patients which may contain
potentially hazardous amounts of the administered cytotoxic
drugs or of their metabolites and which should be considered
genotoxic for at least 48 hours and sometimes up to 1 week after
drug administration.

7. Chemical Waste - Chemical waste consists of discarded solid, liquid, and
gaseous chemicals, for example from diagnostic and experimental work and
from cleaning, housekeeping, and disinfecting procedures. Chemical waste
from health care may be hazardous or non-hazardous.

7.1 Chemical waste is considered hazardous if it has at least one of the
following properties:

7.1.1 Toxic
7.1.2 Corrosive (e.g. acids of pH <2 and bases of pH >12)
7.1.3 Flammable
7.1.4 Reactive (explosive, water-reactive, shock-sensitive)
7.1.5 Genotoxic (e.g. cytostatic drugs)

7.2 Non-hazardous chemical waste consists of chemicals with none of the
above properties, such as sugars, amino acids, and certain organic and
inorganic salts.

8. Waste with high content of heavy metals - Wastes with a high heavy-
metal content represent a subcategory of hazardous chemical waste, and
are usually highly toxic. Mercury wastes are typically generated by spillage
from broken clinical equipment (thermometers, blood pressure gauges, etc.).
Whenever possible, spilled drops of mercury should be recovered. Residues
from dentistry have high mercury content. Cadmium waste comes mainly
from discarded batteries. Certain "reinforced wood panels" containing lead is
still being used in radiation proofing of X-ray and diagnostic departments. A
number of drugs contain arsenic but these are treated here as
pharmaceutical waste.

9. Pressurized Containers - Many types of gas are used in health care and are
often stored in pressurized cylinders, cartridges, and aerosol cans. Many of
these, once empty or of no further use (although they may still contain
residues), are reusable, but certain types notably aerosol cans, must be
disposed of. Whether inert or potentially harmful; gases in pressurized
containers should always be handled with care; containers may explode if
incinerated or accidentally punctured.


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10. Radioactive Waste Includes disused sealed radiation sources, liquid
and gaseous materials contaminated with radioactivity, excreta of patients
who underwent radio-nuclide diagnostic and therapeutic applications,
paper cups, straws, needles and syringes, test tubes, and tap water
washings of such paraphernalia. It is produced as a result of procedures
such as in vitro analysis of body tissues and fluids, in vivo organ imaging,
tumor localization and treatment, and various clinical studies involving
the use of radioisotopes. Radioactive health care wastes generally contain
radionucleides with short half-lives, which lose their activity in a shorter
time. However, certain radionucleides e.g. C-14 contaminated wastes have
much longer half-life, more than a thousand years, which need to be
specially managed in a centralized treatment facility for radioactive wastes.
The same is required for the management of disused sealed radiation
sources used for cancer treatment.



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ANNEX B - Laguna Lake Development Authority Jurisdiction


The Laguna Lake jurisdiction is limited to the water shed of the Laguna
Lake which is consist of the following: Rizal Provinces (13 towns); Laguna
Provinces (27 towns); chartered cities of San Pablo, Antipolo, Tagaytay,
Tanauan, Calamba, Sta. Rosa; Sto. Tomas and Malvar, Batangas; Silang,
Carmona and GMA, Cavite; Lucban, Quezon; Taguig and Pateros, Metro
Manila; chartered cities of Pasay, Caloocan, Quezon, Manila, Muntinlupa,
Marikina and Pasig.















































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ANNEX C - Guidelines for Safe Burial within Hospital Premises


Safe burial within the hospital premises shall be in accordance with the
guidelines specified in the DOH Health Care Waste Management Manual as
follows:

1. Access to the disposal site should be restricted to authorized
personnel only.

2. The burial site should be lined with a material of low permeability,
such as clay or a geo-membrane such as a high-density polyethylene
(HDPE) plastic liner at the bottom of the pit to prevent contaminating
groundwater and avoid pollution.

3. Only hazardous health care waste should be buried. If general health
care waste were also buried on the premises, available space would be
quickly filled-up.

4. Large quantities (>1kg) of chemical/pharmaceutical wastes should not
be buried.

5. The burial site should be managed as a landfill, with each layer of
waste covered with a layer of earth to prevent odor, as well as to
prevent proliferation of rodents and insects.

6. Burial site should not be located in flood prone areas.

7. Hospital ground should be secured. (e.g. fenced with warning signs).

8. The location of waste burial pit should be downhill or down-gradient
from any nearby wells and about 50 meters away from any water body
such as rivers or lakes to prevent contaminating sources of water.

9. Health care facilities should keep a permanent record of the size and
location of all their on-site burial pits to prevent construction workers,
builders, and others from digging in those areas in the future.

10. The safe burial of waste depends critically on rational operational
practices. The bottom of the pit should be at least 1.50 meters higher
than the ground water level.

11. It should be noted that safe on-site burial is practicable only for
relatively limited period, say 1 to 2 years, and for relatively small
quantities of waste, say up to 5 to 10 tons in total. Where these
conditions are exceeded, a longer-term solution will be needed.










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ANNEX D - Procedures for the Safe Burial of Sharps and Syringes
through Concrete Vault


The procedures for the safe burial of sharps and syringes through
concrete vault shall be in accordance with the guidelines in the DOH Health
Care Waste Management Manual as follows:

1. Dig a pit (minimum size of 1 m x 1 m x 1.8 m depth), enough to
accommodate sharps and syringes for an estimated period of time
without reaching the groundwater level. The site must be isolated and at
least 152 meters away from the groundwater supply sources and
dwelling units.

2. Construct concrete walls and slabs of the pit. Provide slab with opening
or manhole for easy deposition of collected sharps and syringes. The
manhole should be extended a few centimeters above the soil surface to
overcome infiltration of surface water.

3. Deposit the collected safety boxes filled with used sharps and needles
inside the concrete vault.

4. Install a security fence around the site.

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