Sharps and Hazardous Waste in Vet Practices

The sharps regulation whose scope is an open question

Search for veterinary sharps guidance and you will find the Health and Safety (Sharp Instruments in Healthcare) Regulations 2013 cited fairly freely. It is worth reading what they actually say about who they cover, because the answer is less obvious than the citations suggest.

Regulation 3 applies them to "a healthcare employer" and to "a healthcare contractor whose employees... are exposed to a risk of injury from medical sharps in relation to the provision of services to a healthcare employer."

Regulation 2 then defines a healthcare employer as "an employer whose main activity is the management, organisation and provision of healthcare", and a medical sharp as "an object or instrument necessary for the exercise of specific healthcare activities, which is able to cut, prick or cause injury".

Neither definition mentions veterinary practice — and "healthcare" is not itself defined anywhere in the Regulations, so the instrument is silent on animal health rather than clearly including or clearly excluding it. The context points the same way without settling it: the Explanatory Note describes the Regulations as "implementing Council Directive 2010/32/EU... implementing the Framework Agreement on prevention from sharp injuries in the hospital and healthcare sector concluded by HOSPEEM and EPSU", and HSE's own information sheet on them, HSIS7, opens "this information sheet is for healthcare employers and employees" and works through an annex of borderline cases — contractors, care homes, pharmacies, prison medical staff — without mentioning veterinary work either way.

So the honest position is that the point is unresolved, and we have not found HSE guidance or a decided case that settles it. Do not assume these Regulations bind your practice; equally, do not assume they do not. If your arrangements would look different depending on the answer, take advice rather than picking the reading that suits you.

In practice this changes very little about what you have to do. The instruments that unambiguously do apply to a veterinary practice are demanding enough on their own, and a practice that meets them is doing most of what the Sharps Regulations would require anyway. The open question is which citation your arrangements answer to, not whether you need them.

What definitely does apply

A needle that has been in an animal presents a risk of injury and of infection to the person holding it. That puts it squarely inside COSHH regulation 7, which states: "Every employer shall ensure that the exposure of his employees to substances hazardous to health is either prevented or, where this is not reasonably practicable, adequately controlled."

Regulation 7(2) sets the hierarchy, and it is the part practices skip straight past: "substitution shall by preference be undertaken, whereby the employer shall avoid, so far as is reasonably practicable, the use of a substance hazardous to health at the workplace by replacing it with a substance or process which, under the conditions of its use, either eliminates or reduces the risk".

Applied to sharps, that hierarchy means the first question is not "which bin?" It is whether the sharp needs to exist at that moment at all — safer-engineered devices, needleless systems where clinically appropriate, not resheathing. Only after that does containment become the answer.

COSHH regulation 7 carries an E+W+S extent marker. Northern Ireland runs equivalent duties under its own COSHH Regulations; the substance of the duty is the same but the citation differs.

Beyond COSHH, the general duties in the Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999 apply to a veterinary practice exactly as they do to any employer, and your risk assessments should already carry sharps as a named hazard.

Segregation: the decision is made at the bin

Every waste failure in a veterinary practice happens at the moment of disposal, by whoever is holding the item, usually in a hurry. Policy written in an office does not travel to that moment unless the bins themselves make the right choice obvious.

Three things make segregation work:

Fewer streams, clearly labelled. A practice with nine bin types and a laminated decision tree has more misclassification than one with four and clear labels. Reduce before you explain.

Point-of-use placement. A sharps container that is on the other side of the room is the reason needles end up in the wrong bin. It goes where the procedure happens.

A named answer for "I don't know." Every practice has items nobody is sure about. Without a designated person to ask and a holding place to put things, the default answer becomes the nearest bin. Write that route into the SOP.

The chemical streams practices forget

Sharps get attention because injuries are visible. Chemical waste rarely does, and it is where the hazardous waste paperwork usually goes wrong.

Formalin and formaldehyde solutions. Formaldehyde is a substance hazardous to health, so the COSHH duty above applies to storage, decanting and spill response as much as to disposal. Do not assume a drain route is available — discharge to sewer is a separate permission from your water company and is not implied by anything else. Confirm the route with your waste contractor and record what they told you.

Cytotoxic and cytostatic medicines waste. Chemotherapy agents used in oncology cases, and their contaminated consumables, run in a distinct stream. If your practice has started offering treatments it did not offer two years ago, check the waste arrangements were updated at the same time — they frequently were not.

Out-of-date and returned medicines. These are not general waste and they are not automatically clinical waste either. Denaturing and disposal of controlled drugs has its own route, covered in our guide to controlled drugs compliance.

X-ray fixer and developer, where wet processing is still in use.

Each of these is likely to be hazardous waste, which means the consignment note and three-year register duties apply to it — a point that catches practices out, because the volumes are small and small volumes feel informal.

What to check this quarter

1. Walk the practice and count bin types. If a nurse cannot state the rule for each one without looking it up, there are too many
2. Check every sharps container is at point of use, not at a central station
3. Confirm your COSHH assessments cover formalin storage, decanting and spill response — not just the substance's existence
4. Ask your contractor which of your chemical streams are classified hazardous, and file the answer in writing
5. Confirm cytotoxic arrangements match the treatments the practice currently offers, not the ones it offered when the contract was signed
6. Record sharps and segregation training in your training records — this is the control the HSE will ask about after an incident

If someone is injured

A sharps injury is an incident, not an inconvenience. It needs immediate first aid and clinical advice, an entry in the accident book, an assessment of whether it is RIDDOR-reportable, and — this is the part that gets skipped — a review of whether the control that failed can be changed.

An injury that produces first aid and no control change will happen again. HSE's sharps injury guidance is written for the health sector but the prevention hierarchy in it transfers directly.

---

VetComply is being built to keep COSHH assessments, waste arrangements, SOPs and training evidence in one place, with review dates tracked rather than remembered. Join the waitlist for early access.

---

This is general guidance based on the published Regulations as they stood at the review date above. The HSE is the authority on health and safety duties in your practice, and your environmental regulator on waste classification — check with them where the treatment of a particular substance or waste stream is unclear.

Sources:

• COSHH Regulations 2002, reg 7 — prevention or control of exposure — legislation.gov.uk
• Health and Safety (Sharp Instruments in Healthcare) Regulations 2013, reg 2 — interpretation — legislation.gov.uk
• Health and Safety (Sharp Instruments in Healthcare) Regulations 2013, reg 3 — application — legislation.gov.uk
• HSIS7 — Health and Safety (Sharp Instruments in Healthcare) Regulations 2013: guidance for employers and employees — HSE
• Sharps injuries — HSE