Brilliant Bins - The Sanitary Bin Guide for Schools in England Edition 7

Brilliant Bins is a trading name of Seiquelle Innovation Ltd, 103 High Street, Hungerford, Berkshire RG16 0NB www.BrilliantBins.co.uk [email protected] Tel: 01488 684850 Edition 7 Feb 2013 © Seiquelle Innovation Ltd 2013

Brilliant Bins

The Sanitary Bin Guide for

Maintained and Independent

Schools in England � Sanitary bin regulations

� Brilliant Bins disposable sanitary bins

Answering the big questions….

There is a lot of confusion about the controls and regulations that apply to sanitary bins.

This guide contains the answers to the questions that we get asked. Some of the

information may surprise you, but this guide will provide you with in depth understanding of

the regulations concerning disposal of sanitary waste. For example, most web information

would like you to believe that sanitary waste is clinical waste, but this is rarely the case.

This guide deals with regulations covering England. Additional guides for Wales, Scotland

and Northern Ireland are being prepared, but please contact us if you would like to discuss

the situation in the devolved regions. The result is pretty similar, but from different sources.

If you would like further information or a no-obligation discussion about

your own disposal arrangements, please do contact me.

• Is it a legal requirement to provide sanitary waste bins?

• Sanitary Bin provision for pupil’s toilets at schools – what is ideal?

• Schools – what regulations cover disposal of feminine hygiene

waste from schools?

• Is feminine hygiene waste classed as clinical or hazardous waste?

• So I can put up to 7kg of sanitary waste in one collection?

• How easy is it for the cleaning staff to exchange the bins?

• I have been told our sanitary bin waste is controlled or offensive waste and

must be collected by a “specialist” service. Is this correct?

• Is Brilliant Bins registered with the Environment Agency?

• How can I check the registration of my waste collector?

• How environmentally friendly is a disposable bin?

• I’m concerned about odour. Why don’t you have chemical fragrance powder in the bin?

• What is Cellogreen eco-print laminate?

• I’d like to provide bags for items to go into before going in the bin. Do you sell these?

• Do you provide guidance on Duty of Care - Waste Transfer Notes?


Is it a legal requirement to provide sanitary waste bins?

There is no specific reference to sanitary bins, either for staff or pupils in current school

premises legislation for England, but the following sections clarify requirements for toilet

facilities.

It is worth reading the question asked by Baroness Tonge in Parliament on 20th June 2012

about provision of sanitary bins in schools to which the reply was “There is no evidence that

it is necessary to regulate on this issue. Schools are expected to take a common-sense

approach to such provision” click here to see this in full.

Schools maintained by Local Authorities

The School Premises (England) Regulations 2012, which came into force on the 31st

October 2012, are the first reference point. However these are extracts of relevance:

• ..suitable toilet and washing facilities must be provide for the sole use of

pupils.

• Separate toilet facilities for boys and girls aged 8 years and over must be

provided except where the toilet facility is provided in a room that can be

secured from the inside and that is intended for use by one pupil at a time.

• School premises and the accommodation and facilities provided therein must

be maintained to a standard such that, so far as is reasonably practicable, the

health, safety and welfare of pupils is ensured.

• There is also a provision that if a separate facility is provided for pupils who

are disabled, then this may be shared by other pupils, teachers, other school

employees and visitors.

Independent Schools

The Education (Independent Schools Standards) (England) (Amendment) Regulations

2012, which came into force on the 1st January 2013 amend the Education

(Independent Schools Standards) (England) (Amendment) Regulations 2010(2)

regulations. The requirements which affect toilet facilities are the same as those in

the regulations covering maintained schools, so this is the same extract:

• ..suitable toilet and washing facilities must be provide for the sole use of

pupils.

• Separate toilet facilities for boys and girls aged 8 years and over must be

provided except where the toilet facility is provided in a room that can be

secured from the inside and that is intended for use by one pupil at a time.

• School premises and the accommodation and facilities provided therein must

be maintained to a standard such that, so far as is reasonably practicable, the

health, safety and welfare of pupils is ensured.

• There is also a provision that if s separate facility is provided for pupils who

are disabled, then this may be shared by other pupils, teachers, other school

employees and visitors.

Boarding and Residential Schools

Without going into detail, toilet and washing facilities are also covered by the

National Minimum Standards for Boarding Schools, and National Minimum Standards

for Residential Special Schools which came into force on 1st January 2013 and these

can be found at the Department for Education Publications.


All schools – staff

Therefore, for staff, but not pupils, the applicable law is the Workplace (Health,

Safety and Welfare) Regulations 1992 paragraphs 20 and 21. The Regulations do not

specifically mention bins for sanitary waste, but do have an overriding condition that

“sanitary conveniences” (ie washroom facilities) should be “suitable and sufficient”.

The Health and Safety Executive, however, in the “Approved Code of Practice related

to the above Regulations, issue their interpretation of “suitable and sufficient” which

includes: “In the case of water closets used by women, suitable means should be

provided for the disposal of sanitary dressings”.

In practise this could be a covered pedal bin, although this would mean revealing the

contents to users and cleaners. Our bin is aimed at providing a better option than the

pedal bin, without having the costs and inconvenience of service collection contracts.

Note that the Workplace regulations above apply to staff, not pupils.

Sanitary Bin provision for pupil’s toilets at schools: what is “suitable”?

For all schools, the excellent “Bog Standard Organisation” www.bog-standard.org has

the serious purpose of promoting better toilet provision in schools.

This organisation, its research, charter and aims, is widely quoted. Even the

Department of Education’s publication “Standard specifications, layouts and

dimensions: Toilets in Schools" refers to the organisation’s School Toilet Charter

which states that sanitary disposal units should be provided in toilets for girls aged

eight and over.

Their campaign for better toilets for pupils was officially launched in England

in 2004 and is organised by ERIC (Education and Resources for Improving Childhood

Continence). It was developed in partnership with School Councils UK, the

Community Practitioners’ and Health Visitors’ Association (CPHVA) and the British

Toilet Association.

The Welsh Government published the following excellent guide in January 2012, good

reading for any school: School toilets: Good practice guidance for Schools in Wales

Primary Schools specifically:

It is worth reading comments on Mumsnet.com and NetMums.com from parents

concerned about how their daughters will cope at primary school if there are no bins

in the pupil’s loos. Research carried out in 2001 indicated that approximately 1 in 8

girls will start her periods whilst still at primary school.

Brilliant Bins are ideal for pupil’s toilets as well as staff toilets. Primary schools

generally have fewer pupils than secondary schools and so generally only one or two

bins are required per term per cubicle.

What regulations cover disposal of feminine hygiene waste from schools?

Schools are deemed to be “Municipal premises other than domestic” for waste

purposes, and so the disposal legislation and guidance is exactly as for business

premises. See the sections below.


Is Feminine Hygiene Waste clinical or hazardous waste? The Environment Agency’s guidance is that “the vast majority of municipal

hygiene waste is non-hazardous and non-clinical waste”.

The example provided by the Environment Agency of a case where the waste could

be classified as clinical is not referring to feminine hygiene waste. Staff and pupils at

school are not likely to be unwell to the degree that feminine hygiene waste is re-

classified. A risk assessment is required for non-domestic premises.

The detail, for all kinds of commercial municipal hygiene waste from non-healthcare

sources, including feminine hygiene waste from schools:

The following guidance is an extract from the Department of Health document: Safe

Management of Healthcare Waste, Edition 2 updated Mar 2011, page 108 & 109.

Municipal premises other than domestic:

This section considers potentially offensive/hygiene waste from non-healthcare

activities and premises(for example offices, shops, schools, childcare facilities,

animal boarding kennels, dog faeces collection bins, body piercing facilities).

These wastes can normally be assumed under this step of the assessment

to present no risk of infection unless an indication to the contrary is

provided by a healthcare professional. However, those who have a duty of

care for such waste should undertake appropriate assessment and

segregation where any risk factors indicate that an element of the waste may

be infectious.

Where there is a risk of infection, the waste is clinical waste and possesses the

hazardous property “H9: Infectious".The EWC code 20 01 99 should be

assigned and the waste disposed of in orange receptacles. (Note added by us:

this would only be for a situation such as an outbreak of diarrhea at a daycare

nursery leading to the production of potentially infectious nappies)

Waste contaminated with non-infectious bodily fluids is capable of causing offence

and therefore requires appropriate packaging to alert those in the waste

management chain of the contents. It is recommended that

such types of waste be classified as offensive/hygiene waste.

This waste should be segregated where it is generated in

quantity – one bag (7 kg or more) in any collection interval.

Only quantities less than 7 kg may be placed in the

black-bag waste stream.

So up to 7kg of sanitary waste can be included in one collection?

As noted above, the limit set by the Department of Health means that up to 7kg in

any one collection cycle may go in the “black bag” waste. One full Brilliant Bin is

likely to weigh approx. 1.0 kg and so our customers are unlikely to come near the

limit. Remember you only need change the bins when full and therefore you will not

be replacing all bins at the same time as with a service contract provider.

How easy is it for the cleaning staff to exchange the bins?

Very easy, very quick, no fuss, and nothing unpleasant to deal with. Each Brilliant Bin

has a plastic sleeve, on the reverse, containing a black bin bag ready for the whole

whole bin to be put into for disposal. It is easy for the cleaning staff to check whether

the bin needs changing by just picking it up – there’s no need to look inside. When

its time to change the bin, the whole bin is placed in the black bin bag and then,

securely double wrapped, it is disposed of within the school general waste.


I have been told our sanitary bin waste is controlled or offensive waste and

must be collected by a “specialist” service. Is this correct?

All household, commercial and industrial waste is “controlled waste” as defined in the

Environmental Protection Act 1990 and further classified in the Controlled Waste

Regulations (England & Wales) Regulations 2012. Therefore sanitary waste is indeed

controlled waste.

However, you don’t need a “specialist” to collect feminine hygiene waste. Controlled

waste may only be transferred to a waste carrier registered with the Environment

Agency, and the waste management company collecting your commercial waste will

be registered as a waste carrier in exactly the same way as any sanitary bin service

contract collector. This means that it is perfectly acceptable for your main waste to

have a proportion of hygiene waste included.

The Controlled Waste Regulations (England & Wales) 2012 also define “offensive

waste” from non-healthcare sources as waste for which the code 20-01-99 applies.

When feminine hygiene waste is a small component of general commercial waste, it

does not need to be described as offensive waste, does not fall within code 20-01-99,

and the whole collection is general municipal waste under code 20-03-01.

Only when feminine hygiene waste is collected as a “separate fraction” and handled

in bulk, as done by the contract service collection companies does it need to be

handled as “offensive waste” with the waste code 20-01-99, which then has a more

onerous final disposal rules.

Is Brilliant Bins registered with the Environment Agency?

Brilliant Bins is registered with the Environment Agency as both a Waste Carrier and

Waste Broker under our company name Seiquelle Innovation Ltd ref CB/HN5010CZ.

How can I check the registration of my waste collector?

You can easily check that your waste collector is registered at the Environment

Agency http://www2.environment-agency.gov.uk/epr/search.asp

How environmentally friendly is a disposable bin?

Using the Brilliant Bin system reduces the vehicle mileage required to dispose of the waste and eliminates the need for water and chemicals to wash out exchange units.

� The Brilliant Bin is inexpensive and so affordable by every school. It therefore

helps to ensure that sanitary waste is not flushed down the loo. It is

estimated that 2 billion sanitary items are flushed down the loo each year.

More on this from the "Bag it and Bin it Don't Flush it" campaign.

� The Brilliant Bin enables you to buy 6 month’s or a year’s supply of bins and

store them compactly in your cleaner’s cupboard. One delivery replaces

multiple trips to your site to deliver exchange units reducing vehicle mileage.


� Sanitary waste in the Brilliant Bin is collected along with your other

commercial waste and so no additional vehicle miles are required. (General

waste from Schools is commercial rather than domestic waste.)

� The Brilliant Bin is printed and constructed in the UK, so no shipping from the

Far East is involved.

� FSC (Forest Stewardship Council) http://www.fsc.org/about-fsc.html certified

box board is the principal material making up the bin. The original pulp is

bleached using an elemental chlorine free process, and the board produced at

an EMAS accredited mill. It can be disposed of by incineration for energy

recovery or is bio-degradeable. Not suitable for recycling due to the content of

the bin. The FSC logo is displayed on the back of the bin.

� The glossy laminate’s major raw material, Cellulose, comes predominantly

from managed forestry in North America. The pulp suppliers have active

replanting programmes and plant more trees than they harvest each year.

Thus this film is distinguished from most other thermoplastic films in that it

comes from a sustainable source and is not derived from fossil fuels. The

secondary raw material is acetic anhydride, a simple derivative of the everyday tabletop chemical acetic acid (vinegar).

I’m concerned about odour. Why is there no chemical fragrance in the Brilliant Bin?

The Brilliant Bin is designed to minimise environmental impact, therefore we do not

use chemical powders and fragrance inside the bin.

The lid of our bin is secured closed with a magnetic catch.

Our research shows that the addition of scented chemicals inside a bin does not

make a significant difference to odour outside the bin whether on an exchange bin or

for the Brilliant Bin.

Occasionally there is an issue which would only be dealt with by changing the bin.

You can change a Brilliant Bin immediately, with an exchange bin you may need to

wait weeks for the next exchange date.

You can also provide small disposal bags for sanitary items to be put in before

placing the item in the Brilliant Bin. These are available, along with an optional

dispenser, on our product page.

I’d like to provide small bags for items to go into before

going in the bin. Do you sell these? Yes, we supply printed paper bags designed for the purpose and

also a clear Perspex holder if needed. See our website product

pages.

What is Cellogreen eco-print laminate?

The glossy laminate inside and outside the Brilliant Bin is not

made from fossil fuel based plastics. The primary raw material

used in the production of the cellulose acetate laminate is

sourced from refined wood pulp from Sustainable Forest Initiative

managed forestry.


Do you provide guidance on Duty of Care - Waste Transfer Notes? With the Brilliant Bin system, you do not need a specific waste transfer note for your

sanitary bins. The completion of a waste transfer note is usually carried out annually

with your waste management company. You should let your waste management

company know that you have a small amount of hygiene waste in your collection.

Please request our Waste Transfer Note Information Sheet. It includes suggested

descriptions, waste code and details to add to your existing waste transfer note

content. Should your waste collection company have any questions, we will be very

happy to assist. We have positive agreement from major waste collection companies

for our system.

We hope this has assisted you to understand that you are allowed to

handle your own disposal of hygiene waste as well as use service

contract exchange-bin providers. Please do call us if you would like to

discuss any of this information further.

Susan Hofgartner

BSc ARCS

All information is provided in good faith, but we do not accept any liability if

you use this advice which is summarised and not tailored to any specific situation.

Documents

Brilliant Bins - The Sanitary Bin Guide for Schools in England Edition 7