The Operating Framework for a Compliant and Sustainable Healthcare Waste Management Program

Healthcare organizations generate some of the most complex waste streams due to the varying types of materials and the potential hazards during handling. Understanding waste stream requirements and being able to apply them is an important part of building a successful waste sustainability program. The operating framework includes all the requirements that your organization must meet or abide by, whether by law, industry, or other business requirements.

If there is an issue in any of your program areas, particularly the operating framework, the waste program will not be sustainable. The operating framework includes four areas: 

• Regulation: Local, provincial, and federal regulations are requirements your organization must follow by law. Some examples may include local requirements, Canadian Council of Ministers of the Environment (CCME), Transport Canada, and Health Canada.
• Industry Standards and Best Practices: Industry standards and best practices are not law but support business needs and objectives. Often, organizations view many standards and best practices as required. Let’s further clarify what this includes:
  • Industry Standards: Industry standards are based on a few different areas. Examples include but are not limited to:
    • Industry organizations that support specific areas, like fire safety.
    • Accreditation organizations that establish standards necessary for specific accreditation. Accreditation standards may be based on law but are not law.
    • Industry rating organizations have standards established for recognition of excellence.
  • Industry Best Practices: Industry organizations provide guidance and potential best practices to support regulation and safe outcomes for employees, patients, the community, and the environment.
• Waste Acceptance Policies and Other Supplier Requirements: Waste acceptance policies may be more stringent than the law because they may include additional business requirements of the supplier. Waste acceptance policy variances from the law may be due to permitting requirements, supplier-specific regulations, or other business decisions to support safety or sustainability. It is important to ask questions and understand these requirements and how they apply to your organization.
• Internal Policies: An organization's policies typically include all other previously mentioned applicable requirements, as well as its own business requirements. Your policies may be more stringent than regulation due to your own business requirements around workplace safety, work efficiencies, supply chain impacts, or other logistical needs.

Working within these frameworks can be complex because there may be a lack of alignment between each requirement area. This can get more complicated when internal policies, such as waste acceptance or infection prevention policies, may be more strict.

Stakeholder Engagement

Proactively identifying the requirements applicable to your organization and including them in your program strategy will help create efficiencies and drive positive, compliant outcomes for your waste programs. Working with all relevant key stakeholders is critical to ensure your plan considers all requirements among other elements when building out your program plan.

Failure to acknowledge, understand, and implement the requirements within an operating framework increases risk that can potentially lead to financial (fines, brand impact, healthcare waste spending), environmental (pollution, overconsumption of resources, higher emissions), and social (employee culture and health, community health and well-being) consequences. 

Typically, operating framework failure results from neglecting to engage and/or communicate effectively with key stakeholders who would be aware of requirements and have insight into the application for all involved groups. Lack of understanding of the requirements or not engaging the appropriate stakeholders leads to a misunderstanding of the materials procured, workflows, and disposal requirements and options.

The requirements are in place to safeguard the health and safety of people and the environment, as well as the financial health of your organization and the community. Compliance is the foundation of a successful sustainability program. 

Learn more about the role Stericycle can play in your organization’s sustainable waste management program.