Handling veterinary waste

Handling veterinary waste

Veterinary waste consists of both hazardous and non-hazardous waste which must be segregated, classified, described, packaged, labeled and disposed of in line with regulatory requirements.

What the BVA has done

We have produced the BVA Good practice guide to handling veterinary waste in England and Wales, which is supported by the Environment Agency. We have also produced posters for Northern Ireland and Scotland.

The guides aim to assist the veterinary profession in complying with waste regulations in their region. This web advice complements the guides.

What you must do

  • register as a hazardous waste producer
  • separate, classify and describe the waste you produce
  • ensure the waste is packaged and labeled appropriately
  • complete consignment notes (hazardous waste streams only) and transfer notes (non-hazardous waste streams only) and keep accurate records
  • submit quarterly returns to the Environment Agency if you receive waste from non-domestic producers (ie satellite practices or farms)
  • register as a lower tier waste carrier (from December 2013)

Duty of care

Your legal responsibility for waste extends beyond the time that the waste is collected. If an omission by the waste producer (veterinary practice) contributes to mismanagement of the waste by another party, then the producer may be held responsible. It is therefore essential that members discharge their Duty of Care.

All businesses have a legal responsibility to ensure their waste is:

  • correctly segregated
  • stored safely and securely on premises
  • packaged appropriately for transport
  • described accurately and fully on the accompanying documentation when removed
  • transferred to an authorised person for transport to an authorised waste site
  • appropriately registered, with necessary records and returns in place

To assist you in doing so, we have produced a letter and waste destination checklist for you to send to your waste contractor. It will enable you to gather and retain all the information you need.

In addition you should conduct:

  • a waste carrier check
  • a carriage of dangerous goods check
  • a pre-acceptance audit

Waste carrier check

To transport waste, a waste contractor must be a registered waste carrier. To ensure a waste contractor is registered:

  • identify the name of each company that collects each of your wastes
  • ask for their waste carrier registration number
  • use the Environment agency's public registerto confirm that the company is a registered carrier
  • record the information

If either the waste contractor is not a registered waste carrier or the number and name provided is not consistent with the public register, under no circumstances transfer or consign waste to this contractor.

Carrying your own waste and waste arising from your care

From December 2013, in order to transport waste that has arisen from your care, you will need to register as a lower tier waste carrier. This is a one off registration and is free of charge.

If you provide a service to farm clients to carry away their waste which has not arisen from your care then you can continue to do this providing you do not charge for it. If you charge for the service, then you would be subject to upper tier registration requirements

Carriage of dangerous goods

As waste producer, you are responsible for ensuring your waste is appropriately, segregated, classified, labelled and packaged. You should also undertake some basic checks to satisfy yourself that the waste contractor's vehicle is appropriate.

Considerations

Hazardous waste is transported in rigid packaging, or in 'bulk' (which relates primarily to hazardous waste bags being loaded into a vehicle without being placed into another rigid package such as a wheeled bin). Before transferring hazardous waste to a waste contractor you should check:

  • whether the hazardous 'clinical waste' bags are going to be transported loose. If so, the clinical waste bags used must be certified for carriage in bulk. Do not assume that they are
  • whether your waste contractor meets the requirements of the HSE with regard to crew and vehicle. Ask them to confirm this in writing

NB. Waste types should be kept separate on the vehicle and bags and rigid packaging should be loaded in a manner that means they are not in contact and are unlikely to come into contact if the vehicle moves.

Pre-acceptance audit

In 2009 the Environment Agency in England and Wales introduced a requirement for producers of healthcare waste who send their waste to alternative treatment plants, which includes veterinary practices, to conduct a pre-acceptance audit on a regular basis.

Clinical waste alternative treatment facilities are required by their permits to obtain additional detailed information on the composition of waste before they receive it.

The audit can be carried out by the practice or by any environmental consultant. Some waste management companies are offering to carry out the audit for a cost, but this is not a legal requirement.

You should contact your waste management company and request guidance on what specific information they require in the audit before they are prepared to accept your waste. You will then be able to make the decision as to whether or not you feel competent to provide this information yourself.

By following the BVA Good Practice Guide to Handling Veterinary Waste and putting in place waste management procedures you should be able to meet the requirements of your waste management company. However, the BVA has produced a pre-acceptance audit checklist that you can download and use.

Record keeping

All veterinary practices must:

  • maintain a register of hazardous waste produced, received and consigned
  • complete consignment notes for all hazardous waste consigned to a waste contractor
  • complete transfer notes for all non-hazardous waste transferred to a waste contractor

In addition, if you collect or receive hazardous waste from a non-domestic client you become a hazardous waste consignee and must:

  • send a return to the producer
  • send a quarterly return to the Environment Agency (including a £10 quarterly fee)

    Consignment

    Consignment notes

    Consignment notes are required for all movements of hazardous waste. Consignment notes can be single/standard or multiple (with annexes). In each case you must provide a copy for the waste contractor and retain a copy for your records, which must be recorded in your waste register.

    Consignment notes contain information on:

    • quantity of waste
    • nature of waste
    • origin of waste
    • destination of waste
    • frequency of collection
    • details of waste carrier
    • mode of transport

    More information

    Environment Agency guidance on completing consignment notes

    Consignee returns

    The consignee (the destination site for the waste) is required to send you, as waste producer, a return each quarter. This return is a record of what has happened to the waste and must be placed in your waste register. These consignee returns must be present to ensure the register is legally complete.

    Consignee returns contain information on:

    • quantity of waste
    • nature of waste
    • origin of waste
    • destination of waste
    • frequency of collection
    • details of waste carrier
    • mode of transport
    • recovery or disposal operation applied to the waste

    If your waste contractor does not provide consignee returns you should make a formal request in writing. If this is unsuccessful you should make alternative arrangements and pass the details of the waste contractor to the Environment Agency.

    If your waste is taken to a transfer station before being sent elsewhere you should request copies of the associated completed paperwork for that onward movement and confirmation that it was received at the final destination.

    Rejected consignments

    Consignees sometimes reject consignments of hazardous waste. When this happens they must send you an explanation. A new consignment note will be completed in order to move the waste elsewhere and the consignee must send you a copy of this note. You should keep the new consignment note and a copy of the reasons for the rejection in your waste register. 

    Waste register

    You must keep a register of hazardous waste that you receive or move.

    The register must contain information on:

    • quantity of waste
    • nature of waste
    • origin of waste
    • destination of waste
    • frequency of collection
    • details of waste carrier
    • mode of transport

    You can meet the register requirements by keeping copies of and recording:

    • standard or multiple consignment notes (including annexes where applicable)
    • consignee returns to the producer/holder. These should be sent to you by your waste contractor (the consignee)
    • details of any rejected consignments
    • waste contractor schedules (if there is more than one contractor involved.

    Your register should be kept at the practice which is registered as the hazardous waste producer. If you have a branch or satellite practice which is exempt from registration as a hazardous waste producer, the register for recording the hazardous waste produced and removed from that branch or satellite practice must be kept at the principal place of business. If you wish to keep it elsewhere then this must be agreed in writing with the Environment Agency.

    Information in the register must be kept for at least three years from the date of removal from the practice by the waste contractor.              

    What is hazardous waste?

    Hazardous waste is waste which is harmful to people, the environment or animals, either immediately or over an extended period of time. This could include waste which is toxic, carcinogenic, infectious or eco-toxic.

    Key veterinary hazardous wastes include

    • cytotoxic and cytostatic pharmaceuticals
    • infectious, clinical waste - any veterinary waste containing viable micro-organisms or their toxins which are known or reliably believed to cause disease in humans or other living organisms; or waste which, following a veterinary assessment, is deemed to present a risk of infection to any person or animal that may come into contact with it
    • sharps contaminated with material that is deemed to present a risk of infection to any animal or person that may come into contact with it
    • photographic chemicals such as waste fixer or developer solutions

    All veterinary facilities that produce more than 500 kg of hazardous waste per annum need to register their premises with the Environment Agency.

    Before any hazardous waste leaves the premises a consignment note must be completed. Sufficient copies of the note must be prepared to allow the producer, the consignor (if different to the producer), all carriers and the consignee (the receiver of the waste) to each have a copy. 

    All people who produce, move or receive hazardous waste need to record this and maintain a register of each waste involved for their records. 

    These records must be kept for at least 3 years.

    Scotland

    In Scotland, hazardous waste is referred to as special waste and includes cytotoxic and cytostatic pharmaceuticals, infectious, clinical waste, contaminated sharps and photographic chemicals.

    Special waste must be disposed of using a special waste consignment note and the records must be kept for at least 3 years.

    Cytotoxic and cytostatic pharmaceuticals

    Cytotoxic or cytostatic pharmaceuticals are medicinal products that are toxic, carcinogenic, mutagenic or toxic for reproduction. The NIOSH Pocket Guide to Chemical Hazards provides a list, but it should be noted that it may not be comprehensive, so if in doubt contact the manufacturer.

    The BVA has produced a basic guide to pharmaceuticals that are cytotoxic or cytostatic.

    Any item of waste that is, or is contaminated by cytotoxic or cytostatic pharmaceuticals should be placed in this waste stream. Following a veterinary assessment waste deemed to be contaminated may include:

    • clinical items (for example Personal Protective Equipment such as swabs, masks and gloves)
    • syringe bodies and items used to administer these substances
    • waste cytotoxic and cytostatic medicines regardless of whether they are in tablet, liquid, cream or aerosol form
    • animal bedding
    • used glass bottles and vials or sharps, which should always be placed in a rigid purple lidded sharps container

    Classification and disposal

    Cytotoxic and cytostatic pharmaceutical waste should be segregated into appropriate purple and yellow containers and classified as follows:

    • EWC = 18 02 07* and 18 02 02* (Cytotoxic and Cytostatic clinical waste, including sharps, for high temperature incineration) 

    NB. If medicines are present in an aerosol form this should also be mentioned in the description.

    Rigid containers may be better as this reduces the risk of the purple stripe being hidden. However, if large quantities of cytotoxic and cytostatic pharmaceutical waste is being produced then a yellow clinical waste bag with a purple stripe may also be considered. This should be discussed with your waste contractor. Contaminated sharps must always be placed in a sharps container.

    The container should be of a type clearly labelled by the manufacturer to identify that it contains (and is suitable for) cytotoxic and cytostatic pharmaceutical waste.

    Infectious waste

    This is any veterinary waste containing viable micro-organisms or their toxins which are known or reliably believed to cause disease in humans or other living organisms; or waste which, following a veterinary assessment based on knowledge of the patient, is deemed to present a risk of infection to any animal or person that may come into contact with it.

    This may include:

    • items used in treatment (for example, swabs, masks and gloves, which may include blood contaminated items
    • animal bedding
    • blood and body parts

    Classification and disposal

    Infectious, clinical waste should be segregated into yellow bags or containers and classified and described as follows

    • EWC = 18 02 02* (Infectious, clinical waste containing anatomical waste for incineration only)

    Alternatively, segregation into orange bags or containers and classified and described as follows:

    • EWC = 18 02 02* (Infectious, clinical waste, no body part, for suitable alternative treatment eg autoclaving)

    The bags and containers should be of a type clearly labelled by the manufacturer to identify that it contains and is suitable for infectious, clinical waste.

    Photographic chemicals

    Photographic chemical waste is waste contaminated with fixer and developer solutions.

    This may include

    • waste fixer
    • waste developer
    • ‘empty’ fixer and developer containers
    • waste film

    Classification and disposal

    Photographic chemical waste should be classified and described as follows:

    • EWC = 09 01 01* (x-ray developer) and 09 01 04* (x-ray fixer)

    Fixer and developer waste should be stored in separate leak proof containers although there is no standard packaging and specific requirements should be discussed with your waste contractor.

    NB. ‘Empty’ fixer and developer containers may still be hazardous waste and, unless triple rinsed following appropriate safety precautions, should be described and disposed of as waste fixer and developer.

    This waste should be moved on a consignment note and sent to an appropriately permitted facility for recovery / recycling.

    Other chemicals

    A detailed explanation of the requirements for disposal of chemical waste is beyond the scope of this web advice.
    There are 3 key points to note:

    • chemicals should not be disposed of in the clinical waste stream, as this may cause chemical releases and worker exposure issues during subsequent handling and disposal
    • chemicals should note be disposed of to foul sewer or surface drains
    • some chemicals may react to produce fire or toxic gas and these incompatible chemicals should be disposed of and stored separately

    Electrical equipment

    Although a detailed explanation of the requirements for disposal of electrical waste is beyond the scope of this web advice, there are three key points to note

    • many electrical wastes including fridges, freezers, fluorescent tubes, televisions, CRT and TFT (flat screen) computer monitors, and certain batteries are hazardous wastes and must therefore be segregated from other waste and consigned
    • local civic amenities are unlikely to be authorised to accept commercial electronic waste and this should be checked before taking waste there, with the required consignment note
    • when purchasing new equipment make arrangements with the supplier to remove the old equipment

    More information

    What is non-hazardous waste?

    Non-hazardous waste is waste which is not harmful to people, the environment or animals, either immediately or over an extended period of time.

    Key veterinary non-hazardous wastes include:

    • any pharmaceuticals (other than cytotoxic or cytostatic pharmaceuticals)
    • offensive waste – waste that is not ‘clinical waste’ but which is unpleasant and may cause offence to the senses. Only certain waste types are suitable for placement in this waste stream without stringent and documented assessment procedures
    • domestic rubbish

    When non-hazardous waste is transferred from one party to another a waste transfer note must be completed, which both parties must sign and keep a copy of. You must also sign a declaration stating that you have applied the waste hierarchy (this will form part of the waste transfer note). An annual transfer note may be used to cover all movements of a regular transfer of the same non-hazardous waste between the same parties. These records must be kept for at least 3 years. 

    Scotland

    In Scotland, non-hazardous waste is referred to as non-special waste and includes pharmaceutical waste (other than cytotoxic or cytostatic pharmaceutical waste), hygiene waste and domestic rubbish.

    Non-special waste must be disposed of using a waste transfer note and the records must be kept for at least two years.  

    Offensive waste

    Offensive waste is veterinary waste (other than sharps, anatomical, pharmaceutical, gypsum, etc) that is not –hazardous or clinical but which is unpleasant and may cause offence to the senses. Only certain waste types are suitable for placement in this waste stream without stringent and documented assessment procedures.

    Offensive waste must have been subjected to a veterinary assessment that clearly demonstrates it does not present a risk of infection or other potential hazard to any animal or person that may come into contact with it, even if mismanaged. This is particularly important in the case of material contaminated with body fluids such as blood, where the veterinary surgeon must be able to demonstrate that they have carried out a veterinary risk assessment which must ask:

    • does the material arise from an animal that has any disease cause by a micro-organism such that the material is contaminated with that micro-organism?
    • is there any potential risk of infection?
    • if the answer to either question is ‘yes’ the waste cannot be classified as offensive waste

    As a result of this veterinary risk assessment the veterinary surgeon is legally declaring that the waste is not ‘clinical waste’ that is capable of causing harm and does not present a risk of infection to any person or other living organism, even is mismanaged by the waste contractor. This waste does not therefore require treatment or incineration.
    Veterinary surgeons should be prepared to provide written assessment procedures to the Environment Agency and waste contractors on request.

    Examples of offensive waste may include:

    • Items used in treatment such as swabs, masks and gloves, which may include blood contaminated items (assessed to be non-infectious)
    • Animal bedding
    • Animal faeces as long as the animal is not suffering from an infection that would result in the presence of pathogens in the faeces

    NB. These must not contain body parts or body tissues

    Classification and disposal

    Offensive waste should only be placed in a ‘tiger bag’ (yellow with a black stripe) and should be classified and described as follows:

    • EWC = 18 02 03 (Offensive waste: Veterinary waste that has been determined by veterinary risk assessment to present no risk of infection.)

    The bags should be of a type clearly labeled by the manufacturer to identify that it contains, and is suitable for, offensive waste.

    Offensive waste should not be placed in a black refuse bag.

    This waste is non-hazardous and should be moved on a waste transfer note. Offensive waste can be disposed of by incineration (preferably energy recovery) or non-hazardous landfill at a suitably permitted facility. The waste hierarchy must be applied.

    Most clinical waste treatment sites are not permitted to dispose of this material as it is not infectious.

    Scotland

    In Scotland, offensive waste is referred to as hygiene waste. The information above applies to hygiene waste.

    Pharmaceuticals and controlled drugs

    Pharmaceuticals and controlled drugs

    This is any waste contaminated with pharmaceuticals (not cytotoxic or cytostatic) and may include

    • denatured controlled drugs
    • prescription-only medicines
    • out-of-date drugs
    • contaminated bottles, syringe bodies, packaging and items used in their handling and administration (NB non contaminated outer packaging such as cardboard should be recycled)

    Classification and disposal

    Pharmaceutical waste is non-hazardous waste and should be segregated into blue rigid leak proof containers. It should be classified and described as follows:

    EWC Classification: 18 02 08 (Pharmaceutical waste (non-cytotoxic or cytostatic) for incineration only)

    Where possible pharmaceuticals (not cytotoxic or cytostatic) should be disposed of in their original packaging. Care should be taken to avoid mixing, particularly if the substance is flammable.

    There is also a duty of care to describe the hazardous properties of a medicine, even if the medicine itself is legally non-hazardous. Possible hazardous properties could include flammable, harmful, irritant, oxidising or ecotoxic (ie capable of causing harm to the environment). Hazardous properties are listed in full in the Environment Agency’s technical guidance

    It is good practice to maintain a record of pharmaceuticals that are disposed of; as it assists in ensuring volatile products are not mixed.

    Controlled drugs

    Controlled drugs are those capable of being abused that are managed under the Misuse of Drugs Regulations 2001.
    They are classified into five Schedules according to different levels of control. A veterinary surgeon acting in a professional capacity has authority to supply those in Schedule 2, 3, 4 and 5.
    A full list of controlled drugs and their classification is available from the Home Office.

    Classification and disposal

    All controlled drugs must be denatured or made not readily recoverable and then be disposed of with other pharmaceuticals (not cytotoxic or cytostatic) by segregation into blue leak-proof containers. They should be classified and described as follows:

    • Classification EWC= 18 02 08 for incineration at an appropriately permitted facility.

    A commercially available Controlled Drugs Destruction Kit should be used wherever possible. 

    Schedule 2 drugs

    Schedule 2 controlled drugs must be destroyed in the presence of an authorised person. This could be 

    • someone from the VMD’s Inspections and Investigations team (formerly the Animal Medicines Inspectorate)
    • an RCVS Practice Standards Scheme Inspector
    • a veterinary surgeon who is independent of the practice concerned (this excludes locums, family members or any relationship that may pose a risk of collusion)
    • another person authorised to witness the destruction of controlled drugs under the Misuse of Drugs Regulations 2001 or the Misuse of Drugs Regulations (Northern Ireland) 2002, such as a Police contact

    A record must be made of the date of destruction and the quantity destroyed, which the witness must sign. It is good practice to also record the name of the controlled drug, form, strength and quantity, date it was destroyed and the signature of the witness and the professional destroying it.

    Please note that the requirement for a witness only applies to the process of denaturing. Denaturing renders the drug unrecoverable and therefore it is not necessary for the physical removal of the denatured drug from the premises to be witnessed as well.

    Returned controlled drugs

    It is not a legislative requirement that the destruction of returned controlled drugs be carried out in the presence of an authorised witness, nor does it have to be recorded. However, it is good practice to make a record of any controlled drugs that are returned and to have their destruction witnessed by another member of staff who then signs the record. 

    Domestic waste

    Veterinary practices are not domestic premises and do not therefore produce domestic waste.

    They do however produce a range of non-hazardous materials that are essentially the same as those produced by a domestic household and can be termed ‘municipal waste’

    Mixed Municipal (Black Bag)waste

    Is the residual ‘domestic’ type waste, after the recyclables have been removed, that is discarded in the ‘black bag’ waste stream or equivalent.

    Veterinary practices should be aware that, unlike domestic householders, they are:

    • legally prohibited from placing any items of hazardous waste in this waste stream, and
    • are subject to a duty to apply the waste hierarchy

    As a result this waste is classified as non-hazardous (or non-special in Scotland).
    Non-recyclables (mixed municipal waste) should be classified as:

    • EWC = 20 03 01 (mixed)

    Non-recyclable mixed municipal waste in a black bag can be disposed of by either:

    • municipal waste incineration with (with significant energy recovery – classed as R1)
    • municipal waste incineration (normally with some energy recovery)
    • mixed municipal landfill

    This waste is normally collected by either the local authority or a commercial waste contractor.

    Waste hierarchy and recycling

    The waste hierarchy sets out the considerations all waste producers must follow, and give precedence to not producing the waste in the first place. 

    • Prevention (i.e. don’t produce the waste) 
    • Preparing for re-use 
    • Recycling 
    • Other recovery (for example incineration at a plant designed to generate significant amounts energy from the waste)
    • Disposal (e.g. incineration or landfill)

    The hierarchy now has a legal rather than good practice basis and all veterinary practices transferring waste will have to sign a declaration that they have applied the hierarchy. The declaration should be included as part of the transfer note.

    Recyclables may include, for example;

    • paper, card, unsoiled newspapers and magazines
    • plastic food containers
    • drink cans
    • batteries (noting that some types are hazardous waste and will require a consignment note. Your waste contractor may be licensed to collect portable batteries for recycling)

    You may also wish to recycle glass vials and bottles. Whether you can or not will depend on what it originally contained. You should not rinse to the sewer any bottles or vials which previously contained cytotoxic or cytostatic pharmaceuticals or pharmaceutically active substances as once they pass through sewage treatment systems and enter the aquatic environment there is potential for harm to living organisms. This takes precedence over the requirement to recycle so glass bottles or vials which contained pharmaceuticals should be disposed of as pharmaceutical waste. Water UK provides national guidance on healthcare waste water discharges

    Scotland

    In Scotland, the waste hierarchy does not apply. However, the Zero Waste Regulations were passed by the Scottish Parliament in May 2012 and place the onus on the waste producer to reduce, re-use and recycle in a similar way to The Waste (England and Wales) Regulations 2011.

    Sharps

    Contaminated sharps

    A contaminated sharp is any partially or fully discharged sharp, hypodermic needle or other sharp instrument contaminated with:

    • cytotoxic or cytostatic pharmaceuticals
    • other pharmaceuticals (not cytotoxic and cytostatic)
    • blood or other body fluids

    A separated syringe body is not considered to be a sharp. If it is medicinally contaminated, is considered pharmaceutical waste.

    Classification and disposal

    Contaminated sharps should be disposed of in a yellow sharps container with a yellow lid and should be classified and described as follows:

    • EWC = 18 02 02* and 18 02 08 (contaminated sharps for high temperature incineration only)

    Non-pharmaceutically contaminated sharps that have been further segregated into a yellow sharps bin with an orange lid should be classified and described as 

    • EWC = 18 02 02* (Sharps non-medicinally contaminated, suitable for alternative treatment)

    This waste is hazardous waste and should be moved on a consignment note.

    All yellow sharps containers with a yellow lid must be disposed of by clinical waste incineration at a suitably permitted facility.

    Non-pharmaceutically contaminated sharps that have been further segregated into yellow containers with an orange lid may be disposed of by alternative treatment (for example, autoclaving) at a suitably permitted facility.

    The container should be of a type clearly labelled by the manufacturer to identify that is contains (and is suitable for) contaminated sharps waste.

    Sharps must never be disposed of in a bag as this may cause injury to waste management staff.

    Non-contaminated sharps

    Sharps classified as non-hazardous waste must have been subjected to a veterinary assessment that clearly demonstrates they do not present a risk of infection to any animal or person that may come into contact with it. 

    A example of a non-hazardous sharp could include an unused sharp that has been dropped on the floor prior to use.

    Non-hazardous sharps are classified as EWC = 18 02 01 however it is unlikely that a veterinary practice would produce a sharps waste stream which could be coded this way. 

    NB. If there is deemed to be a risk, however small, the sharp should be assumed to be hazardous and handled accordingly.

    Scotland

    In Scotland, the above information applies, with the exception of the use of EWC 18 02 08 for contaminated sharps. The Scottish Environment Protection Agency does not permit dual coding nor does it allow the use of non-special codes on special waste. In Scotland you must always use EWC 18 02 02* for contaminated sharps. 

    Cadavers

    Classifying pet cadavers

    The classification of a pet cadaver as infectious waste is a very sensitive issue and any decision must be made in consultation with the owner.

    Strictly speaking a pet cadaver is an infectious waste if the pet is suffering from a disease caused by a micro-organism. This includes any disease regardless of severity or transmissibility. The definition of infectious is not limited to notifiable diseases.

    If after a detailed item and patient specific assessment a veterinary surgeon determines that the pet cadaver would present no risk of infection to any person or animal that might come into contact with it, even if mismanaged, then it should be treated as not infectious. 

    Disposal of non-infectious cadavers

    Pet cadavers are transferred and disposed of under animal by-product controls (except where the cadaver is suspected of harbouring a notifiable disease, in which case collection and disposal will be arranged by Defra).

    Disposal options for non-infectious cadavers are:

    • burial at home
    • burial in a pet cemetery
    • cremation
    • incineration by a clinical waste contractor

    If the owner is taking the pet cadaver home for burial, you may wish to supply them with some information. The BVA has produced guidance on home burial that you can use as a template.

    Advising your Clients on Cremation

    Clients can be upset to find that unless their pet is cremated on the basis of the ashes being returned to them, the final destination of the ashes may be a commercial or council landfill site.

    While some pet crematoria have their own disposal site for these ashes, others do not. This seems to depend very much on the site of the crematorium, and on the conditions imposed upon it by local planning and other council officials. This therefore causes inevitable inconsistency in the final destination of such ashes. 

    We recommend that members check with their pet crematoria what happens to the ashes of pets cremated communally, so that clients can be advised correctly. If any clients then wish to ensure that the ashes of their pets should not go to a general landfill site, they can make alternative arrangements if they are locally available.

    This should help to avoid possible misunderstanding and unpleasantness at times when clients are understandably under stress.

    Disposal of infectious cadavers

    If, following the veterinary assessment, the cadaver is considered to pose a risk the veterinary surgeon should, with the owner’s consent, classify and describe it as:

    • EWC = 18 02 02* (pet cadaver, infectious clinical waste for high temperature incineration)

    What container should be used for pet cadavers?

    There is no standard packaging so specific requirements should be discussed with the waste contractor.
    Any packaging should ensure those handling the cadaver are protected from physical injury and should also contain any potential fluid leaks.

    Approval of pet crematoria and cemeteries

    All pet crematoria must be approved by AHVLA as incinerators. AHVLA also registers pet cemeteries and a list of approved cemeteries is available on the AHVLA website under 'other registered operators'.

     

    • Practice standards

      All the practical tools you need to prepare for an RCVS inspection can be found right here, along with useful information and advice.