Every day, healthcare teams make hundreds of decisions about what goes into which bin. Those decisions determine whether a residue is destroyed, or simply moved somewhere else, often ending up in the sea.
Most waste generators know how to keep clinical waste safe to handle. Far fewer know what happens to it once it leaves the loading dock. That gap matters: the treatment that makes waste non-infectious is not the treatment that makes it harmless.
Two Kinds of Hazard, Two Kinds of Treatment
Clinical waste presents two different hazards.
1. Biological: pathogens on dressings, swabs, personal protective equipment and sharps.
2. Material: chemically persistent substances such as pharmaceutical residues, cytotoxic drugs and products containing per- and polyfluoroalkyl substances (PFAS).
The common non-incineration technologies, steam autoclaving at around 121–134°C or chemical disinfection with agents such as sodium hypochlorite, usually with shredding, are well suited to the first hazard. They reliably inactivate pathogens, and the World Health Organization favours them over incineration for infectious waste where feasible. The treated residue typically goes to landfill.
But these processes are designed to kill organisms, not break down stable molecules. A compound that tolerates 134°C steam and a hypochlorite wash leaves the treatment plant much as it arrived. In landfill it can migrate into leachate, often discharged to sewer, and conventional wastewater treatment was never designed to remove it.
A simple test therefore helps. If a material would survive the autoclave or the chemical bath, those processes will not deal with it. It should go to high-temperature incineration, where it is destroyed rather than relocated.
What the Baltic Sea Tells Us
The Baltic Sea offers a sobering case study. The 2017 HELCOM and UNESCO status report, Pharmaceuticals in the aquatic environment of the Baltic Sea region, compiled data on 167 pharmaceutical substances sampled in the marine environment.
The study found the following;
- 44 per cent of those measured were detected.
- Only nine of 118 assessed pharmaceuticals were removed from wastewater with an efficiency above 95 per cent.
- Nearly half were removed at less than 50 per cent, and 16 were found at higher concentrations leaving treatment plants than entering them.
The report identifies treatment plant discharges as the main pathway to the sea, with coastal and marine waters the “ultimate sinks”. Much of that load reflects everyday medicine use rather than healthcare waste, but the lesson is direct: once a persistent compound reaches the water cycle, it cannot be retrieved, and its risks to marine life and the food chain remain largely unknown.
Close to home
Australia should not assume this is a European problem. A 2023 study by RMIT University, the Marine Mammal Foundation and the University of Melbourne, published in Science of the Total Environment, found liver PFAS concentrations in critically endangered Burrunan dolphins from Port Phillip Bay and the Gippsland Lakes that are the highest reported in dolphins worldwide. One Port Phillip Bay juvenile recorded 19,500 nanograms per gram, the highest level recorded in an individual dolphin globally.
The source of those levels is not yet understood, and medical waste is not the only contributor. But the findings show that Victoria’s bays and lakes already accumulate persistent chemicals. PFAS are used in some medical products, including fluid-repellent gowns and drapes and fluoropolymer tubing and coatings, and their carbon–fluorine bonds will not be broken by steam sterilisation or chlorine disinfection.
The Law Asks for More Than the Lowest Price
In Victoria, the Environment Protection Act 2017 imposes a general environmental duty to minimise risks of harm to human health and the environment from pollution or waste, so far as reasonably practicable. Cost is one factor in that test, but only one. It sits alongside the likelihood and severity of harm, the availability of controls, and what a person knows, or ought reasonably to know, about the risk.
EPA Victoria also makes the generator responsible for ensuring each waste type goes only to a facility permitted to receive it. Its guidance requires pharmaceutical, cytotoxic and human tissue waste to be incinerated, and if a clinical waste stream is contaminated with pharmaceuticals or human tissue, the whole stream must be incinerated. In practice, that means choosing a pathway based on what is in the waste and where it will end up, not which contractor offers the lowest rate per bin.
What Healthcare Teams Can Do
Practical steps include:
• Segregate at the point of generation. Keep pharmaceuticals, part-used vials, infusion bags and cytotoxic items out of the general clinical stream, and use incineration-only (orange-lidded) and purple cytotoxic containers as intended.
• Ask where your waste goes. Ask contractors which technology treats each stream, where the residue is disposed of, and how landfill leachate is managed.
• Identify persistent materials. Review product lines for PFAS-treated or fluoropolymer items, flag them for incineration and consider alternatives at procurement.
• Train and audit. Bin contamination is a common failure point. Regular audits and short, practical training keep segregation on track.
• Choose on outcomes, not price alone. Document why each pathway was chosen. That record is also evidence that you have met the general environmental duty.
A Non-Negotiable
None of this means incinerating everything. Steam and chemical treatment remain right for most infectious waste, and incineration has its own energy and emissions burden. The point is to match the treatment to the hazard.
That requires a deeper understanding of how your waste is treated than many organisations have. But the duty to avoid harm to human health and the environment is not optional. Healthcare exists to protect health, and its waste should not quietly undermine it through the ocean and the food chain. Leaving the world better than we found it is the standard we should all work to.
About the author
Andrew Swann is a Director of Circular Resources Australia (CRA), a National environmental compliance consultancy. He holds a B.Com and B.Sc (Hons) and specialises in hazardous and liquid waste treatment and transport and EPA compliance. CRA has worked with clinical waste operators including Veolia (Corio), Daniels (Dandenong South) and Ace Waste (Dandenong South).
Sources
1. HELCOM & UNESCO (2017). Pharmaceuticals in the aquatic environment of the Baltic Sea region – A status report. UNESCO Emerging Pollutants in Water Series No. 1 (BSEP 149). https://helcom.fi/wp-content/uploads/2019/08/BSEP149.pdf
2. Foord, C., Szabo, D., Robb, K., Clarke, B., Nugegoda, D. (2023). Hepatic concentrations of per- and polyfluoroalkyl substances (PFAS) in dolphins from south-east Australia: Highest reported globally. Science of the Total Environment. doi:10.1016/j.scitotenv.2023.168438
3. World Health Organization (2024). Health care waste – fact sheet. https://www.who.int/news-room/fact-sheets/detail/health-care-waste
4. EPA Victoria. Manage clinical and related industrial waste; Classification of clinical and related industrial waste. https://www.epa.vic.gov.au/manage-clinical-and-related-industrial-waste
5. Environment Protection Act 2017 (Vic), ss 6 and 25 (general environmental duty).