Medical Waste in a Physiotherapy Practice - BDO
Tomek decided his physiotherapy practice "doesn't produce any medical waste" - after all, he doesn't give injections.
Tomek decided his physiotherapy practice "doesn't produce any medical waste" - after all, he doesn't give injections. Used disposable sheets, gloves and gauze pads went straight into an ordinary bin. During an inspection, it turned out that some of this waste counted as infectious, that the practice should have had a BDO (waste register - the Polish national waste database system) entry, a contract with a licensed waste collector, and proper records. The result was a note in the inspection report and the need to overhaul the entire waste management system.
Medical waste is an area many physiotherapists underestimate. Yet the regulations are unambiguous and are enforced both by the Sanitary Inspectorate (Sanepid) and the Environmental Protection Inspectorate. In this article we explain what counts as medical waste in a physiotherapy practice, whether you need a BDO entry, and how to store and hand it over legally.
What is BDO?
BDO stands for the Database on Products, Packaging and Waste Management - a register run by the regional governor's office (marshal of the voivodeship). Entities generating waste (including medical waste) must obtain an entry and keep records in the system.
The legal basis is the Act of 14 December 2012 on Waste and the Regulation of the Minister of Climate on the waste catalogue. Medical waste is additionally governed by the Regulation of the Minister of Health on the detailed procedure for handling medical waste.
Does a physiotherapy practice generate medical waste?
Yes, almost always. Even if you don't perform injections, your practice generates:
- used disposable gloves
- sheets and gauze pads that have been in contact with a patient
- dressings and plasters
- waste from procedures that break the skin barrier (dry needling - this also produces sharps waste)
This means your practice is a generator of medical waste and is subject to waste regulations.
Medical waste codes - which ones apply to you?
Medical waste falls under codes from group 18 01. The most relevant ones for physiotherapy:
| Code | Type of waste | Example in a practice |
|---|---|---|
| 18 01 03* | infectious waste (hazardous), including used needles | needles from dry needling (rigid container), sheets and gauze pads with bodily fluids, dressings |
| 18 01 01 | surgical and treatment instruments and their remnants (other than 18 01 03*) | sharp instruments with no contact with infectious material |
| 18 01 09 | medicines other than those listed above | expired products |
| 18 01 04 | waste other than infectious | dressings without contact with infectious material |
An asterisk (*) marks hazardous waste, which is subject to the strictest requirements. Most physiotherapy practices mainly generate small amounts of waste under code 18 01 03*.
Do you need a BDO entry?
This is the most common question. The general rule is: a generator of medical waste is subject to BDO registration. There are, however, exemptions for entities generating very small amounts of waste - the limits are set out in the regulation on the types and quantities of waste exempt from record-keeping.
In practice:
- If you generate infectious waste (18 01 03*), you generally need an entry and must keep records, since hazardous waste rarely qualifies for exemptions.
- If you generate only minimal amounts of non-hazardous waste, you may be exempt.
Since thresholds are updated from time to time, always verify the current status on the BDO website or with the regional governor's office before starting operations.
How do you segregate and store the waste?
Medical waste must be stored in designated containers and bags of the appropriate colour:
- red bags and containers - infectious waste (18 01 03*)
- yellow - hazardous waste other than infectious (medicines, chemicals)
- rigid, puncture-resistant containers - sharps waste (needles, including those from dry needling -- classified as infectious waste, 18 01 03*)
Storage rules:
- fill bags to a maximum of two-thirds of their capacity
- label containers with the waste code, the date they were opened, and the generator's details
- store infectious waste at a temperature of up to 18°C for no longer than the applicable period, and longer under refrigerated conditions (below 10°C) - details are set out in the regulation on handling medical waste
- the storage area must be separate, enclosed and inaccessible to unauthorised persons
Contract with a waste collector and the waste transfer note
Medical waste must never be thrown out with ordinary rubbish or transported by you yourself. You must have a contract with an authorised company holding a permit to transport and dispose of medical waste.
Every handover of waste must be documented with a waste transfer note (KPO), generated electronically in the BDO system. The KPO is proof that the waste reached a legal collector. It's a document that both the Sanitary Inspectorate and the environmental inspectorate will ask to see.
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Waste records in BDO
If you're subject to registration, you keep records in the BDO system:
- waste record card (KEO) - kept on an ongoing basis, separately for each waste code, for a given calendar year
- waste transfer notes (KPO) - for every handover
- annual report on waste generated - this is the yearly summary, submitted by 15 March for the previous year
Record-keeping is fully electronic. You log into your entity's BDO account using a trusted profile (profil zaufany).
Consequences of neglect
Failing to obtain a required BDO entry, or disposing of medical waste illegally, are serious breaches. Administrative fines for managing waste without an entry can range from several thousand to tens of thousands of zloty. On top of that comes the risk of a note from the Sanitary Inspectorate and liability for creating a sanitary-epidemiological hazard.
Frequently asked questions
My practice doesn't give injections - do I really generate medical waste?
Yes. Medical waste also includes used gloves, sheets and gauze pads that have been in contact with a patient, if they may be contaminated. The mere absence of injections doesn't mean you don't generate infectious waste. It's worth assessing the actual waste stream in your practice and classifying it accordingly.
Can I throw infectious waste into an ordinary bin?
No. Infectious waste (code 18 01 03*) must go into red bags, be stored in a designated area, and be handed over only to an authorised company on the basis of a waste transfer note. Putting it in with municipal rubbish is a breach of the regulations and a sanitary hazard.
How do I check whether I need a BDO entry?
The most reliable source is the official BDO system website and the regional governor's office. Since the thresholds for exemption from record-keeping are updated from time to time, don't rely on outdated information. When generating hazardous waste such as infectious waste, an entry is usually required.
How long can I store infectious waste at my practice?
The storage period depends on the storage temperature and is set out in the regulation on handling medical waste. At room temperature the period is short; under refrigerated conditions it's longer. In practice, small practices arrange regular collections so as not to exceed the permitted deadlines.
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Related articles:
- Sanitary Inspectorate check at a physiotherapy practice
- Premises requirements for a physiotherapy practice
- Most common compliance mistakes in a physiotherapy practice