How dangerous is „non-hazardous” waste?

Overview on the regime and management of non-hazardous healthcare waste

What is non-dangerous waste?

Healthcare or clinical waste, as generically referred to, includes waste of potentially infectious nature, generated by the medical act.

It is known in regulations as “group 18 01”. Many such medical wastes are dangerous – more precisely, infectious waste, defined as substances containing viable microorganisms or their toxins, known as causing diseases in humans or other living organisms [1]. Read more here.

From a legislative point of view, their regime is very clear: this type of waste bears the code 18 01 as per the European Waste Catalogue, transposed into the national legislation through Government Decision no. 856 of 2002.

However, there are types of non-dangerous waste that fall within the same code 18 01. Please read below about these types of waste and how it should be managed.

Which is the non-dangerous medical waste generated by hospitals?

The waste generated by the healthcare system also includes non-dangerous waste (excluding refuse waste), as follows:

18 01 02 – anatomic-pathological waste

18 01 04 – gypsum materials, uncontaminated linen and clothing, disposable diapers used by children or adult patients

18 01 07 – various chemicals, such as disinfectants

18 01 09 – non-dangerous materials (other than cytotoxic/cytostatic)

Methods of disposal of medical waste, including non-dangerous waste

There are clearly regulated procedures that must be complied with when it comes to disposing medical waste, including the waste deemed non-dangerous.

According to the applicable guidelines [2] there are two methods for disposing this waste:

D 9: Physical-chemical treatment (i.e.: low-temperature thermal treatment, also called sterilization); the result of D9 disposal operations consists in sterilized and microbiologically inactivated waste [3]. This type of waste may be discarded in compliant landfills, authorized for this group of waste (19 02 03) or used as alternative fuel for energy recovery, in authorized installations.

D10: Incineration on land; this incineration process generates ash [4] which may be reused as a construction material for road foundation or may be discarded in landfills for industrial waste [5]

Any of these operations is followed by the disposal of the result obtained in compliant landfills, through

D1: Deposit on land (i.e. landfills for industrial waste)

Although this waste is considered not dangerous, it must [6] be disposed of only through the D9 or D10 methods, and never through D1.

Here is where the controversies start…

The controversy concerning the classification of sterilized waste

One of the situations met in Romania which is in violation with the environmental legislation is the classification of the sterilized waste, resulting from low-temperature thermal treatment of medical waste (D9 above) under the 18 01 04 code.

This slip was also noted in the Order of the MoH 1226/2012, Art. 8, parag. 2) contradicting GD 856/2002. The latter stipulates that waste resulting from operations for the treatment of residues of any nature shall be coded 19 02 03 or 19 02 04* and not 18 01 04.

18 01 04 coding is generally used by hospitals under the Ministry of Health operating with sterilizers, to eliminate the sterilized waste by means of disposal.

Municipal or industrial waste landfills, however, do not hold this code in the environmental authorization, and that is why hospitals are forced to use codes of the 20 group to ensure the final disposal of the sterilized waste.

The controversy of disposable diapers

Another non-compliant situation with the legislation is the direct disposal of disposable diapers generated by hospitals in the landfill. These diapers were used by children, elderly or patients subject to surgical interventions of the urinary tract. Usually, this waste is wrapped in black bags, as per art. 30 of the Order of the Minister of Health 1226/2012.

Although this type of waste must be treated through D9 or D10 operations prior to disposal, the tender books for public acquisition procedures drafted by certain public hospitals explicitly require packaging, collection and disposal of disposable diapers for D1 operations, as a non-dangerous waste, without any kind of prior treatment.

If the 18 01 04 classification would have been used correctly, no landfill in Romania would be able to accept this waste without being pre-treated, as medical waste, of whatever nature, cannot be deposited in landfills without prior processing, except refuse waste.

This practice has become possible after the Order of the MoH no. 219/2002 – “Guidelines on the management of waste resulting from medical activities” was replaced. It stipulated that waste classified as 18 01 04 should also be treated by incineration or thermal sterilization, alongside all the other types of clinical waste. However, the Order of the MoH 219/2002 was replaced with Order of the MoH 1226/2012, while disposable diapers often end directly in landfills, most likely for budget-related reasons.

Instead of conclusion

All types of medical waste generated by a hospital should be treated through one of the D9 or D10 methods, prior to being discarded in landfills.

It is likely we will discover cases of biologically contamination of landfills which receive such medical waste without prior treatment and, consequently, the of the underwater.

It is possible that the methods used to cover the budgetary deficit will have an impact not only in terms of environmental protection, but also on human health in its entirety. Only a coherent collaboration between the state’s authorities will be able to lead to a review, enforcement and follow-up on the enforcement and compliance with the legislative provisions.


[1] as per GEO  78/2000, Annex I E.

[2] Disposal of all types of medical waste must only be achieved through one of the operations allowed by Annex II A, of GEO 78/2000

[3] Correct coding is 19 02 03, as per GD 856/2002.

[4] Ash is coded 19 01 11 or 19 01 12

[5] Depending on the test reports which will determine their classification, as per Order MMGA No. 95/2005

[6] As per Order of the MoH no. 1226/2012, Art. 45, parag. c