Medical waste: Auditor-General must investigate failing management accounting function
29 January 2016
Today I write yet another letter to the, Auditor-General, Mr. Thembekile Makwetu to request that, in his scrutiny of the financial affairs of the medical waste disposal industry, he investigates the management accounting function designed to ensure that medical waste is disposed of properly – and, for public health reasons, with rigorous fidelity.
The DA’s visits to 11 hospitals in the Free State, Eastern Cape, Gauteng, Northern Cape and Mpumalanga revealed that the management accounting function was not consistently working, with the consequence that hospital management was not always certain that medical waste was disposed of properly.
This is how it should work: the originator of waste – the hospital - has legal custody over it (the waste) from ‘cradle to grave’. The approved regulatory administrative requirements - to which the hospital chief executive officer (CEO) must be held accountable - involves what is known as a ‘closed loop system’.
A Waste Collection Document (WCD), also known as a tracking document, a waste manifest or a dangerous goods declaration, signed to confirm that the correct separation and storage procedure were followed, from (a) point of generation; (b) whilst in transport; (c) at treatment facility; and when (d) final disposal takes place.
After final disposal, to close the loop, the WCD’s Safe Disposal Certificate (the WCD pink form) is returned, at month’s end with the medical waste removal company’s invoice, to the originating hospital, which is then filed together with the WCD’s white form that was signed and kept when the waste originally left the hospital.
Some of the hospitals we visited maintained such a system; others did not; yet others refused to let us inspect the paperwork; and finally, some refused access to the hospital itself. An insider in the private healthcare sector wrote that while it was much better at this than the public sector, ‘I am not sure that we always got that right’.
It is an extraordinary failure of management that the ‘closed loop system’ is not consistently maintained and that there are no independent assessors or inspectors to ensure that it (management) does. And it this breakdown that creates the opportunity for two heinous practises to emerge.
First is unpunished medical waste dumping, for which the Free State has become notorious. When the ‘closed loop system’ is not closed off, hospital CEOs do not even know that their waste has not been disposed of properly. And once waste is dumped, it is difficult to trace it back to its source. No one can be held accountable.
Second is the growth of a black market for placentas – and other anatomical waste – that end up being used for dubious healing practises. We had a glimpse of this once, in 2007, when a cleaner at a Durban hospital was charged under the Human Tissues Act for stealing a placenta and selling it on for R500 to the police masquerading as a body parts’ syndicate.
An industry insider said that it was ‘an ongoing challenge to safeguard placentas before final disposal’, both in the hospital (anatomical waste is normally stored in mortuaries or a special refrigerated room) and when in the possession of the medical waste removal companies. The problem is likely bigger than we think.
It is of the greatest importance for the Auditor-General to examine the failures of, and the Department of Health to remedy with immediate effect the dysfunctional elements of the ‘closed loop system’ because public confidence in the biosafety of our health-care institutions must be secured.
Statement issued by Dr Wilmot James MP, DA Shadow Minister of Health, 29 January 2016
