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Hi Geoff My impression, from your response, is that you feel that " ..or for free" implies that they are still being put on the market and therefore need to be dealt with under the exceptions section. Our interpretation, which many others adhere to, is that these devices are provided 'on loan', remainig the property of the NHS. Obviously documentation relating to this should be provided to the patient/client at the time of delivery. Under these circumstances the devices are not being put on the market and are therefore not covered, and therefore need to comply with local policies for the decommissioning equipment. cheers Jeremy > > > Hi Graham. > > I have a draft consultation paper from the department of Trade and > Industry, Publication Number URN 04/1335. > > It contains the WEE and RoHS directives, DTI guidance on the > implementation and some impact assessments etc. I am not sure if it > is the latest version. > > On page 9, Definitions - 22. it says producer responsibility will > fall on those persons which put equipment ----- "on the market". > > in 23. it defines "put on the market" as "-------- either for payment > or free of charge." > > But, > > PAge 7, guidance on specific exemptions includes "Implanted medical > equipment and infected medical equipment - applies to all medical > equipment that has been implanted or has otherwise come into contact > with blood or other biological contaminants prior to end of life". > > From my point of view anything that has been on a wheelchair is likely > to have been contaminated by something at some point. > > I am wondering if I need to register, but won't have a quota to meet? > > One of the options seems to be to inform your management team of the > existence of the regulations and to formally ask them for instruction > on how to proceed, its their problem then. At the same time, include > in your user instructions/documentation - information requiring them > to return the equipment to yourselves when no longer needed. RS > Components sell the little wheely bin labels as do Farnell. > > I have yet to explore all of the routes to compliance myself, but I do > know of this company who seem to recycle everything. > > _http://www.sims-group.com/uk/home/_ > (http://www.sims-group.com/uk/home/) > > I am wondering if I can make an agreement with them or someone like > them to let me post my WEEE to them for a nominal fee. > > I also intend to contact my local council and see what they are doing > about this. > > Its a bit like the Medical Devices Directive, we shouldn't really try > and avoid it I suppose. > > Geoff Harbach > LEPMIS > > > > > > In a message dated 26/04/2006 15:42:42 GMT Daylight Time, > [log in to unmask] writes: > > Dear all, > > We custom-make a small number of electronic assistive technology > devices per year for clients of our service. > > As we don't sell these devices it's my feeling that we shouldn't need > to register as a 'producer' (as defined in the WEEE Directive), and > be subject to all the rigmarole and cost associated with producer > responsibility. > > How do other NHS deparments who custom-make electronic devices > interpret the directive? > > If we don't have to register, the tiny amount of recovered > end-of-life custom-made electronics can probably be disposed of via > other available hospital disposal channels. > > I know that WEEE has not yet been incorporated into English law, but > it is only a matter of time. > > > Graham Newiss > > Chief Technician > Dept of Medical Physics and Clinical Engineering > Barnsley Hospital NHS Foundation Trust > > [log in to unmask] > > > > > > > > Jeremy Linskell CEng,MIPEM,SRCS Clinical Engineer Co-ordinator, Electronic Assistive Technology Service Tayside Orthopaedic and Rehabilitation Technology Centre Ninewells Hospital, Dundee, DD1 9SY, Scotland tel +1382-496286, fax +1382-496322 email: [log in to unmask] (backup email: [log in to unmask])