Medical waste is a daily compliance duty, not a one-off opening task for a clinic. Circular 20/2021/TT-BYT governs the whole waste chain inside a medical facility: segregation at the point of generation, colour-coded packaging, storage in a dedicated area within time limits, and handover to an operator licensed for the relevant treatment. For FDI clinics and hospitals, a group’s international operating standards do not replace Vietnam’s segregation and transfer-document rules, and this is exactly where inspectors look hardest.
Segregation at source: the first step that decides the legality of the whole chain
Under Circular 20/2021/TT-BYT, waste in a medical facility must be segregated where and when it arises into the main groups: hazardous waste comprising infectious waste, sharps, chemical waste and radioactive waste; general waste; and recyclable waste. Each group has its own prescribed packaging, containers and identification colours, with sharps placed in dedicated puncture-resistant boxes. Segregating wrongly at the start, for example putting blood-soiled dressings into the general bin, cross-contaminates the whole bag and turns a small lapse into a hazardous waste management violation.
Segregation responsibility lies with the person generating the waste in each procedure, so the facility must train and audit regularly rather than merely posting a chart on the wall. In an FDI facility with foreign doctors and staff, internal training materials should be bilingual, with sorting charts at every generation point from procedure rooms to the laboratory. Training and internal audit records are the first compliance evidence an inspection team asks to see.
Storage, handover and the contract with a licensed treatment operator
After segregation, waste is collected into the facility’s dedicated storage area: it must be separated, warning-signed and hygienic, and hazardous waste may be stored only for a short prescribed period before handover, with infectious waste needing early treatment to avoid odour and pathogen risks. A small medical facility does not treat hazardous waste on site by casual burning or burial; unauthorised burning or burying of medical waste is prohibited conduct and a serious hazardous waste violation.
The standard lawful route is a transfer contract with an operator whose environmental licence covers the corresponding hazardous waste treatment function, with a hazardous waste manifest for each transfer kept on file for inspection. When selecting a contractor, an FDI hospital should verify that the operator’s licence scope actually covers its medical waste codes, because a contract with an under-scoped operator does not protect the waste generator if an incident occurs in transport or at the treatment site.
Common violations and how to build a durable compliance system
Recurring violations in practice include: no segregation or segregation into the wrong group; storing hazardous waste beyond the allowed period; lacking a dedicated storage area; handing waste to an operator without a suitable licence; and missing transfer manifests to prove where the waste went. Each act can draw administrative fines under environmental and health law, with amounts depending on waste type, volume and the nature of the conduct under the current schedule; serious cases can also suspend the waste-generating operation.
A durable compliance system has four auditable components: a written segregation procedure in each department; a current treatment contract with a properly licensed operator; complete volume logs and transfer manifests for every handover; and a named waste management officer in the facility’s structure. These four components are also the waste content of the facility’s environmental permit or registration file, so building them together keeps an FDI facility from having environmental paperwork that says one thing and operations that do another.
Frequently Asked Questions
How must medical waste from FDI clinics and hospitals be treated?
Under Circular 20/2021/TT-BYT: segregate at source into hazardous, general and recyclable groups; package in the prescribed bags and colours; store in a dedicated area within the allowed period; and hand over to a suitably licensed treatment operator with hazardous waste manifests. The facility must not burn or bury medical waste itself.
Must the facility contract a waste treatment company?
Yes, for the hazardous fraction: medical waste must be transferred to an operator whose licence covers the corresponding hazardous waste treatment, under a contract with manifests for each transfer. This is the evidence that waste was lawfully treated when regulators inspect.
How is medical waste classified?
At source into hazardous waste (infectious, sharps, chemical, radioactive), general waste and recyclable waste, using the prescribed packaging and identification colours under Circular 20/2021/TT-BYT. Sharps must be kept in dedicated puncture-resistant containers.
What are the penalties for violations?
Medical waste violations attract administrative fines under environmental and health law, with amounts depending on waste type, volume and the nature of the conduct under the current schedule; serious cases may suspend the violating operation. The schedule in force at the time of the violation should be checked for each specific case.
This article has been quality-reviewed by the FLAW AI Legal Council