Safe Waste and Sharps Management in Residential Long-Term Care in Viet Nam: Appropriate Segregation, Worker Protection and Accountable Disposal

Safe Waste and Sharps Management in Residential Long-Term Care in Viet Nam: Appropriate Segregation, Worker Protection and Accountable Disposal

A care worker at a residential long-term care facility discovers a used needle inside a waste bag while helping prepare an older resident's room for cleaning. The resident receives regular treatment from an external healthcare provider, but the care team does not know who performed the most recent procedure or how the needle ended up in the bag.

The worker stops handling the waste and informs the supervisor. Preventing an injury is the immediate concern, but the discovery raises several questions. Who was responsible for disposing of the needle? Was a suitable sharps container available when the procedure was performed? Had the visiting healthcare provider and residential facility agreed on how the resulting waste would be managed?

There is also concern about what might already have happened. If the bag had been collected by cleaning staff, the needle could have injured someone who had no reason to expect it.

This situation illustrates a problem that can arise when residential care and healthcare activities take place in the same environment. A needle placed in the wrong waste stream may reflect an individual error, but it may also reveal unclear responsibilities between care workers, visiting clinicians, cleaning personnel, and facility management.

Residential long-term care generates different types of waste. Accommodation and personal care produce everyday materials, while some residents receive medical treatment or use devices that generate sharps, contaminated supplies, or other potentially hazardous waste.

For providers in Viet Nam, safe waste management begins with understanding what is being discarded, where it was generated, which legal requirements apply, and who is responsible for handling it.

A reliable system protects residents, care workers, cleaners, waste contractors, and the environment without automatically treating everything associated with older-person care as hazardous medical waste.

Residential Care Generates Different Types of Waste

A residential care facility is also a place where people live.

Meals, housekeeping, laundry, personal hygiene, and ordinary daily activities generate waste similar to that produced in other residential environments. Depending on the services offered, the facility may also encounter materials associated with medication use, clinical procedures, rehabilitation, and medical devices.

Some activities are performed by the facility's own employees. Others may involve visiting healthcare professionals, external contractors, or residents who independently manage aspects of their treatment.

Different waste streams may therefore exist within the same building.

Food packaging and ordinary household materials may be discarded alongside used personal hygiene products. A visiting clinician may generate needles, dressings, or disposable clinical supplies. Maintenance activities may produce batteries, electrical components, or chemical products requiring different handling arrangements.

The fact that these materials originate from the same premises does not make them legally equivalent.

Waste classification depends on the material's characteristics, the activity that generated it, relevant contamination or hazardous properties, and the applicable regulatory framework.

Incorrect classification creates risks in both directions. Hazardous waste entering an unsuitable stream may expose workers and others to injury, infection, or harmful substances. Conversely, unnecessarily classifying ordinary materials as hazardous can increase costs, complicate collection, and create avoidable environmental burdens.

For residential care organizations, the starting point is to understand the waste their activities actually generate rather than assume that one classification applies to everything.

Why Correct Segregation Matters

The World Health Organization's Health-Care Waste fact sheet, updated in October 2024, estimates that approximately 85% of waste generated by healthcare activities is general, non-hazardous waste. The remaining 15% is considered hazardous because it may present infectious, chemical, radioactive, or other risks.

These figures describe healthcare waste at a broad international level. They should not be interpreted as measured proportions for residential long-term care facilities in Viet Nam.

Nevertheless, they illustrate why segregation matters.

Healthcare-related environments can generate substantial quantities of ordinary waste alongside smaller quantities requiring specialized handling.

WHO's handbook Safe Management of Wastes from Health-Care Activities identifies segregation at the point of generation as a fundamental part of safe waste management.

When hazardous material is mixed with ordinary waste, the resulting mixture may require more demanding handling or treatment. Conversely, placing non-hazardous materials into a specialized hazardous waste stream may consume resources without providing a corresponding safety benefit.

The solution is not simply to provide more containers.

Workers need to understand what belongs in each waste stream, and suitable containers must be available where the materials are generated. The classification and handling arrangements must also reflect Vietnamese law rather than relying solely on practices adopted elsewhere.

For example, a container color or label used in another country should not automatically be presented as a Vietnamese legal requirement.

Segregation begins with correct classification and continues through collection, storage, transfer, and final disposal. If any part of that process is poorly organized, the benefits of separating waste at the source may be lost.

Personal Care Waste Is Not Automatically Infectious Medical Waste

Many older residents need assistance with bathing, dressing, continence care, and other daily activities.

These services may generate used tissues, disposable personal care products, absorbent materials, and other hygiene-related waste.

Such items may be unpleasant to handle or require careful hygiene precautions. However, those characteristics alone do not establish that every item is legally classified as infectious medical waste.

Classification must consider the material's actual characteristics, relevant contamination, the activity that generated it, and the applicable legal requirements.

Ordinary personal hygiene waste arising in a residential social assistance facility should therefore not automatically be assigned the same classification as infectious clinical waste generated during regulated healthcare activities.

The opposite assumption would also be unsafe.

A material should not be considered harmless merely because it arose during an activity described as personal care. Relevant infectious contamination, hazardous characteristics, or circumstances requiring additional infection prevention precautions may affect how it must be managed.

Facilities should avoid relying on broad assumptions in either direction.

Where classification is uncertain, management should obtain advice from appropriately qualified healthcare waste, infection prevention, environmental, or regulatory professionals.

A resident's condition may also change. During an infectious disease outbreak or when particular precautions become necessary, the organization may need to reassess its handling arrangements.

This illustrates an important distinction: safe hygiene practice and legal waste classification are related, but they are not identical.

A material may require careful handling to protect workers without necessarily falling within a particular category of regulated medical waste.

For residential care providers, the practical challenge is to maintain appropriate hygiene safeguards while applying the correct classification and disposal requirements.

Sharps Require Particular Attention

Used needles and other sharp instruments create risks that may be difficult to recognize once they have been discarded.

Needles, lancets, scalpel blades, and certain other pointed or cutting instruments can cause injuries when handled incorrectly.

Where a sharp has been contaminated with blood or other potentially infectious material, an injury may also involve occupational exposure to bloodborne pathogens.

A needle hidden inside an ordinary waste bag can injure a care worker, cleaner, laundry employee, or waste collector who has no reason to expect it.

The hazard does not disappear because the needle has been placed in a bag.

International guidance from WHO and the United States Centers for Disease Control and Prevention emphasizes suitable sharps containment, minimizing unnecessary handling, and making appropriate disposal containers available close to where sharps are used.

The general prevention principle is to place used sharps into an appropriate container at the point of generation rather than leaving them on nearby surfaces or mixing them with ordinary waste.

Unnecessary handling, including attempts to manipulate or separate used sharps, can introduce additional risks.

For activities governed by Vietnamese medical waste regulations, requirements concerning container design, puncture resistance, labeling, color coding, and subsequent handling must be followed.

Foreign technical specifications should not be substituted for Vietnamese requirements without establishing their legal and technical suitability.

A residential care organization should also recognize that sharps may be generated by someone outside its own workforce.

A resident may independently use prescribed injectable treatment. A visiting nurse may perform an authorized procedure. An external healthcare organization may provide treatment within the facility.

Understanding who generated the sharp, the circumstances of its use, and the applicable waste-management arrangement is important when determining the responsibilities involved.

When Residents Use Needles or Lancets for Their Own Care

Some older residents use prescribed medicines or medical devices involving needles or lancets.

Depending on their abilities and lawful care arrangements, they may manage certain activities independently, receive assistance from appropriately qualified healthcare professionals, or require another authorized form of support.

A residential care facility should understand whether these activities generate sharps and how the resulting waste will be managed safely.

This does not mean that every resident using injectable treatment must surrender responsibility for their treatment or equipment to the facility.

Some people remain capable of managing their medicines and devices independently.

However, the surrounding environment should not expose other residents, care workers, cleaners, or visitors to avoidable injuries.

The facility should not assume that used needles can enter ordinary household waste merely because the resident manages the treatment independently.

Nor should a non-medical facility assume that agreeing to manage the waste authorizes its employees to perform the underlying clinical procedure.

Medication administration and waste management are connected but distinct responsibilities.

Treatment must be provided under appropriate clinical and legal arrangements. The resulting waste must then be managed according to its characteristics and the applicable legal requirements.

Where the facility lacks the capability or lawful arrangements to manage a particular waste stream, an appropriate solution involving a suitably authorized provider may be necessary.

These arrangements should be clarified before the activity becomes routine, rather than after an exposed needle is discovered in an unsuitable location.

For residents who independently manage their treatment, communication should also be respectful and practical. The facility needs to protect the shared environment without unnecessarily restricting personal autonomy.

Visiting Healthcare Professionals Need Clear Waste Responsibilities

External healthcare professionals may visit residential facilities to assess or treat older residents.

These services can improve access to healthcare, particularly when residents have difficulty traveling to clinics or hospitals.

However, clinical visits may introduce waste streams that differ from those generated by ordinary residential care.

A procedure may involve needles, dressings, disposable instruments, clinical supplies, or other materials requiring specific handling.

The healthcare provider should understand the waste generated by its activities and the legal obligations applicable to its services.

The residential facility, meanwhile, needs to understand whether it has responsibilities concerning temporary storage, collection, transfer, access, or coordination.

These arrangements are best clarified before a procedure takes place.

It is unsafe to assume that the visiting professional will remove all clinical waste unless that responsibility has been established.

It is equally unsafe to assume that the residential facility can place all materials left behind into its ordinary waste collection system.

The allocation of responsibilities depends on the healthcare activity, the legal status of the provider, where and how the waste is generated, the applicable environmental requirements, and any lawful agreements between the parties.

A contract can clarify operational responsibilities, but it does not automatically transfer or eliminate obligations imposed by law.

For facilities that regularly coordinate external healthcare services, waste management should be included in the arrangements governing those services.

The relevant parties need to understand who supplies suitable containers, who performs segregation, whether waste may lawfully remain on the premises, and how collection, transfer, or disposal will be organized.

Clear responsibilities help prevent hazardous materials from being left for unprepared care workers or cleaners to handle. They also reduce the likelihood of disagreement after an incident has occurred.

The presence of a healthcare professional does not automatically resolve every waste-management question. The relevant arrangements need to work across the entire process, including after the professional has completed the visit.

Understanding the Scope of Viet Nam's Medical Waste Regulations

One of the most important legal distinctions concerns the difference between a residential social assistance facility and a healthcare establishment.

Ministry of Health Circular No. 20/2021/TT-BYT, issued on November 26, 2021, and effective January 10, 2022, regulates medical waste management within the premises of healthcare establishments.

Articles 1 and 2 establish its scope and subjects.

The Circular covers relevant healthcare establishments, including licensed medical examination and treatment facilities, preventive medicine facilities, and specified health-sector education, research, testing, and related establishments generating medical waste.

It also applies to organizations and individuals involved in medical waste management within the defined regulatory framework.

The Circular contains requirements concerning classification, segregation, collection, storage, reduction, recycling, transfer, and organizational responsibilities.

These provisions are important, but their legal scope must be respected.

A residential social assistance facility does not automatically become a licensed healthcare establishment simply because its residents have chronic diseases or receive medical treatment.

At the same time, an organization cannot disregard relevant waste-management duties merely because its primary activity is described as social care.

Some residential facilities may operate licensed healthcare services. Others may coordinate with external healthcare providers or undertake defined responsibilities involving waste generated by those providers.

The applicable obligations must be determined according to the activities actually performed and the legal relationships involved.

Circular 20 should therefore not be used as a basis for classifying all waste generated in every residential care facility as medical waste.

Nor should its scope be interpreted as permission to dispose of genuinely hazardous materials through an unsuitable ordinary waste pathway.

Where medical waste is generated outside the premises of a healthcare establishment, the relevant duties and arrangements also require careful examination of the applicable environmental, healthcare, and other legal provisions. The Circular's rules for waste management within healthcare premises should not automatically be extended to every external care setting without establishing their applicability.

Correct classification and clear coordination between service providers are essential to developing a lawful and practical system in Viet Nam.

Identifying Waste Before Choosing Containers

Facilities sometimes begin waste improvement projects by purchasing additional bins, introducing new labels, or changing collection schedules.

These measures may be useful, but they should follow an assessment of the waste generated and the legal requirements that apply.

The organization should first identify the activities performed on its premises.

These may include accommodation, meal preparation, personal assistance, cleaning, maintenance, medication-related support, and authorized healthcare services.

The resulting waste streams can then be assessed under the relevant Vietnamese legal instruments.

Some materials will be straightforward to identify. Others may require technical or legal clarification, particularly where pharmaceuticals, chemicals, sharps, contaminated materials, or hazardous electrical components are involved.

Similar-looking items may require different management because of the activities that generated them or their hazardous characteristics.

A dressing discarded after a clinical procedure, for example, may need different handling from an ordinary household hygiene product.

The correct classification should not depend solely on broad descriptions such as clinical waste or care waste.

These terms may be used differently in international guidance and may not correspond directly to Vietnamese regulatory categories.

Where several types of service operate on the same premises, the facility should establish arrangements that keep relevant waste streams appropriately separated.

Risk assessment can support these decisions, but it does not replace legally required classification.

The purpose is to establish a system that staff can understand and use consistently, while ensuring that the requirements attached to each waste stream are correctly identified.

Suitable Containers Must Be Available Where Waste Is Generated

Once the waste streams have been identified, suitable containers need to be available at appropriate locations.

General waste may be managed through ordinary collection arrangements, while materials with hazardous characteristics may require specialized packaging, containers, or handling procedures.

Sharps require containers designed to reduce puncture hazards and unintended access.

Placement matters as much as the type of container.

If a suitable sharps container is not available near the location where a procedure is performed, staff may be tempted to place used instruments temporarily on furniture or in another unsuitable location.

Conversely, a container holding hazardous materials should not be positioned where residents, visitors, or other unauthorized persons can easily interfere with it.

The appropriate arrangement depends on the activity, the people nearby, and applicable technical requirements.

Containers also need maintenance and replacement.

Damaged, leaking, unstable, or unsuitable containers can create hazards despite being correctly labeled.

The organization should understand who supplies the containers, who checks their condition, and when replacement is necessary.

For waste subject to Circular 20/2021/TT-BYT, specific provisions concerning packaging, containers, labeling, and color coding must be followed where applicable.

However, a residential care facility should not simply copy container colors or labels used in another country and present them as Vietnamese legal requirements.

A classification and containment system is useful only when the selected equipment matches the waste involved and the relevant regulatory framework.

Collection and Temporary Storage Need Safe Arrangements

Correct segregation can be undermined during collection.

Waste may be mixed with another stream, transferred into an unsuitable container, or moved through areas where residents and others could be exposed unnecessarily.

Facilities should consider how waste moves from the point of generation to the designated collection or storage location.

The arrangement should reflect the building layout, type and quantity of waste, collection frequency, and people who may be affected.

Collection schedules may need to avoid unnecessary disruption to meals, personal care, or other resident activities.

Where hazardous or potentially infectious waste is involved, appropriate containment and handling requirements must be followed.

Workers should not be expected to sort mixed waste manually after collection merely to correct preventable segregation errors.

Additional handling may expose them to hazards that should have been controlled earlier.

Temporary storage also deserves attention.

Some waste may remain on the premises before collection or transfer. The conditions required depend on its classification and the legal obligations applicable to the facility.

Storage arrangements should address leakage, environmental contamination, unauthorized access, and potential exposure to residents or workers.

A room suitable for ordinary waste should not automatically be considered suitable for every hazardous material.

Medical waste generated by healthcare establishments within the scope of Circular 20/2021/TT-BYT is subject to specialized storage requirements.

These should not be converted into a single universal storage timetable for every waste stream produced by residential care facilities.

Management should establish who checks storage conditions, responds to problems, and ensures that collection occurs through appropriate arrangements.

A written policy provides little protection if containers routinely accumulate beyond the facility's safe capacity because collection services are unreliable.

Protecting Care Workers, Cleaners, and Waste Handlers

Waste management involves people with different responsibilities and levels of training.

Care workers may encounter discarded materials while assisting residents. Cleaning personnel may collect ordinary waste and identify unexpected hazards. External contractors may transport or process waste under separate arrangements.

Each group needs information and safeguards appropriate to the hazards encountered.

Workers should understand which materials they are expected to handle, which containers to use, and when a situation falls outside their responsibilities.

Training should cover recognition of inappropriate disposal, relevant safe handling practices, reporting concerns, and obtaining assistance.

The level of training should reflect the work actually performed.

A cleaner assigned to ordinary waste collection should not be expected to manage hazardous clinical materials without suitable competence, equipment, and authorization.

Similarly, a care assistant should not be asked to dismantle used medical devices or manipulate discarded sharps to make them easier to dispose of.

Personal protective equipment may be necessary for particular activities, but it should be selected according to the hazard and applicable requirements.

Gloves alone do not make every waste-handling activity safe.

Suitable containers, work organization, training, supervision, and clear professional boundaries are also important.

The facility should consider contracted cleaning and waste-handling personnel as well as its direct employees, while recognizing that the legal responsibilities of different employers and service providers may not be identical.

Effective protection reflects the people who actually perform the work rather than assumptions about who is responsible.

Responding to Sharps Injuries and Suspected Exposure

A sharps injury may involve puncture, bleeding, or exposure to potentially infectious material.

An injured worker needs prompt assessment through an appropriate occupational exposure pathway by qualified healthcare professionals.

The worker should not be expected to determine independently whether a bloodborne infection exposure has occurred or whether preventive treatment is necessary.

The required assessment may depend on the device, circumstances of the injury, and available clinical information.

Some exposures require time-sensitive professional decisions concerning post-exposure prophylaxis or further investigation.

Organizations should therefore establish how staff can obtain appropriate medical assessment, including outside ordinary working hours where relevant.

If the injury involves a sharp discovered in ordinary waste, the facility should also consider whether other waste in the affected area presents an ongoing hazard.

Immediate protection takes priority over administrative documentation.

Nevertheless, the incident should be recorded accurately, and relevant information should be preserved.

A subsequent review should examine how the sharp entered the wrong waste stream, whether a suitable container was available, and whether responsibilities between staff and external providers were clearly established.

The review should not automatically assume that the injured worker caused the problem simply because they encountered the item.

Near misses also deserve attention.

Discovering an exposed needle before an injury occurs may reveal the same underlying weakness that could otherwise result in harm.

The purpose of reviewing such events is to improve the system while maintaining appropriate accountability for any unlawful or unsafe conduct.

Medicines and Pharmaceutical Waste Require Separate Consideration

Residential care facilities may encounter unused medicines, expired products, damaged packaging, discontinued treatments, or medicines remaining after a resident has moved or died.

These materials should not automatically be discarded with ordinary waste or transferred to another resident.

The appropriate management pathway depends on the medicine, its characteristics, the activity involved, and applicable law.

Certain hazardous pharmaceutical products and controlled medicines may require additional safeguards.

The organization should establish who is responsible for identifying medicines that are no longer required and arranging their lawful management.

This is different from making the clinical decision to discontinue treatment.

Care workers should not independently decide that prescribed medication is unnecessary or dispose of it because its packaging appears old.

Where a pharmacy, licensed healthcare establishment, or other authorized provider is involved, the relevant arrangements should be clarified.

Facilities should not assume that every retail pharmacy is legally required or equipped to accept every category of unwanted medicine.

Nor should they attempt informal destruction, redistribution, or disposal without a suitable legal and technical basis.

The purpose is to prevent unauthorized access, inappropriate reuse, accidental exposure, or the release of pharmaceuticals into unsuitable waste streams.

Pharmaceutical waste management should remain connected to medication governance while being distinguished from prescribing and clinical decision-making.

Chemical, Battery, and Technical Waste May Follow Different Rules

Waste generated by residential care organizations is not limited to personal care and healthcare-related materials.

Maintenance may produce batteries, electrical components, damaged equipment, or chemical products.

Cleaning, disinfection, and pest-control activities may also involve substances with particular hazardous characteristics.

These materials need to be assessed under the applicable environmental and, where relevant, chemical safety framework.

Viet Nam's Law on Chemicals No. 69/2025/QH15 took effect on January 1, 2026. Its requirements apply according to the chemical substances and activities involved, alongside relevant amendments and implementing regulations.

However, the presence of ordinary household cleaning products does not automatically mean that every discarded container or cleaning material is legally classified as hazardous waste.

The nature of the substance, hazardous characteristics, quantities, uses, and applicable waste classification requirements matter.

Facilities should obtain appropriate technical advice where the disposal route is uncertain.

Workers should not mix incompatible chemical wastes, reuse unsuitable containers, or attempt improvised treatment merely to reduce disposal costs.

Different waste streams may require different contractors, records, and safeguards.

Accurate classification helps avoid both unsafe handling and unnecessary application of requirements designed for other materials.

Choosing Waste Contractors and Defining Responsibilities

Many residential care organizations rely on external contractors to collect, transport, or treat waste.

This can provide access to specialized equipment, suitable transport arrangements, and lawful treatment capacity.

However, outsourcing waste management does not eliminate the need to understand the service being purchased.

A contractor collecting ordinary solid waste should not automatically be assumed to have the authorization or technical capacity to manage hazardous waste.

Similarly, a company's advertisement for medical waste collection does not, by itself, establish that it holds every authorization required for the waste involved.

The facility should verify relevant legal status, environmental authorizations where applicable, waste categories accepted, and the scope of the proposed service.

The agreement should clarify responsibilities for packaging, temporary storage, collection, transport, transfer documentation, treatment, and incident response, as appropriate.

These arrangements must remain consistent with applicable law.

For healthcare establishments within the scope of Circular 20/2021/TT-BYT, Article 12 contains provisions concerning the transfer of medical waste and related documentation.

The Circular distinguishes relevant arrangements for hazardous medical waste from those applicable to ordinary solid waste.

These specialized provisions should be applied according to the actual waste and legal circumstances.

A residential facility should not treat a signed collection receipt as conclusive evidence that every downstream legal obligation has been fulfilled.

At the same time, it should not assume responsibility for activities legally assigned to a separate waste-management operator without examining the relevant law and agreement.

Accountability requires understanding each party's responsibilities and establishing an appropriate level of verification.

Waste Handover Should Be Traceable Where Required

A facility may know that waste has been collected without having clear information about its classification, quantity, receiving organization, or the documentation required for transfer.

For regulated waste streams, these gaps can create compliance and safety concerns.

The relevant records should establish what waste was transferred, to whom, under which legal or contractual arrangement, and what documentation was required.

The level of detail depends on the waste category and applicable law.

Ordinary waste collection may follow different arrangements from regulated hazardous waste management.

Facilities should therefore avoid applying identical documentation requirements to every waste stream without considering their purpose.

For hazardous waste, applicable records may support traceability through the legally prescribed management process.

Where specialized medical waste provisions apply, additional records may be required.

The organization should also know what happens when a transfer cannot proceed.

A contractor may refuse collection because the waste is incorrectly segregated, a container is damaged, or required documentation is incomplete.

Such situations should not result in waste being abandoned in an unsuitable location or moved into another stream merely to clear space.

The responsible parties need to arrange a safe and lawful response.

Traceability matters because waste management does not end when material leaves a resident's room or the facility's premises.

Viet Nam's Environmental Protection Framework in 2026

Waste management in residential long-term care operates within Viet Nam's environmental protection legislation.

The Law on Environmental Protection No. 72/2020/QH14, as amended, establishes the overarching framework for waste management, environmental responsibilities, and related activities.

Its amendments include changes introduced by Law No. 146/2025/QH15, which took effect on January 1, 2026.

Government Decree No. 08/2022/ND-CP provides detailed implementing provisions.

The decree has been amended by Decree No. 05/2025/ND-CP and Decree No. 48/2026/ND-CP, together with other applicable changes.

Decree No. 48/2026/ND-CP was issued and took effect on January 29, 2026.

Ministry of Natural Resources and Environment Circular No. 02/2022/TT-BTNMT provides additional implementation requirements, including provisions relevant to waste management.

The Circular has been amended by subsequent instruments, including Circular No. 07/2025/TT-BTNMT, Circular No. 07/2025/TT-BNNMT, and Circular No. 09/2026/TT-BNNMT, together with other applicable changes.

Circular No. 09/2026/TT-BNNMT took effect on January 29, 2026.

These developments matter because current waste classifications, procedures, and competent authorities must be determined from the legal provisions in force.

Organizations should not rely solely on the original 2022 versions when establishing or reviewing their waste-management arrangements.

The Law on Occupational Safety and Hygiene No. 84/2015/QH13, as amended, also provides a relevant framework for protecting workers exposed to waste-related hazards.

Other provisions may apply to pharmaceuticals, chemicals, public sanitation, environmental authorizations, and specialized waste-management activities.

The obligations depend on the facility's legal status, activities performed, and materials generated.

Residential care providers should therefore identify which requirements apply to each relevant waste stream rather than assume that one general policy or regulation covers every circumstance identically.

Applying Circular No. 20/2021/TT-BYT Correctly

Circular No. 20/2021/TT-BYT remains an important instrument governing medical waste management within its defined scope.

It addresses classification, segregation, collection, storage, reduction, recycling, transfer, and management of medical waste associated with relevant healthcare establishments.

Its requirements should be interpreted according to Articles 1–2 and the other applicable provisions.

A residential social assistance facility is not automatically a healthcare establishment merely because its residents have medical conditions or require assistance with daily living.

However, a residential provider operating licensed medical services may have obligations associated with waste arising from those activities.

An external healthcare organization providing treatment on residential premises may also have relevant responsibilities, depending on how the services are delivered and the legal arrangements involved.

Where the residential facility itself participates in managing medical waste, the applicable duties should be clarified.

It would be incorrect to claim that every used personal hygiene product generated in residential care must follow the full medical waste pathway under Circular 20.

It would be equally incorrect to conclude that a contaminated needle may enter ordinary waste simply because the premises are primarily used for social assistance.

The relevant questions are what the material is, how it was generated, which hazards it presents, and which legal framework governs its management.

Accurate classification and coordination between the relevant parties are essential to answering those questions.

The Forthcoming Regulatory Framework for Social Assistance Facilities

Government Decree No. 395/2026/ND-CP was issued on October 23, 2026, concerning the operation and management of social assistance facilities.

It is scheduled to take effect on December 7, 2026.

As of November 3, 2026, Decree No. 103/2017/ND-CP, as applicable and amended, remains part of the current framework for facilities within its scope.

Decree 395 establishes updated provisions for specified social assistance facilities, including certain services supporting older people.

These provisions are relevant to facility management, service safety, and organizational responsibilities.

However, Decree 395 should not be interpreted as replacing environmental protection legislation or specialized healthcare waste requirements.

Nor does its issuance automatically mean that every social assistance facility must operate under the same medical waste rules as a licensed hospital.

Organizations should identify their legal classification, review their actual services, and prepare for the requirements that will apply from the new decree's effective date.

Waste-management arrangements must continue to follow the environmental, healthcare, occupational safety, and other relevant laws applicable to the activities involved.

Keeping these regulatory responsibilities distinct helps avoid both undercompliance and unnecessary application of requirements intended for another type of organization.

Responding to Waste-Related Incidents

Waste-related incidents can take different forms.

A worker may discover an exposed needle, a container may leak, hazardous material may enter an ordinary waste stream, or waste may become accessible to residents or visitors.

The appropriate response depends on the actual hazard.

Workers should know how to avoid further exposure, restrict access when necessary, and obtain assistance from personnel with suitable training and equipment.

Suspected infectious or chemical exposure, significant injury, or another serious incident may require prompt professional assessment.

Employees should not be expected to manage unfamiliar hazardous materials or spills beyond their competence and available protective arrangements.

Where an incident involves an external healthcare provider or waste contractor, responsibility for immediate protective action and subsequent investigation should be clarified.

Records should distinguish observed facts from assumptions.

A review may reveal that a suitable container was unavailable, workers misunderstood the classification, or responsibilities between providers were not adequately established.

These findings may indicate system weaknesses requiring corrective action.

However, deliberate misconduct or serious legal violations must still be addressed through appropriate accountability and competent-authority procedures.

An internal quality review does not replace any notification or reporting required under environmental, occupational safety, healthcare, or other applicable legislation.

The purpose is to protect people, respond lawfully, and reduce the chance of a similar event occurring again.

Measuring Whether Waste Management Works in Practice

An organization may have a written waste policy while still experiencing repeated segregation errors, collection problems, or unsafe handling.

Management therefore needs to understand how the system works in everyday practice.

Useful information may include whether waste streams have been correctly identified, suitable containers are available, and employees understand which materials they may handle.

The organization may also examine significant segregation errors, sharps injuries, near misses, storage deficiencies, collection interruptions, and completion of required transfer records.

Where external providers are involved, management should consider whether responsibilities remain clear and whether agreed services are delivered reliably.

These measures require interpretation.

A rise in reported near misses may reflect improved awareness and reporting rather than deteriorating safety.

Similarly, the absence of recorded injuries does not prove that waste handling is safe.

Observation of practice, inspections of relevant areas, staff feedback, and review of incidents can provide information that numerical indicators alone may miss.

Facilities should avoid collecting extensive data that does not influence decisions.

A limited number of meaningful measures, reviewed regularly, may be sufficient to identify weaknesses and confirm whether corrective actions have been effective.

The important question is not merely whether waste has been removed from the building.

It is whether the organization has reasonable assurance that waste is appropriately classified, safely handled, and transferred or disposed of through lawful arrangements.

Building Practical Waste Management in Residential Care

Residential long-term care facilities in Viet Nam differ considerably in size, staffing, physical environment, services, and legal status.

A smaller social assistance facility providing accommodation and personal care may have different waste-management needs from a larger organization that also operates licensed healthcare services.

A useful starting point is to identify the activities performed on the premises and the waste each activity generates.

The provider can then determine which legal requirements apply, who is responsible for segregation and handling, and whether specialized collection or treatment arrangements are necessary.

Employees should receive information appropriate to their actual work.

Care workers need to recognize when they encounter materials that fall outside their responsibilities, including unexpected sharps or other potentially hazardous waste.

Visiting healthcare professionals should understand the arrangements for waste generated during their procedures.

Cleaning and waste contractors need clear responsibilities and the relevant legal and operational capabilities.

Management also needs to consider whether the system will continue to work during staffing changes, service interruptions, or unexpected incidents.

Where the facility lacks sufficient expertise, advice from qualified environmental, healthcare waste, occupational safety, technical, or legal professionals may be necessary.

International guidance can support planning.

WHO's Safe Management of Wastes from Health-Care Activities provides a comprehensive reference concerning classification, segregation, handling, storage, transport, treatment, occupational protection, and environmental considerations.

CDC and NIOSH guidance offers additional principles concerning sharps injury prevention and suitable containment.

ISO 25557:2026, Ageing Societies — Care Quality for Older Persons at Home and in Care Facilities, provides a broader reference for care quality, safety, workforce responsibilities, and organizational accountability.

However, ISO 25557 is not a technical standard for medical waste classification or treatment. It does not replace the specialized legal and technical requirements governing waste management in Viet Nam.

International sources should inform organizational improvement without being treated as automatically binding Vietnamese regulations.

The most useful system is one that reflects the organization's actual activities, can be understood by its workforce, and can be maintained consistently.

From Waste Collection to Accountable Environmental Safety

Waste management may be less visible to residents and families than meals, personal assistance, medication support, or clinical care.

Yet the way a facility handles discarded materials can affect everyone who lives or works there.

A used needle placed in the wrong bag can injure a cleaner. An unsuitable storage area can expose residents to avoidable hazards. An unclear arrangement with a visiting healthcare provider can leave clinical waste without a reliable disposal pathway.

These problems cannot always be solved by purchasing more bins or increasing collection frequency.

They require accurate classification, suitable handling arrangements, clear responsibilities, and management attention when the system does not work as intended.

For residential long-term care providers in Viet Nam, the challenge is particularly important when ordinary living activities and regulated healthcare services take place in the same environment.

Facilities need to avoid two opposite mistakes: treating every care-related material as hazardous medical waste, and allowing genuinely hazardous waste to enter an unsuitable ordinary collection stream.

A dependable approach respects the differences between residential living, personal care, healthcare activities, and environmental management.

It also recognizes that responsibility extends beyond the employee who first discards an item. Cleaners, waste collectors, transporters, and treatment providers may encounter the same material later.

The quality of waste management is therefore not demonstrated solely by a clean-looking facility or a collection schedule that has been completed.

It becomes evident when the organization understands what waste it generates, applies the correct requirements, protects the people handling it, and can account for how regulated materials leave its premises and reach an appropriate disposal pathway.

For residential long-term care in Viet Nam, that is an important part of providing services that are safe, accountable, and environmentally responsible.

Key References and Regulatory Context

World Health Organization. (2024). Health-Care Waste. Fact sheet updated October 24, 2024.

World Health Organization. (2014). Safe Management of Wastes from Health-Care Activities. Second edition.

United States Centers for Disease Control and Prevention. Guidelines for Environmental Infection Control in Health-Care Facilities. Including relevant recommendations concerning regulated medical waste and sharps management.

United States Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health. Bloodborne Infectious Disease Risk Factors for Healthcare Workers. Guidance concerning sharps injury prevention and occupational exposure controls.

National Assembly of Viet Nam. (2020). Law on Environmental Protection No. 72/2020/QH14, as amended, including amendments introduced by Law No. 146/2025/QH15 effective January 1, 2026.

National Assembly of Viet Nam. (2025). Law No. 146/2025/QH15 Amending and Supplementing Certain Provisions of 15 Laws in the Agriculture and Environment Sector. Effective January 1, 2026.

Government of Viet Nam. (2022). Decree No. 08/2022/ND-CP Detailing Certain Articles of the Law on Environmental Protection, as amended, including Decree No. 05/2025/ND-CP and Decree No. 48/2026/ND-CP.

Government of Viet Nam. (2026). Decree No. 48/2026/ND-CP Amending Decree No. 08/2022/ND-CP. Issued and effective January 29, 2026.

Ministry of Natural Resources and Environment, Viet Nam. (2022). Circular No. 02/2022/TT-BTNMT Detailing Certain Provisions of the Law on Environmental Protection, as amended.

Ministry of Natural Resources and Environment, Viet Nam. (2025). Circular No. 07/2025/TT-BTNMT Amending Certain Provisions of Circular No. 02/2022/TT-BTNMT.

Ministry of Agriculture and Environment, Viet Nam. (2025). Circular No. 07/2025/TT-BNNMT Amending Certain Provisions of Circular No. 02/2022/TT-BTNMT. Issued June 16, 2025.

Ministry of Agriculture and Environment, Viet Nam. (2026). Circular No. 09/2026/TT-BNNMT Amending Certain Provisions of Circular No. 02/2022/TT-BTNMT, as Previously Amended. Issued and effective January 29, 2026.

Ministry of Health, Viet Nam. (2021). Circular No. 20/2021/TT-BYT on Medical Waste Management Within Healthcare Establishments. Issued November 26, 2021; effective January 10, 2022. Particularly Articles 1–2 and provisions concerning classification, collection, storage, and transfer of medical waste.

National Assembly of Viet Nam. (2015). Law on Occupational Safety and Hygiene No. 84/2015/QH13, as amended.

National Assembly of Viet Nam. (2025). Law on Chemicals No. 69/2025/QH15, as amended. Effective January 1, 2026, together with relevant implementing provisions.

National Assembly of Viet Nam. (2016). Law on Pharmacy No. 105/2016/QH13, as amended, and applicable implementing regulations.

National Assembly of Viet Nam. (2023). Law on Medical Examination and Treatment No. 15/2023/QH15, as amended.

Government of Viet Nam. (2017). Decree No. 103/2017/ND-CP on the Establishment, Organization, Operation, Dissolution and Management of Social Assistance Facilities, as amended and applicable.

Government of Viet Nam. (2026). Decree No. 395/2026/ND-CP on the Operation and Management of Social Assistance Facilities. Issued October 23, 2026; scheduled to take effect December 7, 2026.

International Organization for Standardization. (2026). ISO 25557:2026 — Ageing Societies — Care Quality for Older Persons at Home and in Care Facilities.

About Healthy Longevity Vietnam

Healthy Longevity Vietnam (HLVN) is a VietnamWellcare initiative advancing evidence-informed and context-appropriate approaches to longer, healthier lives in Viet Nam. Its work connects prevention, healthy aging, care quality, health systems, implementation, and collaboration, with a focus on supporting health, function, participation, and well-being across the life course.

Within this broader mission, HLVN explores opportunities to improve the quality, safety, integration, and responsiveness of care for older people across healthcare, home, community, and long-term care settings.

Disclaimer

This article is intended for general educational, environmental safety awareness, quality improvement, and organizational development purposes. It does not constitute individualized medical advice, occupational exposure treatment instructions, hazardous waste handling certification, technical waste-treatment guidance, legal advice, an official regulatory interpretation, or a mandatory national waste-management standard for residential long-term care in Viet Nam.

Waste classification, segregation, collection, storage, transport, treatment, and disposal must comply with applicable Vietnamese environmental, healthcare, occupational safety, pharmaceutical, chemical, and other relevant legal requirements.

The responsibilities of a residential care organization depend on its legal classification, licensed activities, the waste generated, the responsibilities it undertakes, and the applicable legal arrangements.

Circular No. 20/2021/TT-BYT governs medical waste management within its defined scope. Its requirements should not automatically be applied in full to every residential social assistance facility, nor should its scope be used to avoid duties that apply to relevant medical waste-management activities.

Ordinary personal care waste should not automatically be classified as infectious medical waste. Equally, hazardous sharps, pharmaceuticals, chemicals, and other regulated materials must not enter inappropriate waste streams merely because they arise on non-medical residential premises.

Healthcare providers, waste contractors, and residential care organizations must comply with the legal and professional responsibilities applicable to their activities. Contracts may allocate operational tasks but do not automatically remove statutory obligations.

Sharps injuries, suspected infectious exposures, chemical incidents, and other potentially serious events require appropriate professional assessment and any reporting or notification prescribed by law. This article is not a substitute for a facility-specific occupational exposure, hazardous spill, or emergency response protocol.

International guidance concerning containers, classification, transport, and disposal should not be treated as automatically establishing Vietnamese legal requirements. Organizations should follow applicable national rules and obtain qualified technical advice where necessary.

Decree No. 395/2026/ND-CP was issued on October 23, 2026, and is scheduled to take effect on December 7, 2026. It must not be treated as legally effective before that date or as replacing specialized environmental protection and medical waste regulations.

Organizations should develop facility-specific waste-management arrangements with appropriately qualified environmental, healthcare, occupational safety, technical, legal, and other relevant professionals, and consult competent authorities when required.

Information and regulatory context reviewed as of November 3, 2026.