Healthcare Waste Management in Viet Nam: Safe Segregation, Treatment, and Environmental Responsibility

Healthcare Waste Management in Viet Nam: Safe Segregation, Treatment, and Environmental Responsibility

IMPLEMENTATION INSIGHTS · HEALTHCARE SUSTAINABILITY & ENVIRONMENTAL RESPONSIBILITY

Last reviewed: October 25, 2026

Healthcare facilities generate waste every day, from used needles and contaminated dressings to expired medicines, laboratory chemicals, packaging, and ordinary materials discarded during routine activities. These materials may leave the same building, but they should not necessarily follow the same waste management pathway.

A used needle requires protection against sharps injuries and potential infection. A discarded cytotoxic medicine presents different hazards. Clean packaging may be suitable for recycling, while contaminated materials may require specific treatment before further handling or disposal.

Decisions made when these materials are discarded can affect healthcare workers, waste handlers, patients, surrounding communities, and the environment.

Healthcare waste management is therefore more than a housekeeping function. It is an important part of infection prevention, occupational safety, environmental protection, and responsible healthcare governance.

For healthcare organizations in Viet Nam, the challenge is not simply to provide correctly colored waste containers or arrange regular collection. It is to ensure that waste is appropriately identified, segregated, collected, stored, transferred, treated, and ultimately managed according to its characteristics and applicable requirements.

A hospital may have written segregation procedures and a contract with a waste treatment company, yet important questions can remain. Are materials consistently placed in the appropriate containers? Can waste move safely from clinical areas to temporary storage? Is the receiving organization authorized and technically capable of managing the relevant waste? Are transfer records maintained, and can problems be identified and corrected?

The answers matter because waste management failures can occur at different points, even when the initial arrangements appear satisfactory.

Healthcare waste management should therefore be understood as a connected process, beginning where waste is generated and extending through its lawful treatment, recovery, or final disposal.

This article focuses primarily on solid healthcare waste and selected hazardous pharmaceutical and chemical waste streams. Healthcare wastewater, liquid waste, and emissions are also important aspects of environmental management, but their specific technical and regulatory requirements are not addressed comprehensively here.

Why Healthcare Waste Requires a Risk-Based Approach

Not all waste generated by healthcare activities is hazardous.

According to the World Health Organization's October 2024 fact sheet on healthcare waste, approximately 85% of waste generated by healthcare activities is general, non-hazardous waste. The remaining 15% is considered hazardous and may involve infectious, toxic, chemical, pharmaceutical, radioactive, or other risks.

These are broad international estimates, not measured waste composition figures for every healthcare facility or for Viet Nam specifically.

The distinction matters because different waste categories present different hazards.

Infectious waste may contain microorganisms capable of causing disease. Sharps can cause injuries and potentially expose workers to bloodborne pathogens. Certain pharmaceuticals and chemicals may have toxic, corrosive, or other hazardous properties. Improper waste management can also contribute to contamination of soil, water, or air, depending on the materials and management methods involved.

These risks cannot all be addressed through the same arrangements.

Treating every discarded item as hazardous waste may appear cautious, but it can increase treatment costs, consume additional resources, and create avoidable environmental impacts. Conversely, incorrectly classifying hazardous materials as ordinary waste may expose workers and communities to preventable harm.

Good waste management therefore depends on identifying the characteristics of each waste stream and applying appropriate controls.

This is consistent with WHO's Safe Management of Wastes from Health-Care Activities, second edition, which provides international guidance on segregation, handling, treatment, worker protection, and environmentally sound disposal.

The objective is not to subject every discarded material to the most intensive treatment available. It is to ensure that each waste stream receives management appropriate to its risks and legal classification.

What the 2026 WHO/UNICEF Report Tells Us

On August 18, 2026, WHO and UNICEF published Progress on Water, Sanitation, Hygiene, Environmental Cleaning and Waste Management in Health Care Facilities 2015–2025.

Prepared through the WHO/UNICEF Joint Monitoring Programme for Water Supply, Sanitation and Hygiene (JMP), the report provides updated estimates of essential environmental health services in healthcare facilities worldwide.

In 2025, an estimated 71% of healthcare facilities globally had basic healthcare waste management services.

Under the JMP definition, a basic service requires safe segregation into at least three appropriately designated containers in the consultation area, together with safe treatment and disposal of infectious waste and sharps waste.

The three categories are general non-hazardous waste, infectious waste, and sharps waste. National regulations may require more detailed classification.

Estimated global coverage increased from 59% in 2015 to 71% in 2025. However, the countries contributing data changed over time, so the figures should not be interpreted as a fully comparable measure of improvement across an identical group of countries.

For 2025, sufficient data were available from 79 countries, representing approximately 52% of the global population, to estimate basic healthcare waste management coverage.

The report also estimated that 21% of healthcare facilities had limited waste management services, while 7% had no waste management service.

These findings provide international context but should not be presented as measured coverage rates for Viet Nam.

The definition of a basic service also has limitations.

Meeting the JMP indicator does not automatically demonstrate compliance with every national environmental requirement. It does not provide a comprehensive assessment of pharmaceutical waste, chemical hazards, treatment emissions, contractor performance, or the final destination of every waste stream.

Similarly, the availability of appropriate segregation containers does not establish that all waste is consistently placed in the correct category.

The report therefore offers a useful starting point for understanding basic service coverage. Healthcare organizations need additional information to evaluate the safety, reliability, and environmental performance of their own waste management arrangements.

For healthcare leaders, the important question is whether the entire process functions as intended, not simply whether essential infrastructure is present.

Segregation at the Point of Generation: Where Safe Waste Management Begins

Waste segregation begins when an item is discarded.

In a treatment room, operating theatre, laboratory, pharmacy, or patient care area, the person generating waste is often best positioned to identify its characteristics and select the appropriate disposal category.

Once different types of waste have been mixed, separating them safely may become difficult or inappropriate.

For example, placing clean packaging into an infectious waste container can unnecessarily increase the volume requiring infectious waste treatment. Placing an infectious item into an ordinary waste container can create risks for personnel who handle materials without expecting exposure to infectious hazards.

Incorrect segregation may also undermine opportunities for lawful recycling and affect the suitability of downstream treatment methods.

Viet Nam has specific requirements for healthcare waste segregation.

Ministry of Health Circular No. 20/2021/TT-BYT, dated November 26, 2021, regulates healthcare waste management within healthcare facility premises.

The Circular requires healthcare waste to be classified and segregated at the place and time of generation. It distinguishes infectious waste, non-infectious hazardous waste, ordinary solid waste, and other relevant categories.

Infectious sharps must be placed in yellow, puncture-resistant containers. Other infectious waste categories are also associated with yellow containers or packaging, subject to their specific requirements.

Solid non-infectious hazardous waste is associated with black containers or packaging. Ordinary solid waste not intended for recycling is associated with green containers, while ordinary solid waste intended for recycling is associated with white containers.

These color-coding arrangements reflect Vietnamese regulatory requirements and should not be treated as a universal international system.

Detailed requirements vary according to the form and characteristics of the waste. Liquid hazardous waste requires suitable containment and identification, while non-infectious sharps also require protection against puncture injuries. Special arrangements apply to certain materials, including anatomical waste and waste with a high risk of infection.

An important provision concerns infectious waste mixed with other waste.

Under Circular No. 20/2021/TT-BYT, when infectious waste is mixed with another waste category, the mixture must be collected, stored, and treated as infectious waste, with subsequent management reflecting the waste's characteristics after treatment.

This should not be interpreted as meaning that treatment intended to control infectious hazards automatically eliminates chemical, pharmaceutical, or other hazardous properties.

Where multiple hazards are present, the selected management and treatment pathway must remain appropriate to all relevant characteristics.

For healthcare organizations, effective segregation requires more than purchasing containers in the correct colors. Containers need to be available where waste is generated, appropriately designed, clearly identified, and supported by practical instructions.

Personnel also need to understand what to do when the correct waste category is uncertain.

A well-designed segregation system makes the correct action straightforward during normal clinical work rather than depending entirely on workers remembering complex instructions under pressure.

Collection and Temporary Storage Must Remain Safe

Correct segregation is only the beginning.

Once waste has been placed in an appropriate container, it must move through the healthcare facility without creating unnecessary risks.

Collection may involve clinical staff, environmental services personnel, cleaning teams, waste handlers, and contracted workers. Their responsibilities need to be coordinated so that waste can be handled safely.

Infectious waste requires arrangements that limit leakage, spills, and unintended contact. Sharps containers must maintain their protective function during collection and movement. Chemical and pharmaceutical waste may require separate precautions based on their characteristics.

Collection routes, equipment, and timing should be appropriate to the facility. Waste movement should minimize avoidable exposure and interference with patient care, while personnel need appropriate training and protective measures.

Temporary storage is another important control point.

A healthcare facility may segregate waste correctly but undermine the process through inadequate storage conditions, poor maintenance, insufficient security, or delayed collection.

Circular No. 20/2021/TT-BYT establishes requirements for temporary healthcare waste storage and specifies different arrangements according to waste category and circumstances.

For infectious waste generated at a healthcare facility, the general maximum storage period under normal conditions is two days.

However, the Circular provides specific exceptions. Infectious waste may be stored for up to seven days in appropriate refrigerated equipment maintained below 8°C. For healthcare facilities generating less than 5 kilograms of infectious waste per day, storage under normal conditions may extend to three days, provided the prescribed containment requirements are met.

Different provisions apply to infectious waste received from other healthcare facilities for centralized or cluster-based treatment. Such waste generally needs to be treated on the day it is received. Where treatment cannot occur immediately, the Circular specifies additional temperature and storage duration requirements.

Non-infectious hazardous waste is subject to a separate storage framework. Under Circular No. 20/2021/TT-BYT, the general maximum storage period is one year from the date of generation. Where this period is exceeded because suitable transportation or treatment arrangements are unavailable, the healthcare facility must fulfill the applicable reporting requirements.

These distinctions matter because the appropriate storage conditions and periods are not identical for every healthcare facility or waste stream.

Organizations should apply the detailed requirements relevant to their circumstances rather than adopt a single storage rule for all waste. Regulatory maximum periods should also not be interpreted as recommendations to retain waste for as long as possible.

Storage arrangements need to reflect actual waste volumes, collection frequency, staff access, available space, and foreseeable operational difficulties.

The objective is to maintain safe containment and handling until the waste is treated or transferred through an appropriate pathway.

Responsibility Continues After Waste Leaves the Healthcare Facility

Many healthcare organizations do not operate their own hazardous waste treatment systems.

Instead, they transfer waste to external organizations authorized to collect, transport, and treat the relevant waste categories.

This can be appropriate, particularly where centralized treatment services provide technical capabilities that individual healthcare facilities may not have.

However, contracting an external provider does not eliminate the generating facility's legal responsibilities for segregation, storage, documentation, and lawful transfer.

Healthcare organizations need to understand which waste streams they generate and whether the receiving organization is appropriately authorized to manage them.

A waste treatment contract does not, by itself, demonstrate that every waste category can be handled by the contractor.

The receiving organization's relevant permits, authorized activities, waste categories, treatment capabilities, and transportation arrangements should be considered according to applicable requirements.

For example, a contractor authorized to manage infectious waste is not necessarily authorized or technically equipped to treat cytotoxic pharmaceutical waste.

Similarly, an organization authorized to collect ordinary recyclable materials should not be treated as an appropriate destination for hazardous healthcare waste simply because the materials contain plastic, metal, or other potentially recoverable substances.

The practical issue is whether each waste stream follows a lawful and technically suitable pathway.

Circular No. 20/2021/TT-BYT establishes requirements for healthcare facilities transferring waste to external organizations, including relevant handover records and hazardous waste documentation.

For hazardous healthcare waste transferred to appropriately authorized providers, the quantities transferred must be recorded, and hazardous waste documentation must be used in accordance with applicable regulations.

The Circular also contains specific arrangements for healthcare waste managed through approved cluster-based treatment systems.

These distinctions are important because different transfer models may involve different documentation and management requirements.

Healthcare organizations should therefore understand which provisions apply to their arrangements rather than assume that one documentation process covers every situation.

Records can help establish what was transferred, in what quantity, to which organization, and under which arrangements. They can also support investigations when discrepancies or other concerns arise.

Appropriate contractor oversight is an important part of environmental governance.

This does not mean that a healthcare facility assumes every legal responsibility belonging to an independent waste treatment provider. It means fulfilling its own obligations while maintaining reasonable assurance that the waste transferred enters an authorized and suitable management process.

Waste leaving the facility should not automatically be treated as evidence that all applicable responsibilities have been fulfilled.

Treatment Technology Must Be Appropriate for the Waste

Healthcare waste treatment is sometimes discussed as though there were one preferred technology suitable for every hazardous waste stream.

In practice, treatment suitability depends on the nature of the waste, the hazards involved, the technical capabilities of the treatment system, and the applicable legal and environmental requirements.

WHO's 2019 publication, Overview of Technologies for the Treatment of Infectious and Sharp Waste from Health Care Facilities, examines treatment options according to their technical performance, operational requirements, environmental implications, and practical suitability.

For certain infectious waste streams, non-incineration technologies such as steam-based treatment or appropriately designed microwave systems may provide alternatives to combustion.

When properly selected, validated, operated, and maintained, these technologies can reduce some pollution risks associated with poorly controlled burning.

However, non-incineration treatment is not automatically appropriate for every type of hazardous healthcare waste.

Cytotoxic pharmaceuticals, certain chemical wastes, anatomical materials, and other specialized waste streams may require different treatment or disposal pathways.

A steam-based process intended to inactivate microorganisms does not necessarily neutralize hazardous chemicals or make pharmaceutical residues environmentally safe.

Incineration also requires careful consideration.

WHO identifies open burning and poorly controlled, low-temperature incineration as environmental health concerns because they can generate harmful emissions, including particulate matter, dioxins, and furans under certain conditions.

Properly designed and operated incineration systems with appropriate pollution controls may be used for waste streams requiring combustion-based treatment, subject to applicable technical and environmental requirements.

The decision should therefore not be reduced to whether a facility uses incineration or a non-incineration technology.

The more relevant questions are whether the treatment process is suitable for the waste involved, whether it achieves the required technical performance, whether environmental controls are effective, and whether the relevant activities are lawfully authorized.

Waste management responsibilities may also continue after treatment.

Ash, sludge, treated solid waste, and other residual materials cannot automatically be assumed to be harmless or suitable for ordinary disposal.

Their subsequent classification and management must reflect their remaining characteristics and applicable requirements.

For healthcare organizations and treatment providers, the objective is safe and environmentally sound treatment rather than adopting a technology primarily because it appears modern or sustainable.

Pharmaceutical, Chemical, and Radioactive Waste Require Additional Safeguards

Pharmaceutical waste presents challenges that cannot always be addressed through ordinary infectious waste management.

Unused medicines, expired products, damaged pharmaceutical supplies, cytotoxic agents, and materials contaminated with particular drugs may require different controls.

Some pharmaceutical substances can create environmental concerns if they enter waste streams or treatment systems that are unsuitable for their characteristics.

In February 2025, WHO published Safe Management of Pharmaceutical Waste from Health Care Facilities: Global Best Practices.

The guidance addresses pharmaceutical waste generated across different healthcare settings and emphasizes prevention, appropriate segregation, safe handling, treatment, and disposal.

It also considers sustainability, emergency conditions, and the relationship between pharmaceutical waste management and antimicrobial resistance.

For healthcare organizations, pharmaceutical waste management begins before medicines become waste.

Procurement decisions, inventory management, appropriate storage, stock rotation, and coordination between pharmacy and clinical services can influence how much unused or expired medication must eventually be discarded.

Reducing avoidable pharmaceutical waste may be preferable to managing larger quantities after waste has already been generated.

However, prevention measures must remain compatible with medication quality, patient safety, infection prevention, and applicable pharmaceutical requirements.

Chemical waste requires similar attention to its particular characteristics.

Laboratory reagents, disinfectants, diagnostic chemicals, and other hazardous substances may need to be managed according to their properties rather than the department in which they originated.

Healthcare organizations should not assume that all liquid waste can be discharged into the wastewater system or that chemically contaminated materials are suitable for the same treatment process as infectious waste.

Appropriate arrangements may require specialized technical assessment and compliance with additional legal requirements.

Radioactive waste involves a separate regulatory framework.

Circular No. 20/2021/TT-BYT expressly excludes radioactive waste generated by medical activities from its scope.

Viet Nam's Law on Atomic Energy, No. 94/2025/QH15, effective January 1, 2026, provides an updated legal foundation relevant to radioactive materials, radiation safety, and radioactive waste management.

Healthcare facilities using radioactive materials must follow the specialized requirements applicable to their activities rather than rely solely on general healthcare waste management provisions.

These distinctions illustrate why waste classification is not merely an administrative task. It determines which safety controls, technical expertise, treatment pathways, and legal requirements may be necessary.

Waste Reduction and Recycling Must Not Compromise Safety

Environmental responsibility includes reducing unnecessary waste generation and identifying opportunities for appropriate resource recovery.

However, waste reduction should never undermine patient safety, infection prevention, or lawful waste management.

Healthcare organizations use disposable products for different reasons. Some are necessary to support safe clinical practice, while others may be selected because of procurement arrangements, logistics, or established operational preferences.

A responsible sustainability approach distinguishes these situations rather than assuming that reducing disposable products is always preferable.

An appropriate starting point may be to review procurement, inventory management, avoidable product expiration, unnecessary packaging, and material use.

Where safe and appropriate, organizations may also examine whether reusable alternatives can meet relevant clinical requirements and whether their reprocessing, maintenance, resource consumption, and environmental implications have been adequately considered.

This should not be interpreted as permission to reuse or reprocess medical products intended for single use without appropriate legal, technical, and professional safeguards.

Recycling requires equal care.

Clean, non-hazardous materials such as certain paper, cardboard, plastic, or other packaging products may offer opportunities for recycling when they meet the applicable requirements and suitable collection arrangements are available.

However, the presence of recyclable materials in healthcare waste does not automatically make that waste eligible for recycling.

Circular No. 20/2021/TT-BYT establishes requirements for ordinary solid waste that may be collected for recycling.

Healthcare facilities must determine suitable recyclable categories based on the applicable provisions, prescribed lists, and waste actually generated by their activities.

The Circular also provides that infectious waste treated to meet the relevant national environmental technical requirements may be managed as ordinary solid waste and collected for recycling under the prescribed conditions.

These provisions should not be interpreted as allowing unrestricted recycling of any waste that has passed through a treatment system.

Treatment outcomes, remaining hazards, waste classification, and the specific requirements for packaging, identification, documentation, and transfer must still be considered.

In particular, the Circular establishes documentation requirements when treated infectious waste is transferred for recycling, including the prescribed handover records.

Material recovery should be lawful and safe for waste handlers, downstream users, and the environment.

Correct segregation is particularly important because it can prevent avoidable contamination of materials that would otherwise be eligible for recycling.

At the same time, a high recycling rate should not automatically be treated as evidence of good healthcare waste management.

A favorable figure may be misleading if waste has been incorrectly classified, treated inadequately, or transferred without appropriate controls.

The priority must remain safe and lawful management, with environmental improvements pursued within those boundaries.

What Recent Research Reveals About Viet Nam

Healthcare waste management in Viet Nam involves a complex combination of healthcare, environmental, technical, and institutional responsibilities.

Hospitals and other healthcare facilities differ considerably in size, clinical services, geographical location, technical infrastructure, financial resources, and access to authorized waste treatment providers.

A large urban hospital may have different waste volumes, treatment options, and logistical arrangements from a smaller healthcare facility in a remote area. These differences affect what solutions are feasible and how waste management responsibilities can be implemented.

A relevant recent study is Circular Transitions in Healthcare Waste Management in Vietnam: An Institutional Perspective, published in Business Strategy and the Environment on August 23, 2026.

The research, conducted by Virva Tuomala and colleagues, examined institutional factors influencing healthcare waste management and the transition toward more circular practices in Viet Nam.

The researchers collected information through focus groups involving representatives of hospitals and waste management companies in Ha Noi and Ho Chi Minh City.

Their findings highlighted the influence of regulatory requirements, professional expectations, organizational practices, and institutional pressures on waste management decisions.

The study suggests that progress toward more circular healthcare waste management depends on more than introducing new treatment technologies.

Regulatory conditions, professional practices, organizational relationships, and the capabilities of waste management providers can influence implementation. International benchmarking and the adoption of practices from other organizations may also play a role.

This is relevant because a technology may offer potential environmental benefits without being readily implementable within a healthcare organization's existing legal, financial, or operational arrangements.

However, the study's qualitative design and geographical scope should be recognized.

Its findings help explain institutional experiences and potential barriers, but they should not be presented as a nationally representative measurement of segregation quality, treatment compliance, or recycling performance across all healthcare facilities in Viet Nam.

These findings reinforce the importance of looking beyond treatment equipment. Improvement also depends on institutional arrangements, professional responsibilities, appropriate technical capacity, and coordination between healthcare organizations and waste management providers.

For Viet Nam, this supports an approach in which proposed changes reflect the facility's actual circumstances and the lawful services available to it.

Understanding Viet Nam's Legal Framework in 2026

Healthcare waste management in Viet Nam is governed by several related legal instruments.

These instruments should be interpreted according to their respective scopes rather than treated as a single interchangeable set of requirements.

The Law on Medical Examination and Treatment, No. 15/2023/QH15, effective January 1, 2024, provides an important healthcare-specific foundation.

Article 75 establishes that healthcare facilities are responsible for healthcare waste management and environmental protection in accordance with environmental protection legislation.

The Law on Environmental Protection, No. 72/2020/QH14, as amended, provides the broader framework for waste management, environmental protection, environmental permits, and the responsibilities of relevant organizations.

Its application in 2026 must take account of subsequent amendments, including Law No. 146/2025/QH15, dated December 11, 2025, which amended provisions of fifteen laws in the agriculture and environment sectors and took effect on January 1, 2026.

Government Decree No. 08/2022/ND-CP provides detailed provisions for implementing the Law on Environmental Protection.

The Decree has been amended by Decree No. 05/2025/ND-CP and Decree No. 48/2026/ND-CP, the latter taking effect on January 29, 2026.

These amendments form part of the regulatory framework healthcare organizations need to consider when reviewing their environmental responsibilities, permits, and waste management arrangements.

At the ministerial level, Circular No. 02/2022/TT-BTNMT provides detailed provisions for implementing environmental protection legislation, including requirements relevant to hazardous 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.

Circular No. 09/2026/TT-BNNMT, issued by the Ministry of Agriculture and Environment, took effect on January 29, 2026.

For healthcare facilities, Ministry of Health Circular No. 20/2021/TT-BYT remains a central instrument governing healthcare waste management within facility premises.

The Circular addresses waste classification, segregation, collection, storage, waste reduction, recycling-related arrangements, on-site treatment systems, transfer, reporting, documentation, and organizational responsibilities.

It also requires healthcare facilities to assign leadership and professional responsibilities for waste management, develop appropriate management arrangements, allocate resources, and provide relevant education and training.

Healthcare facilities operating waste treatment systems must meet the applicable requirements concerning operation, maintenance, recordkeeping, and environmental performance.

Facilities transferring waste to external providers must follow the relevant legal requirements for transfer and documentation.

The distinction between managing waste within healthcare facility premises and managing its external transportation, treatment, and disposal is important.

Circular No. 20/2021/TT-BYT primarily regulates healthcare waste management within facility premises and related responsibilities, while the broader environmental framework also governs external waste management activities.

Not every healthcare organization is subject to identical environmental permitting requirements. Likewise, not every waste stream requires the same classification, transportation arrangements, or treatment documentation.

Applicable obligations depend on the type of waste, the facility's activities, its environmental authorization status, and the treatment or transfer arrangements used.

Radioactive healthcare waste remains subject to specialized legislation, including the Law on Atomic Energy No. 94/2025/QH15 and its applicable implementing requirements.

International WHO guidance can support professional practice and quality improvement, but it does not replace Vietnamese legislation or create independent regulatory authorization.

Healthcare organizations should determine their actual obligations according to current law, applicable environmental technical regulations, authorized activities, and the characteristics of the waste they generate.

Making Waste Management Part of Routine Healthcare Governance

Healthcare waste management can become fragmented when different departments manage separate stages without sufficient coordination.

Clinical personnel generate and segregate waste. Environmental services and cleaning teams collect it. Infection prevention personnel contribute relevant safety requirements. Facilities teams may oversee storage areas or treatment equipment, while procurement personnel arrange supplies and contracts.

Management is responsible for ensuring that these activities are appropriately organized, resourced, and overseen.

Each group has an important role, but safe waste management depends on how effectively their responsibilities connect.

For example, a recurring segregation problem may reflect unclear instructions, unsuitable container placement, insufficient supplies, or a mismatch between procedures and clinical workflows.

A collection problem may involve staffing, transportation equipment, storage capacity, or external service arrangements.

Simply recording that collection occurred may not explain why the underlying problem persists.

Healthcare organizations can therefore benefit from reviewing waste management as a connected operational process.

This involves understanding where waste is generated, how it moves through the facility, when responsibilities change, which records are created, and how concerns are identified and resolved.

The arrangements should remain proportionate to the organization's size and complexity.

A small outpatient clinic does not necessarily need the same management structure as a large hospital. However, both need clear responsibilities for safe handling, appropriate storage, and lawful waste transfer.

Where treatment is performed on site, additional technical competence, equipment maintenance, operational records, and environmental monitoring may be required.

Where treatment is outsourced, appropriate contractor selection, contract management, and transfer arrangements remain important.

Professional learning should also reflect actual responsibilities.

A clinician generating waste may need to understand segregation requirements. A waste handler may require specific training in collection, containment, and personal protection. A manager responsible for selecting treatment contractors may need to understand how to verify relevant authorizations.

Training should help personnel perform their assigned tasks rather than be limited to general environmental awareness.

In August 2026, WHO introduced an online course on advanced healthcare waste management, covering classification, segregation, storage, transport, treatment, waste minimization, and selected hazardous waste streams, including mercury-containing devices and pharmaceutical waste.

Such educational resources can support professional learning, but participation does not replace applicable Vietnamese training obligations, technical authorizations, or legal compliance requirements.

Waste management is most reliable when it is embedded in routine healthcare operations and supported by appropriate supervision, review, and corrective action.

Measuring Performance Beyond Waste Collection Volumes

Healthcare organizations need practical evidence to determine whether their waste management arrangements are functioning as intended.

The presence of correctly colored containers, written procedures, and waste collection contracts is important, but these measures alone cannot establish overall performance.

A useful assessment may examine whether waste is segregated appropriately at the point of generation, whether containers are suitable and available, and whether collection and storage arrangements are consistently followed.

Organizations may also need to review the quantities of different waste streams, waste transfer records, treatment information, and relevant contractor documentation.

Waste quantities can provide useful information, but they require careful interpretation.

An increase in recorded hazardous waste may reflect greater clinical activity, changes in services, or improved identification of previously misclassified materials.

A reduction may indicate successful waste minimization, but it could also reflect inappropriate segregation or incomplete reporting.

Comparisons between departments or healthcare facilities should therefore consider patient volumes, clinical procedures, service complexity, and waste classification practices.

No single indicator can demonstrate that healthcare waste management is safe, environmentally sound, and legally compliant.

Organizations may draw on internal inspections, professional observations, maintenance records, incident reports, treatment documentation, and other relevant evidence.

For example, repeated contamination of recyclable waste may indicate weaknesses in segregation arrangements. Differences between recorded waste quantities and transfer documentation may require review of weighing, recording, or handover procedures.

Recurring problems with temporary storage may indicate a need to improve infrastructure, collection frequency, or contractual arrangements rather than provide additional training alone.

Where problems are identified, the priority should be understanding their causes and implementing appropriate corrective actions.

Meaningful monitoring should help managers understand what is working, where weaknesses remain, and whether changes have improved performance.

The objective is not simply to achieve favorable waste management statistics. It is to maintain a process that can be understood, reviewed, and improved.

Climate Resilience and Environmental Responsibility

Healthcare waste management also has implications for climate resilience and environmental sustainability.

Extreme rainfall, flooding, prolonged heat, and other environmental conditions may affect temporary storage, transportation routes, treatment facilities, and the reliability of collection services.

A waste management arrangement that works during normal operations may become more difficult to maintain when transport is interrupted or environmental conditions affect essential infrastructure.

For healthcare organizations, preparedness may therefore require considering how waste management activities will continue when local conditions change.

The relevant risks depend on the facility's location, waste volumes, storage arrangements, and access to treatment services.

A healthcare facility relying on frequent external collection may face different vulnerabilities from one operating an authorized on-site treatment system.

Additional waste generation during an infectious disease outbreak or another unusual event may also place pressure on existing arrangements.

Circular No. 20/2021/TT-BYT recognizes the importance of preparing for environmental incidents and abnormal increases in hazardous healthcare waste.

Climate resilience should therefore be considered in relation to the facility's actual waste management dependencies rather than treated as a separate environmental initiative.

Environmental sustainability also requires attention to the impacts of waste treatment and disposal.

Reducing avoidable waste, improving segregation, selecting suitable treatment technologies, and maintaining appropriate pollution controls may help reduce unnecessary resource use and environmental harm.

However, environmental claims need to reflect the broader implications of proposed changes.

A treatment technology described as low-carbon may still require energy, water, consumables, transportation, and subsequent management of residual waste.

Similarly, a reusable healthcare product may have different environmental impacts depending on how it is manufactured, transported, cleaned, reprocessed, and used.

A particular technology or material should not automatically be assumed environmentally preferable in every setting.

Where comparisons are important, decisions should be informed by appropriate evidence, relevant lifecycle considerations, technical feasibility, and applicable requirements.

The underlying principle is that environmental improvement should strengthen, rather than compromise, safe healthcare waste management.

What Climate & Health Vietnam Can Contribute

For Climate & Health Vietnam (CHVN), healthcare waste management is a relevant area for evidence synthesis, professional learning, and implementation-oriented collaboration.

The subject connects healthcare sustainability with environmental health, patient safety, occupational safety, governance, and organizational quality improvement.

CHVN can contribute by helping healthcare professionals understand the distinctions between waste segregation, safe handling, treatment suitability, environmental responsibility, and performance monitoring.

International guidance and emerging research can provide useful perspectives, but their practical application needs to reflect Vietnamese legal requirements and the circumstances of individual healthcare organizations.

An important area of professional learning is the relationship between waste classification and downstream management.

Healthcare organizations may benefit from understanding why different waste streams require different treatment pathways, how responsibilities are distributed, and what forms of evidence can support appropriate oversight.

CHVN may also facilitate professional discussions involving healthcare managers, infection prevention personnel, environmental health specialists, waste management professionals, researchers, and other relevant stakeholders.

Potential contributions include evidence summaries, educational resources, implementation discussions, and collaboration on identifying practical knowledge gaps.

Such activities should remain within CHVN's actual expertise, institutional capacity, and applicable legal and professional boundaries.

CHVN should not present its educational materials as official WHO waste management assessments or imply that it has regulatory authority to certify treatment facilities, determine legal compliance, approve treatment technologies, or issue environmental permits.

Where specialized waste characterization, treatment selection, environmental monitoring, technical assessment, or legal compliance verification is required, appropriately qualified and authorized professionals or organizations should be involved.

CHVN's appropriate role is to make credible evidence more accessible, explain its relevance to responsible healthcare practice, and encourage informed professional collaboration.

This supports a broader approach to healthcare sustainability in which environmental responsibility is connected with healthcare quality, patient safety, and effective governance.

Safe Healthcare Waste Management Is a Continuous Responsibility

Healthcare waste management is sometimes viewed as a process that begins when a waste container becomes full and ends when a collection vehicle leaves the healthcare facility.

In reality, some of the most important decisions occur much earlier.

The classification of a discarded item influences how it is handled, which personnel may be exposed to it, whether specialized treatment is necessary, and whether lawful material recovery is possible.

Those decisions must be supported by appropriate collection, temporary storage, transportation, treatment, documentation, and management oversight.

For Viet Nam, strengthening healthcare waste management does not necessarily mean that every facility needs new treatment infrastructure or a separate management program.

A practical starting point is to understand which waste streams are generated, whether segregation is appropriate, how each stream is managed, and whether the necessary responsibilities and safeguards are in place.

Improvements may involve better container placement, clearer instructions, more reliable collection arrangements, appropriate contractor oversight, or stronger monitoring of treatment and transfer records.

The measures required will differ between healthcare organizations, but the underlying responsibility remains the same.

Healthcare waste must be managed according to its characteristics and applicable requirements, with attention to the people who handle it and the environments that may be affected.

Environmental sustainability should be pursued through waste prevention, appropriate treatment, responsible resource recovery, and effective pollution control rather than through waste reduction targets alone.

For healthcare leaders, waste management is therefore not simply a matter of compliance documentation or operational housekeeping. It is part of the organization's responsibility for safe care and environmental protection.

Responsible healthcare waste management begins with correct segregation, continues through safe handling, lawful transfer, and appropriate treatment, and requires accountability throughout the process until waste reaches a suitable and lawful destination.

Selected References and Policy Context

International Guidance and Evidence

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

World Health Organization. Overview of Technologies for the Treatment of Infectious and Sharp Waste from Health Care Facilities. March 4, 2019.

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

World Health Organization. Safe Management of Pharmaceutical Waste from Health Care Facilities: Global Best Practices. February 21, 2025.

World Health Organization and UNICEF. Progress on Water, Sanitation, Hygiene, Environmental Cleaning and Waste Management in Health Care Facilities 2015–2025. WHO/UNICEF Joint Monitoring Programme. August 18, 2026.

World Health Organization. New WHO Online Course Strengthens Safe and Sustainable Health-Care Waste Management. August 20, 2026.

World Health Organization. Operational Framework for Building Climate Resilient and Low Carbon Health Systems. November 9, 2023.

Selected Evidence and Research From Viet Nam

Tuomala, V., Schiffling, S., McClelland, R., Kok, S. K., Tran, D. T., Hoang, P., Nguyen, A., and Ngo, A. Circular Transitions in Healthcare Waste Management in Vietnam: An Institutional Perspective. Business Strategy and the Environment. Published August 23, 2026.

Viet Nam Policy and Regulatory Context

National Assembly. Law on Medical Examination and Treatment No. 15/2023/QH15, effective January 1, 2024, particularly Article 75 concerning healthcare waste management and environmental protection.

National Assembly. Law on Environmental Protection No. 72/2020/QH14, effective January 1, 2022, as amended.

National Assembly. Law No. 146/2025/QH15, dated December 11, 2025, amending selected provisions of fifteen laws in the agriculture and environment sectors, including the Law on Environmental Protection, effective January 1, 2026.

Government. Decree No. 08/2022/ND-CP, dated January 10, 2022, detailing certain provisions of the Law on Environmental Protection.

Government. Decree No. 05/2025/ND-CP, dated January 6, 2025, amending selected provisions of Decree No. 08/2022/ND-CP.

Government. Decree No. 48/2026/ND-CP, dated January 29, 2026, further amending Decree No. 08/2022/ND-CP, effective January 29, 2026.

Ministry of Health. Circular No. 20/2021/TT-BYT, dated November 26, 2021, regulating healthcare waste management within healthcare facility premises, effective January 10, 2022.

Ministry of Natural Resources and Environment. Circular No. 02/2022/TT-BTNMT, dated January 10, 2022, detailing certain provisions of the Law on Environmental Protection, as amended by subsequent applicable instruments.

Ministry of Natural Resources and Environment. Circular No. 07/2025/TT-BTNMT, dated February 28, 2025, amending selected provisions of Circular No. 02/2022/TT-BTNMT.

Ministry of Agriculture and Environment. Circular No. 07/2025/TT-BNNMT, dated June 16, 2025, amending selected provisions of Circular No. 02/2022/TT-BTNMT.

Ministry of Agriculture and Environment. Circular No. 09/2026/TT-BNNMT, dated January 29, 2026, further amending Circular No. 02/2022/TT-BTNMT, effective January 29, 2026.

National Assembly. Law on Atomic Energy No. 94/2025/QH15, dated June 27, 2025, effective January 1, 2026, providing the specialized legal framework relevant to radioactive materials and waste.

Professional scope: This article is intended for professional education, evidence synthesis, and knowledge sharing. It does not constitute facility-specific waste classification or treatment instructions, hazardous waste characterization, environmental engineering advice, legal advice, environmental permitting guidance, a compliance determination, an official WHO assessment, or accreditation or certification criteria. Descriptions of waste categories, segregation arrangements, treatment technologies, and legal provisions are provided for general professional understanding and should not replace the full requirements applicable to a particular healthcare facility or waste stream. References to WHO, UNICEF, and other international organizations do not imply endorsement of Climate & Health Vietnam or its activities. Healthcare organizations should apply current Vietnamese legislation, applicable environmental technical regulations, relevant professional requirements, and qualified infection prevention, occupational safety, environmental health, waste management, and engineering judgment when assessing or improving healthcare waste management.