Choosing the right containment, transport, and treatment for waste items contaminated with chemotherapy or antineoplastic agents can be confusing. Questions that come up include, “Is chemo managed as hazardous waste, or is it medical waste? Do I have to use a yellow container and chemo labeling or a black container and hazardous waste labeling?” To answer these questions, we must consider how this waste is classified, segregated, and ultimately regulated.
Chemo waste disposal must be managed with local, state, and federal regulations in mind in order to protect all parties with potential exposure. Federal Resource Conservation and Recovery Act (RCRA) classifies nine chemotherapy drugs as characteristic or listed hazardous waste pharmaceuticals (HWP).
Hazardous Waste Chemotherapy Drugs
|Generic Name||Brand Name||Waste Code|
|Arsenic Trioxide||Trisenox||P012, D004|
|Daunomycin||Daunorubicin, Cerubidin, DaunoXome, Rubidomycin||U059|
|Mitomycin C||Mitomycin, Mutamycin||U010|
Note: This list may not be all-inclusive since new products may be introduced at any time.
If a chemo drug waste is classified as a HWP by RCRA, it must be managed as hazardous waste (not medical waste) unless the container is “RCRA-empty” (only residual remaining) or there are only trace amounts of the HWP on waste items, such as gloves or drapes (“trace chemo waste”). HWP that are in containers not RCRA-empty are typically referred to as “bulk chemo waste.” This waste must be managed by a hazardous waste disposal company. Trace chemo waste or RCRA-empty chemo containers can be managed by a medical waste company as long as they are incinerated.
There are numerous chemotherapy drugs that have not been assessed and therefore, not classified as HWP by RCRA. In addition, numerous states require all chemo be handled as HWP. Best management practices in healthcare include the disposal of ALL chemo as trace or bulk HWP as applicable. Having proper containers for segregation of chemo wastes will help keep those wastes out of sharps containers, red bags, and the trash. Note that the terms “trace/residual” or “bulk” chemotherapy are not regulatory terms but are used to differentiate between items that are RCRA-empty from those that are not.
RCRA-Empty – Trace/Residual Chemo (The Yellow Container)
For a chemotherapy waste container to be considered RCRA-empty or contain only residual amounts of the drug, all chemo must have been removed using practices commonly employed industry-wide to remove wastes from containers, such as pouring, aspirating, and draining until no more than 3 percent by weight the container remains. Such containers typically include empty IV bags, syringes, and medication vials. Trace chemotherapy can be found on items used to prepare and administer chemo, including gloves, pads, and gowns.1 As previously mentioned, some states, e.g., California, are stricter than RCRA and recognize an “empty” container as one having no remaining drug in it at all.
Trace or RCRA-empty chemotherapy can be disposed of in waste containers labeled as “Chemotherapy Waste” or “Incinerate Only” or other labeling that may be required by an individual state. Items contaminated with trace chemo or those RCRA-empty containers can be managed by a medical waste company as long as they are incinerated. They must be marked for incineration because otherwise, sharps containers and red bags are managed as medical waste and treated by autoclave, which is not appropriate treatment for ANY pharmaceutical waste.2
Sharps Compliance offers the 2-Gallon Sharps Recovery System for Trace Chemo, the Two 3.5-Gallon Pail TakeAway Recovery System for Trace Chemo, and the 20-Gallon TakeAway Recovery System for Trace Chemo. These systems are designed for simplified and regulatory-compliant collection, transport, and proper treatment of needles, empty vials, syringes, and other waste items contaminated with trace/residual amounts of chemotherapy agents.
Bulk Chemo (The Black Container)
According to the State of Washington’s Department of Ecology, bulk chemotherapy waste includes chemo in containers that are not RCRA-empty, such as unused or partially empty IV bags, syringes, or vials. Chemo spill cleanup materials are also considered bulk chemo.3
Bulk chemotherapy waste should be contained in RCRA containers that are DOT approved to transport this type of hazardous material (often black) and labeled as hazardous pharmaceutical waste with the correct DOT hazard class. They must be transported through hazardous waste pickup by an EPA-permitted transporter and properly managed as hazardous waste to an EPA permitted and authorized treatment facility. Sharps provides services for the compliant transport and disposal of bulk chemo and other hazardous pharmaceutical waste.
Proper waste segregation is key to increasing compliance for your facility while decreasing exposure to employees and the environment. To increase proper segregation in your facility, train employees that chemotherapy waste must never be placed in red bags, sharps containers, or regular trash; and that they instead belong in labeled, color-coded containers for this specific waste.