Cytotoxic, or chemotherapy waste, is a top concern for healthcare facilities who are always on the lookout for the safest, most cost-effective disposal methods. The smallest of errors when packaging, labeling, and disposing of chemo waste can have serious consequences, including steep fines and penalties for non-compliance.
Do you know the rules for proper chemotherapy waste disposal?
Characteristics of Chemotherapy Waste
There are 9 key things you need to know about chemo waste:
- There is more than one type and it can be found on both P-lists and U-lists of substances under the Resource Conservation and Recovery Act (RCRA) regulations.
- It is only considered infectious when it’s contaminated with an infectious substance like blood.
- There’s a difference between “trace” and “bulk” chemotherapy. Now called “RCRA empty,” trace chemo waste includes things like IV bags and tubing as well as vials and is usually placed in yellow containers for disposal. Bulk chemo waste is placed in a black container and is handled as hazardous waste.
- Bulk chemo waste can also include materials used to clean up spills or those worn as protective gear. Full bags and bottles are also considered bulk as are P-listed chemotherapy drugs.
- Facilities must avoid cross-contamination or mixing.
- Federal and state guidelines both require chemo waste to be processed (trace and bulk) by incineration treatment only.
- Various terms are used for it including “antineoplastic waste.” In ADEM code 335-3, Alabama specifically defines “chemotherapeutic waste” as: "waste material resulting from the production or use of antineoplastic agents used for the purpose of stopping or reversing the growth of malignant cells.”
- Be sure to properly label each type of waste. If you’re unsure which labels are required to be compliant in Alabama, your disposal service can assist you.
- The proper handling of chemotherapy waste requires current and continuing training in handling, storing, and disposing of it.
Many medical facilities still have ineffective chemotherapy waste management practices. But to be compliant, safe, and environmentally-friendly, it’s important to understand the end-to-end process. Otherwise you risk accidents like spillage and infection.
Containment of Chemotherapy Waste
In Alabama, as in most states, chemo waste must follow RCRA regulations, be stored in appropriate containers, and correctly labeled. The waste storage area must also have posted an appropriate and prominent sign.
Because of the different subcategories, it can be difficult for your staff to understand how to segregate chemotherapy or antineoplastic waste. Common concerns include wondering whether chemo is managed as hazardous waste or a medical one. Should a yellow container with chemo labeling be used or is the black container with hazardous waste labeling the right choice? That’s why formal training is so important to the process. The separate containers designed specifically for chemo waste help keep the segregation process compliant.
- Yellow containers are used for trace or residual chemo and should be labeled “Chemotherapy Waste” and/or “Incinerate Only.”
- Black containers are used for bulk chemo and are labeled “Hazardous Pharmaceutical Waste” with the correct DOT hazard class.
Remember, it is your facility’s responsibility as the generator of the waste to make sure it is properly packaged, labeled, and disposed of. Though it can be confusing, your qualified hazardous waste disposal provider can be a major force in helping you mitigate risk and stay compliant.
The penalties and fines various agencies levy for non-compliance can be enormous. Whatever type of chemotherapy-waste producing facility you manage, adherence to both federal and state rules and regulations reduces the legal and financial exposure for your business, your employees, and the environment. While staying current on proper handling and containment of chemotherapy waste isn’t always easy, working with a hazardous waste expert will ensure your facility is operating in a safe and compliant way.