Your medical practice staff should know exactly what kinds of medical waste your practice produces and how to properly collect and prepare it for storage and transport. Chemotherapy waste disposal must be carefully managed in order to protect your employees, patients, and community. Chemotherapy can use highly toxic drugs and generates some of the most hazardous medical waste. If disposed of incorrectly, this type of pharmaceutical waste can present the biggest risk to human health and the environment. Knowing what goes in the yellow bin will help ensure proper bulk and trace chemotherapy waste handling.
Note: Technically, chemotherapy waste is a pharmaceutical waste that is covered as a single category. However, the medical disposal industry breaks chemotherapy waste into two subcategories: bulk chemotherapy waste and trace chemotherapy waste.
Bulk Chemotherapy Waste
This category includes any product that is a characteristic waste, listed, and still contains more than 3% by weight of the regulated ingredient. For example, IV bags left over after treatment or materials used to clean up chemotherapy spills.
The Resource Conservation and Recovery Act (RCRA) identifies nine chemotherapy drugs as characteristic or listed hazardous waste pharmaceuticals (HWP), and this antineoplastic waste is considered RCRA Hazardous Waste, which goes into the black container.
Note: There are many chemotherapy drugs that have not been classified as HWP and many states require that all chemo drugs be handled as HWP, which is an accepted best practice in medical waste management.
Trace Chemotherapy Waste
Intact and unused EPA “listed” or “characteristic” chemotherapy waste that is less than 3% by weight of the ingredient is referred to as trace chemotherapy waste. Another definition is “empty by normal means” — another way of stating that no more than 3% of the volume should remain in the container. This category also includes any items that came into contact with hazardous substances such as gowns and rubber gloves.
At a Glance: Yellow Container Chemotherapy Waste
The yellow container is for trace chemotherapy waste. (You may also use a container marked as “trace chemotherapy.”)
Trace contaminated chemotherapy waste is generated in the preparation & administration of antineoplastic/cytotoxic drugs. (An antineoplastic drug is defined as a drug that prevents, inhibits, or halts the development of a tumor. A cytotoxic drug is designed to destroy rapidly growing cancer cells.)
These materials do not have any liquid or powder that can be scraped or poured. Only residual amounts of the drug remain.
These items may be contaminated with trace amounts of a chemotherapy drug:
- IV tubing
- Empty bags/bottles
- Empty drug vials
Sharps contaminated with trace chemo should also be disposed of in the yellow bin.
Bottom Line: All trace chemotherapy waste
What Does “RCRA Empty” Mean?
Although the term “trace” is commonly used, the official Environmental Protection Agency (EPA) designation is “RCRA empty” for some containers that once held chemotherapy drugs. This means that the item that once held a U-listed substance now has less than 3% of the former volume in it.
For containers that held P-listed substances, triple-rinsing will render them RCRA empty. The EPA also stipulates two other ways that a container that held an acute hazardous waste can be considered “empty.” If these criteria are met, the waste can be considered “trace waste.” This type of waste can be managed as regulated medical waste; however, it must be medically incinerated.
Due to the highly toxic nature of chemotherapy drugs, trace chemotherapy waste must be carefully managed. This type of regulated medical waste goes into a yellow container or in a container clearly marked as “trace chemo.” It must legally go through medical waste incineration, which exposes waste to extremely high temperatures. The waste is reduced to ash (or nearly ash), rather than going through an autoclaving process.
After the waste has been processed, it no longer poses a health risk and can be landfilled. Proper chemotherapy waste disposal can help protect the health and safety of your employees, patients, and the environment. Working with a fully certified and permitted waste management provider can help you ensure that your medical practice is fully compliant with all regulatory requirements.