The Right Way to Handle Bulk vs. Trace Chemotherapy Waste

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There is a great deal of confusion surrounding the handling and disposal of bulk and trace chemotherapy waste. The Resource Conservation and Recovery Act (RCRA) was enacted by the EPA to mandate the disposal of waste deemed hazardous. Neither RCRA or most states specifically define trace chemotherapy, however, the EPA has recently recognized trace chemotherapy waste as empty IV bags, tubings, vials, gowns, gloves and other items that may be contaminated with chemotherapy pharmaceuticals. And in Arizona, chemotherapy waste is defined as any discarded material that has come in contact with an agent that kills or prevents the reproduction of malignant cells. This includes antineoplastic drugs.

To further muddy the waters, the RCRA lists just nine chemotherapy agents. That’s because the regulations were written years ago and have not been updated since the approval of over 100 new drugs now on the market.

Let us try to clear up some of the confusion.

The Difference Between Bulk and Trace Chemotherapy Waste

Healthcare facilities generate trace chemotherapy waste (also known as yellow bag/container waste) and hazardous chemotherapy waste (sometimes called bulk chemotherapy waste). For items such as vials and IV bags to be considered “trace,” they must meet the RCRA definition of empty. All contents must be removed that can be removed through normal means, and there can be no more than 3 percent by weight remaining.

Bulk chemotherapy waste generally refers to chemotherapy drugs that do not meet the RCRA definition of empty. Other bulk waste may include items used to clean up chemotherapy waste spills or visibly contaminated personal protective equipment.

How to Dispose of Bulk and Trace Chemotherapy Waste

In Arizona, trace chemotherapy waste is placed in yellow containers and must be picked up by a licensed medical waste transporter and disposed of via medical waste incineration.

Bulk chemotherapy waste and containers that are not “RCRA empty” must be managed in accordance with applicable hazardous waste regulations. While not all chemotherapy waste may be regulated as hazardous under the federal RCRA regulations, the EPA recommends that facilities manage all unused bulk chemotherapy pharmaceuticals as hazardous waste as a best management practice.

Arizona regulations require that all chemotherapy waste must be treated by incineration in an approved facility. Bulk waste must be sent to a RCRA-approved incinerator. But trace waste — with one exception — may be sent to a medical waste incinerator. These incinerators have less stringent transportation and documentation requirements, and thus cost significantly less to dispose of than bulk waste.

The Exception: Arsenic Trioxide

Of the nine chemotherapy drugs listed under RCRA, the exception is arsenic trioxide, a P-listed (acutely toxic) hazardous waste. To be “RCRA empty,” all the contents must be removed and it must be triple rinsed. This is not possible in most healthcare settings, so it is to be considered bulk waste. There is one exception to this exception (no wonder people are confused!): The EPA does allow a used arsenic trioxide syringe to be discarded as trace chemotherapy.

Still Confused?

Get help from a licensed, experienced medical waste disposal company like US Bio-Clean. We can create a fully compliant chemotherapy waste disposal plan that fits your specific needs.

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