Bulk or trace chemotherapy waste
Health care facilities typically divide chemotherapy waste into bulk or trace categories. The Washington Dangerous Waste Regulations, Chapter 173-303 WAC and Resource Conservation and Recovery Act (RCRA) do not distinguish between bulk and trace chemotherapy waste. For the purposes of this page and supporting documents, we will use the following descriptions of bulk and trace to help you manage your chemotherapy waste properly.
Bulk chemotherapy waste includes, but is not limited to:
- Chemotherapy waste that designates as RCRA hazardous waste or state-only dangerous waste.
- Non-empty containers of chemotherapy.
- Materials used to clean up a chemotherapy spill.
Trace chemotherapy waste includes:
- PPE or other materials that are not visibly contaminated.
- Empty chemotherapy containers that did not hold either a P-listed chemotherapy or a state-only extremely hazardous waste (EHW) for toxicity.
Designating chemotherapy waste
The U.S. Environmental Protection Agency developed the discarded chemical products list (WAC 173-303-9903) in 1976 to identify hazardous and acutely hazardous chemicals when discarded. The list has not been updated since 1976, so any chemotherapy drugs developed since still have the potential of designating as a RCRA hazardous waste for the characteristics of ignitability, corrosivity, or toxicity. All other chemotherapy drugs will likely designate as state-only dangerous waste, WAC 173-303-100.
RCRA hazardous waste
There are a number of chemotherapy drugs that designate as RCRA hazardous waste including:
- Non-viable chemotherapy formulations with a listed discarded chemical product as the sole active ingredient (WAC 173-303-080).
- PPE or other materials visibly contaminated with a listed discarded chemical product. PPE and other materials are considered contaminated when there is either employee knowledge of contact or visible evidence of contamination with a P-listed chemotherapy agent.
- Materials used to clean up a spill of a listed waste.
- Chemotherapy containers that held formulations with either a P-listed discarded chemical product as the sole active ingredient.
- A P-listed container is not considered empty unless it has been triple-rinsed. Since it is not practical to triple-rinse vials, syringes, and IV bags, manage these containers as RCRA hazardous waste.
- Chemotherapy formulations that exhibit a dangerous waste characteristic of ignitability, corrosivity, reactivity, or toxicity. You can determine if a waste is characterized as hazardous by its concentration of certain compounds and the traits of the whole solution:
- Ignitable: flash point is less than 60°C or 140°F, or it contains more than 24% alcohol. Waste code is D001.
- Corrosive: pH ≤ 2.0 ≥ 12.5. Waste code is D002.
- Reactive: see the descriptions in WAC 173-303-090(7). Waste code is D003.
- Toxic waste: contains a compound listed in WAC 173-303-090(8) in concentrations greater than the threshold using the Toxicity Characteristic Leachate Procedure (TCLP). Waste codes are D004 – D043 depending on the compound.
- Any PPE or other material that designates as a RCRA characteristic for ignitability, corrosivity, reactivity, or toxicity (WAC 173-303-090). PPE or other materials visibly contaminated with a non-listed chemotherapy must be fully designated before they can be considered trace chemotherapy waste. You should assume these wastes are hazardous waste unless they are designated separately. Designation must be documented.
- Materials used to clean up spills of RCRA hazardous chemotherapy.
State-only dangerous waste
Any chemotherapy that is not a RCRA hazardous waste will likely designate as dangerous waste for Washington State criteria of toxicity or persistence (WAC 173-303-100). You should assume these wastes are dangerous waste unless they are proven not to be through designation. Designation must be documented.
- Containers that held chemotherapy designating as state-only extremely hazardous waste (EHW) for toxicity are also state-only dangerous waste. A container is not considered empty unless it has been triple-rinsed. Since it is not practical to triple-rinse vials, syringes, and IV bags, manage these containers as dangerous waste.
- Materials used to clean up spills of state-only dangerous chemotherapy.
Managing chemotherapy waste
Unwanted chemotherapy agents eligible for credit from a manufacturer, wholesaler, or reverse distributor are viable pharmaceuticals and not considered waste. Viable pharmaceuticals include unused and/or unopened pharmaceuticals that can still be used or receive a credit. You must manage items not receiving a credit as waste.
RCRA hazardous chemotherapy waste
- Manage all bulk chemotherapy waste as RCRA hazardous waste at a RCRA-permitted facility.
- Under the dangerous waste regulations, accumulating more than 2.2 pounds (one liter) of any P-listed waste will make you a large quantity generator with additional requirements.
- Under the Interim Pharmaceutical Waste Policy, the listed waste will not count towards your generator status if it is sent to a RCRA-permitted incinerator as RCRA hazardous waste on a Uniform Hazardous Waste Manifest.
See the Pharmaceutical Waste Management Flowchart and Chemotherapy Waste Flowchart.
State-only dangerous chemotherapy waste
Any trace chemotherapy waste can be managed together with state-only dangerous waste. Manage as dangerous waste at a RCRA-permitted facility. You also have the option of managing state-only dangerous waste at an incinerator meeting the criteria of the Conditional Exclusion.
Note: Ecology recommends following the National Institute for Occupational Safety and Health's (NIOSH) Alert: Preventing Occupational Exposures to Antineoplastic and Other Hazardous Drugs in Health Care Settings and the Occupational Safety and Health Administration's Controlling Occupational Exposure to Hazardous Drugs to prevent exposure to patients and staff.