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Dual waste

Dual waste is dangerous pharmaceutical waste that is also biomedical waste as defined by Chapter 70.95K RCW. Dual waste is usually generated when dangerous pharmaceutical waste is mixed with blood or attached to a needle. Segregate infectious wastes from non-infectious wastes.

We recommend using intravenous (IV) systems that have connections like a luer-lock system whenever possible. This simplifies waste management by allowing the sharps to be disconnected easily.

Biomedical waste in Washington includes sharps waste, human blood or blood products, pathological or animal wastes, cultures and stocks, and any biosafety level 4 wastes.

Many facilities use the terms “biomedical,” “biohazardous,” “infectious,” and “regulated medical waste.” For clarity, we will use the terms “biomedical” or “infectious.” Most pharmaceuticals are not inherently biomedical waste or infectious.

Examples of dual waste

  • Syringes that contained epinephrine or epinephrine salts since it is not practical to remove the needle or triple-rinse the syringe.
  • A partially administered syringe containing flu vaccine that has thimerosal.
  • A partial IV bag that contains arsenic trioxide, if the needle cannot be removed.
  • A partial IV bag that contains an antibiotic that just designates as state-only dangerous waste is a state-only dangerous dual waste if the needle cannot be removed.

It is a violation of the dangerous waste rules to send dangerous dual waste to a non-RCRA permitted landfill.

Making dual waste non-infectious

Some waste can be safely rendered non-infectious. Potential methods of segregating the biomedical from the pharmaceutical portions, or rendering the waste non-infectious include:

  • Removing the needle and attached tubing (infectious) from the rest of the IV bag (non-infectious) if using a luer-lock system.
  • If the dual waste is a syringe,* consider dispensing any remaining non-P-listed pharmaceutical waste into a separate container for management as a pharmaceutical waste and manage the syringe as an empty sharp. * This is not applicable for syringes used to administer P-listed pharmaceuticals.
  • If the material does not include a sharp but is otherwise infectious or potentially infectious, consider whether on-site disinfection is an option. The disinfection process must not cause a release of the dangerous waste pharmaceutical to air or water. Some potential disinfection methods include:
    • Autoclave or microwave sterilization
    • Chemical breakdown (e.g., use of strong oxidizer)
    • Ultraviolet-light exposure
  • Properly, safely, and legally managing infectious hazardous waste is very challenging and we are continuing to review management options for dual waste and will amend the recommendations as necessary.

Designating dual waste

RCRA hazardous dual waste

Resource Conservation and Recovery Act (RCRA) hazardous pharmaceutical waste that is also biomedical waste is considered RCRA hazardous dual waste. Some examples include:

  • Non-empty syringe or IV with sharps still attached that contains a listed or characteristic RCRA hazardous drug.
  • Syringe or IV with sharps still attached that contained P-listed RCRA hazardous waste, even if fully dispensed. If the IV bag can be separated from the needle, the bag and associated tubing are P-listed RCRA hazardous waste while the segment with the sharps is regulated medical waste. Examples of P-listed RCRA hazardous wastes include epinephrine and salts, warfarin (in concentrations over 0.3%), and arsenic trioxide.
  • Pharmaceuticals derived from human sources that designate as either a RCRA listed waste or as a RCRA characteristic waste.

State-only dangerous dual waste

State-only dangerous pharmaceutical waste that is also biomedical waste is considered state-only dangerous dual waste. Some examples include:

Managing dual waste

RCRA hazardous waste

If there is a safe method, either separate the biomedical portion of the waste (i.e., the needle), or treat on site to render the waste noninfectious. Manage the remainder as hazardous waste at a RCRA-permitted facility.

Send to a RCRA-permitted facility as RCRA hazardous dual waste following all the requirements of your local health department, the U.S. Occupational Safety and Hazard Administration (OSHA), Washington State Labor and Industries (L&I), and the U.S. Department of Transportation (DOT).

Most medical waste facilities are not RCRA-permitted facilities. Check with your biomedical and hazardous waste vendor.

State-only dangerous waste

  • If there is a safe method, either separate the biomedical portion of the waste (i.e., the needle) or treat on site to render the waste noninfectious. Manage the remainder as dangerous waste or under the Conditional Exclusion.
  • Manage as either dangerous waste or under the Conditional Exclusion.
    • If managing the dual waste as dangerous waste, send to a RCRA-permitted facility following all the requirements of your local health department, OSHA, L&I, and DOT.
    • If managing the dual waste under the Conditional Exclusion, send to an incinerator that meets the criteria of the exclusion. Most medical waste incinerators would meet the incineration conditions of the exclusion. Check with your biomedical waste vendor for information and to verify that the criteria are met.
  • Since most biomedical waste generated in Washington is autoclaved and landfilled, this dual waste must be segregated and sent for incineration. Contact your county health department for a local definition of infectious/biomedical/biohazardous waste.