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My Watershed

  Specific waste: Chemotherapy

For the purposes of these Web pages, we will use the term chemotherapy to describe the treatment of cancer through the use of antineoplastic pharmaceuticals.

Chemotherapy wastes include:

  • Expired drugs and aborted dosages.
  • Contaminated personal protective equipment (PPE) and other materials.

Heath care facilities typically divide chemotherapy waste into two categories: bulk or trace.  The Dangerous Waste Regulations and RCRA do not distinguish between bulk and trace chemotherapy.  For the purposes of this page and other supporting documents, Ecology will use the following descriptions of bulk and trace to optimize proper chemotherapy waste management.

  • Bulk chemotherapy waste includes, but is not limited to:
  • Trace chemotherapy waste includes:
    • Any PPE or other materials that are not visibly contaminated.
    • Any empty chemotherapy containers that did not hold either a P-listed chemotherapy or a State-only extremely hazardous waste (EHW) for toxicity.

Designation of chemotherapy waste

Chemotherapy pharmaceuticals are highly toxic and designate as dangerous waste.  There are several chemotherapy drugs that designate as RCRA hazardous waste, either as P- or U-listed hazardous wastes or as characteristic hazardous wastes. 

The US Environmental Protection Agency (EPA) developed the list of discarded chemicals [Chapter 173-303-9903 WAC] 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 Washington State-only dangerous waste [Chapter 173-303-100 WAC].

RCRA hazardous waste:  There are a number of chemotherapy drugs that designate as RCRA hazardous waste including:

  • Any non-viable chemotherapy formulations with a listed discarded chemical product as the sole-active ingredient (Chapter 173-303-080 WAC).  
  • Any 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.  Any materials used to clean up a spill of a listed waste are 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. 
  • Any chemotherapy formulation that exhibits a RCRA characteristic of ignitability, corrosivity, reactivity, or toxicity (Chapter 173-303-090 WAC). You can determine if a waste is characteristic hazardous by its concentration of certain compounds and the traits of the whole solution:
    • Ignitable: flash point is < 60°C or 140°F, or it contains > 24% alcohol.  Waste code is D001.
    • Corrosive: pH ≤ 2.0 ≥ 12.5.  Waste code is D002.
    • Reactive: See the descriptions in Chapter 173-303-090(7) WAC.  Waste code is D003.
    • Toxic: contains a compound listed in Chapter 173-303-090(8) WAC 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 (Chapter 173-303-090 WAC).
    • 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 to be hazardous waste unless they are designated separately.   Designation must be documented.
  • Any 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 [Chapter 173-303-100 WAC].  You should assume these wastes are dangerous waste unless they are designated.   Designation must be documented.

  • Containers that held chemotherapy designating as a 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. 
  • Any materials used to clean up spills of State-only dangerous chemotherapy.

Management of chemotherapy waste

Viable chemotherapy:  Unwanted chemotherapy agents eligible for credit from a manufacturer, wholesaler, or reverse distributor are viable pharmaceuticals and not considered waste.  Viable pharmaceuticals include any 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:  All bulk chemotherapy waste can be managed as RCRA hazardous waste at a RCRA-permitted facility.  It is a violation of the Dangerous Waste Regulations to dispose of these pharmaceuticals in the sewer, sharps container, or a regulated medical waste container. 

State-only dangerous chemotherapy waste:  Any trace chemotherapy waste can be managed together with State-only dangerous waste.   Manage as a dangerous waste at a RCRA-permitted facility.  It is a violation of the Dangerous Waste Regulations to dispose of these pharmaceuticals in the sewer or in a sharps container or regulated medical waste container destined for landfill.

  • You have the option of managing State-only dangerous waste at an incinerator meeting the criteria of the conditional exclusion [Chapter 173-303-071(3)(nn)]. 

Note: Ecology recommends following the NIOSH Alert: Preventing Occupational Exposures to Antineoplastic and Other Hazardous Drugs in Health Care Settings and OSHA safety requirements to prevent exposure to patients and staff.   

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