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  Specific waste: Dual waste

Dual waste is any dangerous pharmaceutical waste that is also a biomedical waste as defined by RCW 70.95K.  Biomedical waste in Washington State 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.  Pharmaceuticals derived from human source materials are potentially infectious and thus dual waste when disposed. 

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.

  • Ecology recommends the use of IV systems that have connections like a luer-lock system whenever possible.  This simplifies waste management by allowing the sharps to be disconnected easily.

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:

  • Remove 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 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 like epinephrine.  See Specific Wastes: Epinephrine.
  • 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 a strong oxidizer)
    • Ultraviolet-light exposure

Properly, safely and legally managing infectious hazardous wastes is very challenging and Ecology continues to review management options for dual waste and will amend the recommendations as necessary.

Designation of dual waste

RCRA hazardous dual waste: RCRA hazardous pharmaceutical waste that is also biomedical waste is considered a RCRA hazardous dual waste. Some examples include:

  • Any non-empty syringe or IV with sharps still attached that contains a listed or characteristic RCRA hazardous drug.
  • Any syringe or IV with sharps still attached that contained P-listed RCRA hazardous waste, even if it is 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 waste include epinephrine and salts, warfarin (in concentrations over 0.3%), and arsenic trioxide.
  • Any pharmaceutical derived from a human source that designates as either a RCRA listed waste [Chapter 173-303-080 WAC] or as a RCRA characteristic waste [Chapter 173-303-090 WAC].

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

  • Any non-empty syringe or IV with sharps still attached where the pharmaceutical only designates under the State criteria for toxicity or persistence [Chapter 173-303-100 WAC].
  • Any pharmaceutical derived from a human source that only designates under the State criteria for toxicity or persistence [Chapter 173-303-100 WAC].

Examples of dual waste

  • Syringes that contained epinephrine or epinephrine salts are RCRA hazardous dual waste.  Since it is not practical to either remove the needle or triple-rinse the syringe, the syringe is still a P042 RCRA listed waste. 
  • A partially administered syringe containing flu vaccine that either has thimerosal added as a preservative or has trace amounts leftover from the manufacturing process is a RCRA hazardous dual waste with a waste code D009. 
    • If the thimerosal is added, the final concentration of thimerosal is 25 mcg/0.5 mL dose or 50 mg/L.  This results in a final mercury concentration of 25 mg/L since thimerosal is approximately 50 percent mercury by weight. 
    • The vaccines with trace amounts of thimerosal have approximately 1 mcg/0.5 ml dose or 2 mg/L thimerosal, resulting in a final mercury concentration of 1 mg/L. 

Both formulations exceed the RCRA characteristic threshold for mercury which is 0.2 mg/L

  • A partial IV bag which contains the chemotherapy arsenic trioxide is a RCRA hazardous dual waste with the waste code P012 if the needle cannot be removed.  If the needle can be removed from the rest of the IV bag, you simply have a regulated medical waste (the sharps) and a RCRA hazardous waste (the IV bag and attached tubing). 
  • A partial IV bag which contains an antibiotic that just designates as State-only dangerous waste is a State-only dangerous dual waste if the needle cannot be removed.  If the needle can be removed from the rest of the IV bag, you simply have a regulated medical waste (the sharps) and a State-only dangerous waste (the IV bag and attached tubing). 

Management of 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 US Occupational Safety and Hazard Administration (OSHA), Washington State Labor and Industries (LNI), and the US Department of Transportation (DOT).
    • Most medical waste facilities are not RCRA-permitted facilities.  It is a violation of the Dangerous Waste Regulations to send RCRA hazardous waste to a non-RCRA permitted facility.  Please check with your biomedical waste vendor and hazardous waste vendor for more information. 

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 either as dangerous waste or under the conditional exclusion [Chapter 173-303-071(3)(nn)].
  • Manage as either as dangerous waste (see above) or under the conditional exclusion.
    • If you are managing the dual waste as dangerous waste, send to a RCRA-permitted facility following all the requirements of your local health department, OSHA, LNI, and DOT.
    • If you are managing the dual waste under the conditional exclusion, send to an incinerator meeting the criteria of the exclusion.  Most medical waste incinerators would meet the incineration conditions of the exclusion.  Please check with your biomedical waste vendor for more information and to verify that the criteria are met. 
  • Since most biomedical waste generated in Washington State is autoclaved and landfilled, this dual waste must be segregated and sent for incineration.   It is a violation of the Dangerous Waste Regulations to send State-only dangerous dual waste to a landfill that is non-RCRA permitted landfill. 

Resources
Contact your county health department for a local definition of infectious/biomedical/biohazardous waste.