Written by Megan Chamberlain
06 Feb 2018

How to Dispose of Chemotherapy Waste

Disposing of chemotherapy waste requires a number of considerations. First comes the definition of chemotherapy waste. Is it just the drug? The bag filled with the chemo drugs? The IV tubing? Chemo waste is defined as either trace waste or bulk waste. Which defines the two?

A thorough understanding of terminology goes a long way toward maintaining compliance when it comes to chemotherapy waste disposal.


Know the terminology

It’s not just the drugs or medications used for chemotherapy delivery that are of concern when it comes to collection, segregation, and disposal. What do you do with the tubing, the needles, and the packaging the chemo drugs came in? Is chemotherapy waste classified as hazardous waste or medical waste?

When it comes to chemotherapy treatments, chemotherapy or trace chemotherapy waste is produced during the preparation of or administration of chemotherapy, but not all waste comes into contact with the actual chemotherapy drug. So how are these items segregated?

Trace chemotherapy waste can include IV tubing, medicine bags, vials, or any part of the tubing and needle system that delivers the chemotherapy drug to a patient. However, personal protective equipment (PPE), towels, wipes, and pads may come into contact with chemotherapy drugs as well, and proper disposal is mandatory. Chemotherapy wastes are defined as a hazardous waste by the EPA and are treated as medical waste through incineration.

At its simplest definition, chemotherapy drugs that are listed as hazardous waste chemotherapy drugs must be segregated, managed, and transported as hazardous waste rather than “just” medical waste.

However, if the container is deemed “RCRA empty” - meaning only trace amounts of the chemotherapy drug are found on waste items such as draping or gloves and tubing – these items can be treated at a medical waste incinerator.

Terminology is important in chemotherapy waste segregation processes, as terminology has changed over the years. Today, trace chemotherapy waste is termed “RCRA empty” if, after the contents of the bag have been emptied through various methods (infusion, pouring, or pumping), the container or bag holds less than 3% total volume. At that point, it’s deemed “empty,” and is therefore exempt from hazardous waste regulations. Such regulations have been around for a while, per the EPAs Introduction to Containers training document (40 CFR Parts; §261.7).


State guidelines often more stringent than federal guidelines

Every state has its own guidelines for disposal of chemo waste, but all regulations (federal, state, and local) must be followed. For example, New Hampshire’s management and disposal guidelines for U-listed antineoplastic (chemo) wastes provides explicit instructions on how chemotherapy waste is to be dealt with, in addition to following federal standards.

Because states throughout the country employ different standards when it comes to the handling and disposal of chemotherapy waste, it is best to become familiar with regulations of their locality and state, plus federal guidelines forward and backward. Some states mandate that all chemo waste be handled as a hazardous waste product and such waste must be segregated from other types of waste. Others differ in both wording and requirements.


Segregating chemotherapy waste

Special containers designed for chemotherapy waste can help the segregation process. For example: sharps used in chemotherapy administration. In such situations, not all sharps containers are meant to contain all sharps waste. Daniels Health makes it easier to segregate chemo waste from other waste streams with single use or reusable chemotherapy collectors and sharps containers in a variety of sizes. Some are designed for small quantity generators and small spaces. Some are disposable and others reusable.

Different colored containers and tops identify different waste streams. Our Chemosmart container comes with a yellow top and body to clearly identify it as a chemotherapy waste container designed for sharps waste only, and can be situated in a patient’s room or the chemotherapy treatment center. A container filled with trace amounts of RCRA ‘empties’ and byproducts must be contained in separate containers with clearly marked labels for “incineration only” or “chemotherapy waste” based on state requirements. Every state facility needs to verify the process for removal of such containers from their property, even with their medical waste company.

Bulk chemo waste must be in a RCRA rated container; black containers are the industry standard but ultimately the color doesn't matter. Bulk chemotherapy waste is defined as any chemotherapy waste that is not deemed RCRA-empty. This can include but is not limited to half-empty IV bags, vials, or syringes. Any items used to clean up a chemo spill are also deemed as bulk chemo waste. Such waste must be stored in containers approved by the Department of Transportation (DOT) when it comes to transportation of hazardous materials and correctly labeled as a hazardous pharmaceutical waste, and per very specific DOT hazard classifications.

The medical waste business responsible for transporting that waste must also hold permits from the EPA for the proper management and disposal or treatment of that waste. Most states and localities have medical sharps disposal companies who must also adhere to transportation and disposal of hazardous pharmaceutical waste and bulk chemo waste.

It is the responsibility of the generator to make sure that the medical waste disposal or medical waste pickup companies used by the facility are following regulatory guidelines. If they’re not, you also may bear the brunt of penalties and fines associated with noncompliance. It’s not just an ethical scenario, it’s the law.

As mentioned earlier, different states have varying guidelines on how to manage, handle, segregate, and transport chemotherapy waste. For example, Florida follows the guidelines of the RCRA regulations when it comes to handling of hazardous waste (Title 40 CFR parts 260 through 271). The state of Florida also has its regulations, found in Florida’s Administrative Code, Rule 62 through 730.

In California, the department recommends that non-RCRA hazardous waste be segregated and managed from RCRA hazardous waste, and that only pharmaceutical waste that falls under California’s Title 42 §6901 should be disposed of in hazardous waste containers, including bulk chemotherapy drugs.


Daniels Health clarifies regulations

Yes, it can be confusing. We’re here to provide reliable healthcare waste solutions in multiple facility scenarios. Our accessories are designed to increase efficiency, boost safety, and promote cost-effective chemotherapy waste management. Contact us about your chemotherapy waste disposal concerns for trace and bulk disposal. We’ve got you covered.


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Megan Chamberlain

Megan Chamberlain

Content and Digital Solutions Specialist

With a little bit of knowledge about a lot of things and a quick wit, Megan was the recipient of the Daniels Pun-Master Award 2017 and is the go-to for fun analogies to explain healthcare waste.