Written by Megan Chamberlain
04 Jul 2019

Guide to Cytotoxic Waste Compliance

When you hear the words “cytotoxic waste” what is the first thing that comes into your mind? A leaking nuclear reactor? The sludgy stuff that might leak out of the industrial plant and into our waterways? Zombies?

Actually, if you don’t know the specific or at least general definition of cytotoxic waste, you’ve got some homework to do, especially if you are a medical waste generator of any size or type. In the United States, the most known type of cytotoxic waste is chemotherapy waste. Cytotoxic waste is defined as a drug that contains certain chemicals that are deadly or toxic to cellular structures - like drugs used in chemotherapy treatments. 

Cytotoxic wastes, have the potential to severely endanger human health and wellness. It’s even more important to be aware that cytotoxic waste residues can contaminate number of items in and around healthcare or other workplace environments, specifically equipment and other materials.

Cytotoxic drugs, such as those used in chemotherapy, are also known as antineoplastic drugs, typically given to individuals diagnosed with potentially deadly diseases such as cancer, multiple sclerosis, and rheumatic and autoimmune disease processes.


Compliance supports safety

Proper education, knowledgeable waste segregation, and attention to detail when it comes to the storage, handling, and/or transportation of cytotoxic waste can reduce risk of inadvertent exposure. Healthcare workers, medical waste disposal company employees, and anyone else involved in any form with the manufacture, transportation, handling, or disposal of cytotoxic waste needs to be aware that exposure can come from numerous directions.

One of those directions is percutaneous such as a needlestick injury in the delivery of the chemotherapy treatment. It can be absorbed through the skin, inhaled, or even ingested. Careful handling and proper disposal into a compliant sharps container may help prevent inadvertent needle sticks.

Did you know that a patient undergoing cytotoxic drug treatment excretes bodily fluids that are potentially contaminated with cytotoxic waste? Are you aware that the risk of such exposure can exceed seven days following treatment? Protoect your employees and patients from exposure.


Daniels Health encourages processes that reduce risks

Daniels Health is well aware of the potential cytotoxic exposure to family members, other patients, hospital employees, and even medical waste removal companies. It gets even worse if it’s improperly disposed of.

Exposure can also occur through inadvertent touching of objects that have been contaminated with cytotoxic waste, such as:

  • Personal protective equipment (PPE)
  • Syringes
  • Gloves
  • Needles


For this very reason, waste segregation processes must be understood and followed by everyone in a medical care environment from housekeeping staff to janitors, to nurses, physicians, and ancillary staff. Is your facility up-to-date on regulations and guidelines for handling or exposure to cytotoxic waste?

Cytotoxic waste must be segregated and disposed of properly! Treat cytotoxic waste as a biohazard waste. Disposing of anything that may have been exposed to cytotoxic drugs with other types of waste renders all that waste hazardous.

Cytotoxic waste is typically disposed of through a process of incineration. Before it gets to the incinerator, knowing waste stream management and proper waste segregation methods must be followed.

Federal guidelines for the handling and management of pharmaceutical hazardous waste is available from the Environmental Protection Agency website. In addition, state guidelines are also very specific and must be followed. You can’t follow just federal or state regulations. You have to ensure that both are followed. Know your state’s guidelines in regard to healthcare waste management and chemo waste, clinical waste, and microbiological waste – state rules are often more stringent than those of the federal government.


Brief overview of disposal guidelines for chemotherapy waste - a type of cytotoxic waste

Specific state guidelines for proper disposal of antineoplastic or chemotherapy waste are found under the administrative code guidelines of every state. For example, in the state of New Hampshire, disposal recommendations specify that this type of waste is commonly managed by separate waste stream categorization and broken down into trace and bulk chemotherapy waste.

In some cases, the terminology can get a bit tricky. “Trace” chemotherapy waste may not always coincide with infectious waste definitions, but in New Hampshire, it is always deemed (RCRA) ‘empty’. RCRA is the acronym for the Resource Conservation and Recovery Act, a set of legislative laws overseen by the EPA, a regulatory body.

Although some states, including New Hampshire, specify that as such, trace chemotherapy waste is not always regulated as a hazardous waste, nor an infectious waste, it can cause a severe threat to human and environmental health due to its cytotoxic nature. For this reason, the majority of healthcare facilities in the state opt for incineration, treating chemotherapy waste as if it were infectious.

Treatment of potentially dangerous infectious waste on-site through incineration is recommended whenever possible, not only to reduce the amount of times it’s handled before it reaches its final disposal, but because it also reduces risk to medical waste disposal companies and the general public. Be aware the transportation of any potentially infectious waste, or biohazard waste disposal must also adhere to the guidelines of the federal government, the Department of Transportation, and other agencies.

“Bulk” chemotherapy wastes that are not defined as RCRA empty should always be handled as hazardous waste. Better safe than sorry, even if chemotherapy agents (as new drugs are developed) may not always be mentioned in hazardous waste lists.

Still using New Hampshire guidelines as an example, containers that contain any amount of “free liquid, must be managed as antineoplastic waste. Place the entire container (file, syringe, IV bag, etc.) into the bulk hazardous waste container for proper disposal.

In addition, “gowns, goggles, gloves or other materials that are contaminated with antineoplastics found during routine administration or preparation must be managed as a hazardous waste.”


Stay compliant – know the rules

According to the EPA and RCRA guidelines, chemotherapy drugs are listed as hazardous waste, based on federal guidelines 40 CFR 261.33 (f) – more commonly known as the U-list. As such, these drugs are regulated under the EPA hazardous waste regulation “if they are discarded commercial chemical products, off- specification species, container residues or spill residues.”

For more detailed information and definitions, read 40 CFR subpart D – list of hazardous wastes. Take the time to read through the sections and the regulations. Information is detailed and specific:

  • Section 261.30 General.
  • Section 261.31 Hazardous wastes from nonspecific sources.
  • Section 261.32 Hazardous wastes from specific sources.
  • Section 261.33 Discarded commercial chemical products, off-specification species, container residues, and spill residues thereof.
  • Section 261.35 Deletion of certain hazardous waste codes following equipment cleaning and replacement.


Every medical waste generator, hospital, cancer treatment center, outpatient clinic, and so forth must be aware of proper disposal methods of antineoplastic wastes. Even the National Institutes of Health must follow these rules and guidelines.

Daniels Health is dedicated to protecting human health and the environment when it comes to healthcare waste management. We also stress the importance of taking a cradle-to-grave approach to any type of medical waste. That means taking responsibility of your medical waste generation from the point of origin to final disposal, and yes that means even after your medical waste has been picked up by a medical waste disposal company.

Such an approach is not only ethical, but it’s the law. For more information on how Daniels Health can help you set up compliant and safe waste stream and waste segregation processes and develop long-term, sustainable, and effective solutions in dealing with cytotoxic waste to maintain compliance, give Daniels Health a call today.


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Megan Chamberlain

Megan Chamberlain

Content Strategist

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.