There is a great deal of confusion surrounding the handling and disposal of bulk and trace chemotherapy waste. The Resource Conservation and Recovery Act (RCRA) was enacted by the EPA to mandate the disposal of waste deemed hazardous. Neither RCRA nor most states specifically define trace chemotherapy; however, the EPA has recently recognized trace chemotherapy waste as empty IV bags, tubings, vials, gowns, gloves and other items that may be contaminated with chemotherapy pharmaceuticals. In Arizona, chemotherapy waste is defined as any discarded material that has come in contact with an agent that kills or prevents the reproduction of malignant cells. This includes antineoplastic drugs.
To further muddy the waters, the RCRA lists just nine chemotherapy agents. However, the regulations were written years ago and have not been updated to include more than 100 new drugs now on the market.
Let us try to clear up some of the confusion.
The Difference Between Bulk and Trace Chemotherapy Waste
Healthcare facilities generate trace chemotherapy waste (also known as yellow bag/container waste) and hazardous chemotherapy waste (sometimes called bulk chemotherapy waste). In order for vials and IV bags to be considered “trace” materials, they must meet the RCRA definition of empty. All removable contents must be eliminated, with no more than 3 percent by weight remaining.
Bulk chemotherapy waste generally refers to chemotherapy drugs that do not meet the RCRA definition of empty. Other bulk waste may include items used to clean up chemotherapy waste spills or visibly contaminated personal protective equipment.
How to Dispose of Bulk and Trace Chemotherapy Waste
In Arizona, trace chemotherapy waste is placed in yellow containers and must be picked up by a licensed medical waste transporter and disposed of via medical waste incineration.
Bulk chemotherapy waste and containers that do not meet RCRA standards for “empty” must be managed in accordance with applicable hazardous waste regulations. While the federal RCRA regulations do not consider all chemotherapy waste hazardous, the EPA still recommends that facilities manage all unused bulk chemotherapy pharmaceuticals as hazardous waste.
Arizona regulations require that all chemotherapy waste must be treated by incineration in an approved facility. Bulk waste must go to RCRA-approved incinerators, and trace waste — with one exception — may go to a medical waste incinerator. These incinerators have less stringent transportation and documentation requirements, costing significantly less to dispose of than bulk waste.
The Exception: Arsenic Trioxide
Of the nine chemotherapy drugs listed under RCRA, the exception is arsenic trioxide, a P-listed (acutely toxic) hazardous waste. In order to consider this “RCRA empty,” all the contents must be removed and triple rinsed. This is not possible in most healthcare settings, and should therefore be considered bulk waste.
Still, there is another exception to this exception. The EPA will consider a used arsenic trioxide syringe as trace chemotherapy waste.