waste haulers and incineration firms that specifically handle chemotherapy
waste routinely specify in their waste acceptance protocols that
only paraphernalia such as tubing, gloves, gowns,
and EMPTY vials, syringes, and IVs can be accepted
for disposal. These items are considered trace chemotherapy and should be incinerated at a regulated medical waste incinerator to prevent
employee exposure during autoclaving, microwaving, or other alternative treatment.
Bulk chemotherapy waste should be managed as hazardous chemical waste, even though EPA regulations
have not been updated in this area. As a result, the EPA only regulates nine chemotherapy drugs as hazardous chemical waste. These nine drugs,
arsenic trioxide, chlorambucil, cyclophosphamide, daunomycin, diethylstilbestrol, melphalan, mitomycin C, streptozotocin, and uracil mustard, must be segregated from
yellow trace chemotherapy waste containers, red sharps containers, or red bags, and placed into RCRA hazardous waste containers when
present in bulk amounts.
Since many of the non-regulated chemotherapeutic
agents are at least as hazardous as the nine listed chemotherapy
drugs, good risk management should involve treating all bulk chemotherapy agents as hazardous waste when discarded.
In addition, chemotherapy
spill clean-up materials have traditionally been placed in yellow
or white chemotherapy waste containers. Since these absorb more
than trace amounts, they should be placed into hazardous waste containers.