Trace or Bulk Chemotherapy Waste - Which one are you generating?

Neither The Environmental Protection Agency (EPA) nor most states specifically define trace chemotherapy (often shortened to “chemo”). EPA has recently recognized trace chemo waste as empty IV bags, tubings, vials, gowns, gloves and other items that are contaminated with residual chemo pharmaceuticals.  To add to the overall confusion, EPA lists only nine chemo agents, but we must consider that the regulations were written years ago and have not been updated since the approval of numerous new drugs now on the market.

What is Trace Chemotherapy Waste?
  1. All chemo paraphernalia should be managed as trace chemo waste if there is any risk exposure to chemo contamination.
  2. Trace chemo waste includes:
    • RCRA empty vials, syringes, IV bags, tubing, gowns, gloves, wipes
    • other paraphernalia associated with routine handling, preparation, and administration of chemo
    • wipes and other materials used during routine cleaning and decontamination of a biological safety cabinet or glove box (unless alcohols, phenols or other hazardous materials are used)
What is Bulk Chemotherapy Waste?
“Bulk” chemo waste isn’t a regulatory term, rather it is used to differentiate chemo containers that are not “RCRA” empty.

EPA chemotherapy drug list
GENERIC NAME
BRAND NAME
WASTE CODE
Arsenic Trioxide
Trisenox
P012, D004
Chlorambucil
Leukeran
U035
Cyclophosphamide
Cytoxan, Neosar
U058
Danuomycin
Daunorubicin, Cerubidin, DaunoXome, Rubidomycin
U059
Diethystilbestrol
DES, Stilphostrol
U089
Melphalan
Alkeran, L-PAM
U150
Mitomycin C
Mitomycin, Mutamycin
U010
Streptozotocin
Streptozocin, Zanosar
U206
Uracil Mustard
Uramustine
U237

EPA says a container that holds the chemo agent Arsenic Trioxide (P-listed) is not "RCRA empty" unless:
  1. All the contents have been removed
  2. And it is triple rinsed.
Healthcare facilities have found this task less effective, therefore all containers that have held arsenic trioxide should be disposed of as hazardous waste, regardless of contents. EPA has designated one exception to this rule which allows a used syringe (previously containing arsenic trioxide) to be discarded as trace chemo waste.

The remaining 8 chemo drugs are U-listed. The conditions for containers previously containing these drugs to be considered “RCRA empty” are less stringent.  To be considered “RCRA empty” and be disposed of as trace chemo waste:
  1. All contents have been removed that can be removed through normal means (drawing liquid out with a syringe)
  2. And there is no more than 3% by weight remaining
If no conditions are met, then this would be classified as bulk chemo waste.

Comments

Post a Comment

Thank you for your comments, they will be reviewed and approved accordingly.

Popular posts from this blog

Tech Corner: Know your hazardous waste accumulation & storage rules

Image
One notable change triggered by the Hazardous Waste Generator Improvement rule is the marking and label requirements on hazardous waste accumulation containers while in satellite waste accumulation and in central waste storage.   Previous RCRA labeling regulations did not require generators to identify and indicate the specific hazards of the hazardous waste accumulated in containers, tanks, drip pads and containment buildings.   This resulted in a failure to communicate risks associated with wastes being accumulated or stored in different locations. Another risk associated with marking and labels was the Treatment Storage Disposal Facility (TSDF) not knowing how to treat the waste to meet land disposal restriction requirements because generators did not always identify the specific RCRA waste codes associated with the waste. To avoid these risks the following changes to hazardous waste management regulations have been applied: 1.        Satellite accumulation – Containers and
Read more

HWGI rule - Summary of important points

The Environmental Protection Agency’s (EPA) Hazardous Waste Generator Improvement (HWGI) rule has been in effect since May 30, 2017.  Regardless of generator status designation, there are some important tasks generators must complete.  Here is a summary of the most important of those requirements. ·         Episodic events – Generators can exceed their designated generator status threshold once per year.  Additionally, they can petition for an additional “unplanned” event within the same year.  Generators must have an EPA ID and advise the EPA at least 30 days prior to the event.  In the case of an “unplanned” emergency, the generator must advise the EPA with 72 hours. (§262 subpart L ) ·         Re-notification – SQGs are required to re-notify of waste activities using Form 8700-12 every four years starting in 2021.  LQGs continue current system of re-notification as part of its biennial reporting requirement. (§262.18(d) ) ·         Pre-transport marking & labeling – Gener
Read more

Tech Corner: More states institute COVID-19 Standards

Image
  Credit: Simon Davis/DFID 14 states have instituted COVID-19 safety standards for the work place so far. As the COVID-19 pandemic continues to surge in the US, the concern for worker safety and health has all but subsided and the need to institute COVID-19 safety standards has become very apparent. In the absence of federal leadership in establishing these standards, some governors and state health departments have stepped up to expand worker protections. Virginia was the first state to issue an Emergency Temporary Standard to protect workers during the COVID-19 pandemic along with Oregon and Michigan shortly following. Other states have issued guidelines, some of which are tied to enforcement efforts. Additional some cites also have issued ordinances geared toward protecting their local workers. Below is partial list of states along the Mid-Atlantic and Northeastern regions that have adopted COVID-19 safety standards (with links to more information) Massachusetts - Safety standards f
Read more