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.