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An Overview of Chemotherapy and Pharmaceutical Waste

By Steve Todisco, Senior Healthcare Account Manager

Some of you out there have been asking questions about the differences and similarities between chemotherapy waste and the newly coined term, "pharmaceutical" waste. By definition, pharmaceutical waste includes all expired, unused, contaminated or discontinued drugs (also known as medicines or chemicals) that can no longer be used for humans or animals. Chemotherapy waste, once no longer intended for human or animal use, is really just a sub-set of pharmaceutical waste.

In the broader scale, Pharmacy waste falls in to one of several categories; it is either hazardous or non-hazardous (as defined by the EPA). Thus, it stands to reason that chemotherapy waste, also, may be either hazardous or non-hazardous. There are currently nine (9) chemotherapy drugs whose waste is listed by the EPA as hazardous since 1976. Ironically, this list has not been updated and there are today many more chemotherapy drugs whose waste is much more dangerous to the environment than the original list of nine (9)...more to follow on this issue.

Typically, chemotherapy waste no longer intended for human or animal use comes in three flavors for those who are managing, collecting and disposing of it; namely, "product", "trace" or "bulk". The following rules apply: 1) If the chemotherapy waste is a packaged drug and eligible for reverse distribution (a topic for another day), then it may be managed as a "product" and returned for credit. 2) If the chemotherapy waste is EPA "listed" or "characteristic" within a container and less than 3% of its therapeutic dose remains intact (including gowns, glove, masks used in the administration of the chemotherapy waste for which there are no spills or leaks on them), then it may be managed as non-hazardous "trace" chemotherapy waste. It is usually collected in a "yellow bucket" and may be disposed of by a medical waste incinerator. 3) If the chemotherapy waste is EPA "listed" or "characteristic" within a container and more than 3% of its therapeutic dose remains intact (including contaminated gowns, gloves or other disposable items upon which chemotherapy has spilled or leaked-out upon them), then it must be managed as hazardous waste. It is then typically placed in the "black bucket" and disposed of by a hazardous waste incinerator. And finally, 4) if the chemotherapy waste is not identified as either "listed" or "characteristic", it may be managed as non-hazardous waste and disposed of as trace chemotherapy per above.

Which, of course, leaves us some final, parting thoughts; such as:

1. Given that the chemotherapy drugs developed and manufactured after 1976 are far often more dangerous to ourselves and to our environment than those identified in 1976 (albeit currently not regulated), should we, as good and responsible stewards of the earth, collect all chemotherapy waste, regardless of their properties, and,

2.  If we do, should all chemotherapy waste then be disposed of only by hazardous waste incineration?

Where does the line blur between "cost" and "conscience"?

For your opinions, or for a free consultation for building an EPA compliant pharmaceutical program, please contact per the information below.

Steve Todisco, Senior Healthcare Practice Manager, HEM, CHEM
Triumvirate Environmental, Inc.
Cell Phone: 339-226-0524 or Email: