How to Dispose of Bulk Chemotherapy Waste
Larger-than-trace chemotherapy waste, including RCRA-listed antineoplastic drugs and containers that are not RCRA-empty, must go to a permitted hazardous waste incinerator under federal rules.
What counts as bulk chemotherapy waste
Bulk chemotherapy waste is any antineoplastic (chemo) waste that is more than trace, meaning containers and items that are not RCRA-empty, partially used or unused vials, and dispensing or compounding waste with recoverable drug remaining. This is distinct from trace chemo waste (RCRA-empty containers, empty IV bags, tubing, gowns, and gloves with only residual contamination), which is covered on a separate page. The dividing line matters because bulk RCRA-listed chemo is regulated hazardous waste, while trace chemo is typically managed as a regulated medical (yellow-container) waste stream.
Step by step: containment, segregation, transport
- Identify whether the drug is RCRA-listed.
Check each chemo agent against the P and U lists in 40 CFR 261.33. Arsenic trioxide is P012 (acute hazardous, P-listed). The commonly cited U-listed antineoplastics are cyclophosphamide (U058), daunomycin (U059), melphalan (U150), mitomycin C (U010), streptozotocin (U206), uracil mustard (U237), chlorambucil (U035), and diethylstilbestrol (U089). Drugs not on these lists may still be hazardous if they exhibit a characteristic (for example toxicity, D-codes) or fall under your state program.
- Determine bulk versus trace and segregate.
If a container is not RCRA-empty, or holds unused or partially used listed drug, manage it as bulk RCRA-hazardous waste rather than trace. Keep it separate from the yellow trace-chemo stream and from regular regulated medical waste so the hazardous fraction is not diluted into the wrong stream.
- Place RCRA-hazardous bulk chemo in the correct container.
Collect RCRA-hazardous bulk chemo in a black container, the standard designation for RCRA-regulated hazardous waste. Label it with the applicable waste codes (for example P012 for arsenic trioxide, U058 for cyclophosphamide), keep it closed except when adding waste, and accumulate it within the time and quantity limits for your generator status.
- Ship to a RCRA-permitted hazardous waste incinerator.
Manifest the black-container bulk chemo to a RCRA-permitted hazardous waste combustor for incineration. Permitted hazardous waste combustors are subject to 40 CFR part 63 subpart EEE. Use a licensed hauler and retain the manifests and disposal documentation.
- Manage the whole stream under Subpart P and never sewer it.
Healthcare facilities and reverse distributors should manage hazardous waste pharmaceuticals, including bulk chemo, under 40 CFR 266 Subpart P. Do not flush or pour any hazardous waste pharmaceutical down a drain; the sewer ban in 40 CFR 266.505 applies to all healthcare facilities, including very small quantity generators.
Container, color code, and labeling
RCRA-hazardous bulk chemotherapy waste is collected in a black container, the industry-standard color for RCRA-regulated hazardous waste, and sent to a RCRA-permitted hazardous waste incinerator (permitted combustors are regulated under 40 CFR part 63 subpart EEE). Healthcare facilities manage these hazardous waste pharmaceuticals under 40 CFR 266 Subpart P, which carries a strict sewer prohibition: under 40 CFR 266.505, all healthcare facilities, including very small quantity generators, and reverse distributors are prohibited from discharging hazardous waste pharmaceuticals to a sewer that passes through to a publicly owned treatment works. Handling on the workforce-safety side is governed by the NIOSH List of Hazardous Drugs in Healthcare Settings and by USP General Chapter 800, which references the NIOSH list to set engineering controls, PPE, and containment requirements for antineoplastic and other hazardous drugs.
Frequently asked questions
What makes chemo waste bulk instead of trace?
Bulk chemo waste is anything more than trace residue: containers that are not RCRA-empty, and unused or partially used drug. Trace chemo is RCRA-empty containers and contaminated items like empty IV bags, tubing, gowns, and gloves. Bulk RCRA-listed chemo is hazardous waste; trace chemo is usually a regulated medical waste stream.
Which chemotherapy drugs are RCRA hazardous waste?
Under 40 CFR 261.33, arsenic trioxide is P-listed (P012, acute hazardous). Eight commonly cited drugs are U-listed: cyclophosphamide (U058), daunomycin (U059), melphalan (U150), mitomycin C (U010), streptozotocin (U206), uracil mustard (U237), chlorambucil (U035), and diethylstilbestrol (U089). Other chemo drugs may be hazardous by characteristic or under state rules.
How is bulk RCRA-hazardous chemo waste disposed of?
It is collected in a black container and shipped on a hazardous waste manifest to a RCRA-permitted hazardous waste incinerator. Permitted hazardous waste combustors operate under 40 CFR part 63 subpart EEE. It cannot go to a standard medical waste autoclave or to the sewer.
Can hazardous chemo waste ever be poured down the drain?
No. Under 40 CFR 266.505, all healthcare facilities, including very small quantity generators, and reverse distributors are prohibited from sewering any hazardous waste pharmaceutical. This federal sewer ban took effect August 21, 2019 and applies in every state regardless of state adoption of the rest of Subpart P.