What is the difference between trace and bulk chemotherapy waste?
From an EPA perspective, a container that holds the chemotherapy agent arsenic trioxide, which is a P-listed hazardous waste, is not “RCRA empty” unless all the contents have been removed and it is triple rinsed. Since this is not feasible in a healthcare facility, all containers that have held arsenic trioxide should be discarded as hazardous waste, regardless of contents. The only exception the EPA has granted is for a used syringe, which can be discarded as trace chemotherapy. The other eight chemotherapy drugs regulated by the EPA as hazardous waste are U-listed. If all the contents have been removed that can be removed through normal means (such as drawing liquid out with a syringe), and there is no more than 3% by weight remaining, the container is considered “RCRA empty” and can be disposed as trace chemotherapy waste in the yellow container. If either criterion is not met, it should be disposed of as hazardous waste and would be considered bulk chemotherapy waste.
