Pima County Department of Environmental Quality Hazardous Waste Generator Program 33 N. Stone Ave., Suite 700, Tucson, Arizona 85701-1429
Disposal of Chemotherapy Waste
The Pima County Department of Environmental Quality (PDEQ) has been conducting RCRA compliance inspections of hospitals located within Pima County. One issue that warrants special attention is the disposal of hazardous chemotherapy waste. In some cases, hazardous chemotherapy waste is being added to biomedical waste and handled as such. Biomedical waste contractors are permitted to accept biomedical waste only and are not permitted to accept hazardous waste in any amount, which is usually specified in your contract. PDEQ found that some chemotherapy wastes were neither stored nor transported in containers labeled as hazardous waste and the biomedical waste contractors did not have an EPA Identification Number as a transporter of hazardous waste.
Biomedical waste is defined in the Arizona
Syringes and IV bags that contain unused hazardous
chemotherapy wastes should not be disposed of as
being composed of one or more of the following:
a. Cultures and stocks: Discarded cultures and
stocks generated in the diagnosis, treatment or
WHAT QUESTIONS SHOULD YOU ASK?
immunization of a human being or animal or
in any research relating to that diagnosis,
chemotherapy drugs, contaminated personal
protective equipment, wipes and pads from the
b. Human blood and blood products: Discarded
pharmacy, patient room, or oncology clinic?
products and materials containing free-flowing
c. Human pathologic wastes: Discarded organs
Human pathologic wastes do not include the
d. Medical sharps: Discarded sharps used in
research, or clinical laboratories. This includes
scalpel blades; blood vials; needles attached to
tubing; broken and unbroken glassware; and
e. Research animal wastes: Animal carcasses,
body parts, and bedding of animals that have been infected with agents that produce, or may
Biomedical waste consists of human tissue, body
Note: The letter and three numbers beside the
parts, blood, body fluids, cultures and stocks of
chemical name is the EPA hazardous waste number.
infectious agents, needles, IV tubing, syringes
This is not a complete list of U-listed and P-listed
with needles attached, and scalpel blades.
chemicals. For a complete list, refer to
TGD-HW15 – Disposal of Chemotherapy Waste
2. Do you have Material Safety Data Sheets
If so, your hospital is required to have an EPA
Identification Number and comply with storage
and shipping requirements. For additional
waste disposal information to determine if it
information you may refer to the TGD HW14 -
technical guidance document, located on the
3. Do you generate a total of 220 pounds
hazardous waste (or 2.2 pounds of P-listed
4. Does your hospital ship hazardous waste off-
site? If so, your waste hauler is required to have an EPA Identification Number.
For additional information regarding proper management of solid or hazardous waste in Pima County, you may contact the Pima County Department of Environmental Quality (PDEQ) at (520) 724-7400, or the address at the beginning of this document, or visit the PDEQ website atfor access to the PDEQ Hazardous Waste Generators Handbook and waste or generator specific, technical guidance documents.
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