[Pharmwaste] Question about haz med waste

Suhr, Marcus W. MSuhr at ChristianaCare.org
Wed Feb 17 10:47:05 EST 2010

Hopefully this helps answer your questions,


When you ask about hazardous drugs, there are RCRA hazardous, and also NIOSH/OSHA hazardous.  Joint Commission also has a new acute healthcare standard in EOC (EC.  The hospital minimizes risks associated with disposing of hazardous medications. (See also MM.01.01.03, EPs 1, 2, 3) which mentions hazardous medications but does not define hazardous.  In the most basic definition, hazardous can mean: 'capable of causing harm to humans or the environment'.  


Please remember medical waste is not hazardous waste.  Medical waste is either infectious waste, or biomedical waste/biohazardous; all synonymous.  Hazardous waste is it's own category of 'solid' waste at the federal level.  Many people refer to red-bag waste as hazardous because they are not aware of the legal difference, in case that is part of your question.  Your state could possibly cover medical waste under their hazardous waste regulations, but in Delaware, that is not the case.


Just to give an example, we have 3000 formulary items and approximately 11% we have deemed as "hazardous" when disposed of.  Guidance used to evaluate 'hazard' was taken from different sources;

1)      RCRA listed or characteristic waste (complex process to evaluate)

2)      NIOSH special handling list (i.e. antineoplastic agents) found at http://www.cdc.gov/niosh/docs/2004-165/2004-165d.html

3)      OSHA technical manual (CHAPTER <http://www.osha.gov/dts/osta/otm/otm_vi/otm_vi_2.html>  2. CONTROLLING OCCUPATIONAL EXPOSURE TO HAZARDOUS DRUGS)

4)      PharmEcology review classified 'hazardous' pharmaceuticals, i.e. endocrine disruptors, anti-virals, hormones, anti-retrovirals etc.


There are other solid wastes that can be considered hazardous by EPA standards; i.e. laboratory solvents etc.


I have profile lists we have developed here for proper hazardous waste disposal that I can provide as examples upon request but they will be site specific; we have a rather large formulary so I would imagine some of the more frequently used pharmaceuticals will be on our lists.  The guide found at this link was paramount to our development of our program which we are still rolling out; http://www.hercenter.org/hazmat/tenstepblueprint.pdf.  This guide was in-part funded by an EPA grant.

Good luck,  let me know if there are any other questions;

Marcus Suhr, CSP
Occupational Safety Specialist
Christiana Care Health Services
Occupational Safety Department, Office L840J
4755 Ogletown-Stanton Road
Newark, DE 19718
302-733-3787 (office) 
302-573-7662 (pager)
302-733-3771 (fax)
MSuhr at christianacare.org 

Alle Ding' sind Gift, und nichts ohn' Gift; allein die Dosis macht, daß ein Ding kein Gift ist. 
"All things are poison and nothing is without poison, only the dose permits something not to be poisonous." - Paracelsus 

-----Original Message-----
From: Sue Dayton [mailto:sdayton at swcp.com] 
Sent: Wednesday, February 17, 2010 7:09 AM
To: pharmwaste at lists.dep.state.fl.us; 'Tenace, Laurie'
Subject: [Pharmwaste] Question about haz med waste


Good morning!


I need help. Can anyone on this list serve send me information re: the following: 


1.       List of pharmaceutical drugs classified as hazardous.

2.       List of chemotherapeutical chemicals classified as hazardous.

3.       Any other type of medical waste that may be classified or considered hazardous waste.


Thank you in advance! 


Best -


Sue Dayton

Blue Ridge Environmental Defense League

North Carolina Healthy Communities Program


Saxapahaw, NC 27340

(336) 525-2003

sdayton at swcp.com




Our lives begin to end the day we become silent about things that matter.   -  Martin Luther King Jr.





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