Oncology clinics are medical practices and produce largely the same wastes as doctor’s practices, but the big difference is that oncology clinics administer chemotherapy drugs, which can be dangerous to patients, employees, and visitors. Waste generated at these clinics can be genotoxic and mutagenic. Care is required to collect the waste and keep it in secure storage until it can be removed for treatment.
If you have a good medical waste disposal company, they should be able to take away your infectious and biomedical waste, and possibly any RCRA hazardous and radioactive waste on site. Let them know that you have pharmaceutical waste, and that it includes chemotherapy agents or derivatives. The procedures and mechanics of handling this type of waste is not substantially different from managing other RCRA hazardous waste, and the legal restrictions are similar. However, the waste management company should know the composition to decide on a course of treatment. Pharmaceutical waste is incinerated, while some hazardous waste is treated with chemicals.
Segregation is a key tenet of waste management. If you keep waste items confined to the appropriate streams and avoid mixing, you will save a lot of money.
Pathological waste is a type of infectious waste. Human organs, tissues, or fluids are pathological waste. Anything recognizable as having come from a human body is pathological waste. Biopsy tissue is pathological waste. When you are done analyzing the tissue, whether it is malignant or not, it is classified as pathological waste. This is a subcategory of biomedical waste, but you should keep it in a separate collection system. Pathological waste is ultimately destroyed by incineration. Your waste disposal company needs to know which containers have pathological waste in them. Label these containers “Pathological Waste” and “Biohazard”.
Surgery is not routinely done at oncology clinics, but if any tissue is removed in surgery it is also pathological waste. Some oncology clinics have radiation treatment, and radioactive waste can be generated. The radioactive waste of most concern is the source of the radiation, which is often cobalt. Just because tissue or items have been exposed to radiation does not make them radioactive waste. Brachytherapy is a medical procedure that involves implanting radioactive pellets in the patient’s body. Radioactive waste can ensue. Excrement from the patient may be radioactive. When the pellets are removed, they are rad waste as is any residual tissue that sticks to the pellets.
Ecologists have discovered traces of chemotherapy agents in fish. This results from cancer patients excreting the drugs and them passing through the sewage treatment system (they would not normally be destroyed.) This is unavoidable and a price our society pays for chemotherapy. But it would be a real shame to flush chemo agents down the drain.
Some chemotherapy drugs cause cancer themselves. The cancer they cause will be considered a secondary cancer. Chemotherapy agents can be genotoxic and mutagenic. Whether they meet the criteria for RCRA hazardous waste or not, classify all chemotherapy waste together. (If there is a danger from mixing two drugs, take precautions, but this is unlikely.)
The waste disposal company will not (should not) mix chemotherapy waste with other hazardous waste that is not chemotherapy medicine. Chemo waste is incinerated. Other RCRA waste might be incinerated depending on its characteristics, but much hazardous waste is not appropriate for incineration.
Consider a collection system with at least four categories. You might want or need even more categories.
If you produce pharmaceutical waste, it will cost money to dispose of, but you also will lose out on revenue from giving those pharmaceuticals to patients, or back to the pharmaceutical distributor. There is a well-developed system for reverse distribution of prescription drugs. This is especially important for oncology clinics, as they often double as dispensaries. The patient does not bring their medication with them in most cases.
Further, regular pharmacies do not usually carry chemotherapy drugs. The clinic or doctor sells the drug to the patient. Some of the new oncology drugs are very expensive. Take-back programs will generate cash for the oncology clinic. Further, law enforcement may get involved if they suspect prescription drugs are not in a tight inventory system.
