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Hazardous Drug Waste

Definition

EHS recommends any individual using chemotherapy drugs, antineoplastic drugs, or other hazardous drugs take MSU’s Safe Handling of Hazardous Drugs training.

Hazardous drugs are defined by the National Institute for Occupational Safety and Health (NIOSH). The definition and list of hazardous drugs is available on the EHS website.

Generally speaking, drugs are classified as hazardous if they may cause cancer, developmental, or reproductive toxicity or harm to organs at low doses.  These types of drugs can include chemotherapy or antineoplastic agents, antiviral drugs, hormones, some bioengineered drugs, and other various drugs. The main type of hazardous drugs utilized at MSU are chemotherapy or antineoplastic drugs.

All hazardous drug waste must be collected and given to the EHS Hazardous Waste Program for disposal. Hazardous drug waste MUST NOT be placed in the general refuse trash or go down the drain. Refer to MSU’s Drain Disposal policy.

Container Type

Previously, hazardous drug waste was collected in yellow Trace Chemotherapy containers. However, in order to streamline hazardous drug waste disposal more effectively at MSU, all liquid and solid waste utilized in the preparation or administration of hazardous drugs will be collected as pharmaceutical waste. These wastes must be collected in black and white pharmaceutical waste containers. Pharmaceutical waste containers are available for purchase through University Stores in Spartan Marketplace. MSU EHS does not provide replacement pharmaceutical waste containers, so please have a new container on hand prior to disposal.

Examples of liquid and solid hazardous drug waste can include, but is not limited to pharmacy/nursing PPE utilized in the preparation or administration of hazardous drugs, empty packaging, vials, ampules, IVs, bottles, and tubing, sharps, all syringes, investigative drug vials, fluids or devices removed from intra cavity installations, closed system drug transfer devices, and heavily soiled items such as those used to clean up a spill of hazardous drugs.

One large and one small black and white plastic pharmaceutical containers with MSU Pharmaceutical Waste label

Special accommodations have been made for the Vet Clinic Oncology and Campus Animal Resources vivarium areas at MSU that generate large amounts of contaminated PPE. EHS will provide a 55-gallon lined fiber drum for hazardous drug waste collection in these specific locations.

55-gallon fiberboard barrel with lid

Red medical waste sharps containers and red biohazard bags must not be used for hazardous drug waste.

When reusing empty containers for solutions of hazardous drug waste, they must be compatible with the type of chemical waste stored in them. Empty reagent bottles can be used for chemical waste collection after following the Empty Bottle guidance in the Waste Section of the EHS website.

Although EHS does not maintain a list of compatible materials, in general hazardous drug waste solutions can be stored in glass and plastic containers. However, do not store liquid waste in containers that previously held solids, as they will leak. Container compatibility information is also available on Safety Data Sheets. EHS provides 5-gallon high density polyethylene (HDPE) carboys for liquid hazardous waste storage, which are proven to be compatible with a variety of waste types.

Former ethanol bottle with label completely defaced, the words “Hazardous Waste” on the bottle, and a MSU Waste Tag attached.EHS provided 5-gallon carboy with the words hazardous waste on the label and a MSU Waste Tag attached.

Storage

Waste containers must be kept free of any liquids or residue on their exteriors. EHS Hazardous Waste Staff will reject any container with liquid or residue on the exterior until it has been cleaned.

  • All container lids MUST be closed once requested a Hazardous Waste Request has been submitted to EHS.
  • Do not overfill containers. When the container is full, seal and request disposal through the EHS Hazardous Waste Program.

MSU Waste Tag Required

Yes - A MSU Waste Tag is required for any hazardous drug waste not contained in a pharmaceutical waste container.

No - A MSU Waste Tag is not needed when submitting hazardous drug waste in the pharmaceutical waste containers.

MSU Waste Tags must be directly affixed to the waste container either with string, a twist tie, chain and clipboard, rubber band, or tape. MSU Waste Tags are provided by EHS and can be requested through an EHS Hazardous Waste Request.

Labeling

Pharmaceutical Waste Containers

When using black pharmaceutical containers for hazardous drug waste, it must be labeled with the EHS Hazardous Waste Pharmaceutical label.

Orange and White label with “Hazardous Waste Pharmaceuticals at top

Vet Med Oncology & Vivarium Locations

When utilizing 55-gallon fiber drums for hazardous drug waste, a MSU Waste Tag should be filled out and completed for containers with contaminated PPE. The contact information at the top of the MSU Waste Tag must be filled out to identify where the hazardous waste was generated, the container size and type, and who to contact with questions regarding the waste container.

The Contents should be “PPE contaminated with” and identify the specific drugs being utilized. The Volume column should read “100%”. Check the poison/toxic hazards at the bottom of the MSU Waste Tag.

Hazardous Drug Solutions

A MSU Waste Tag must be filled out and completed for solutions of hazardous drug waste that are not in the original manufacturer’s container.

The contact information at the top of the MSU Waste Tag is needed to identify where the hazardous waste was generated, the container size and type, and who to contact with questions regarding the waste container.

All chemical constituents must be accounted for on the MSU Waste Tag. Chemical names must be printed legibly, in English, and with no abbreviations. The amount of chemical constituents can be captured by either using percentages up to 100%, or by units of volume. Either way, these need to match the amount of waste in the container when EHS arrives to pick up the material. Inaccuracies and discrepancies on the MSU Waste Tag can result in the waste being rejected by the EHS Hazardous Waste Staff for safety and compliance reasons. For aqueous solutions, the check box for “Water Balance” can be used to account for the remaining percentages or volume. Chemical constituents must be identified on the MSU Waste Tag as they are added to the container, as guessing the contents of a full container creates safety and compliance violations.

Review and check all applicable potential hazards at the bottom of the MSU Waste Tag each time when adding waste to the container. The color and consistency section can be completed when the container is full, or when approaching the 90-Day storage limit.

Guidance on how to accurately fill out the MSU Waste Tag can be found in the Waste Section of the EHS website.

Submit Hazardous Waste Request

When the container is full or close to the 90-day accumulation limit, submit a Hazardous Waste Request via the EHS Safety Portal as follows:

  • EHS Website: ehs.msu.edu
  • Log in to the Safety Portal through a preferred web browser using your MSU Net ID and EBS Password
  • Select Hazardous Waste Request
  • Pharmaceutical Waste, Drugs is found under the Common Process category