Managing cytotoxic waste

What is cytotoxic waste?

Cytotoxic waste includes any residual cytotoxic medicine that remains following patient treatment. It also includes any materials or equipment that may be contaminated with cytotoxic medicines, such as:

• unused cytotoxic pharmaceuticals
• sharps and syringes
• intravenous infusion sets and containers
• ampoules and vials
• personal protective equipment (PPE) and clothing
• dressings and bandages
• stoma bags/equipment, incontinence aids (such as pads, nappies) and other biological waste such as vomitus
• linen.

Cytotoxic waste is hazardous to human health and the environment. Cytotoxic substances are:

• prescribed as a form of reportable priority waste
• subject to strict regulation by the Environment Protection Authority Victoria (EPA Victoria).

A key element of any waste management strategy is to create policies and systems to avoid and minimise waste.

Establishing a cytotoxic waste management strategy

Employers should develop and periodically review a strategy to safely manage cytotoxic waste. To help with this process, employers should:

• audit what cytotoxic waste is generated or potentially generated
• identify the chain of responsibility and which employees should manage cytotoxic waste.

Employers can use the following guidance to help develop a strategy:

Key elements of a cytotoxic waste strategy

Your cytotoxic waste strategy should have the following key elements:

• A designated person who is responsible for ensuring an efficient waste disposal system:
  • is maintained
  • controls any risk
  • complies with legal requirements.
• Systems to avoid and minimise waste in consultation with:
  • Health and Safety Representatives (HSRs)
  • the areas that are generating the waste
  • waste-handlers
  • waste disposal employees.
• A procedure to identify, segregate, package, store, transport, administer and dispose of cytotoxic waste.
• A system to manage cytotoxic waste generated. This includes outpatients and domiciliary services under the direction of a hospital.
• An internal and external transport and disposal flowchart from the waste generator to the disposal site.

Employers must, so far as is reasonably practicable, consult with employees and any HSRs when creating strategies, systems and procedures for cytotoxic waste control.

Identifying, containing, segregating and storing cytotoxic waste

Identifying waste

Cytotoxic medicines and their waste products are universally identified by the purple symbol in Figure 1 (see Labelling of cytotoxic medicines). Waste containers should be identified with the words 'CYTOTOXIC WASTE' on at least two sides.

Containing waste

The requirements for packaging and transporting cytotoxic waste are set out in the Environmental Protection Regulations 2021.

Employers should use the following control measures:

• Bag the waste and put into the appropriate cytotoxic hazard waste bin for transport to the waste disposal facility. To minimise exposure, cytotoxic waste bins with a foot-opening mechanism are recommended.
• Where cytotoxic medicines are used outside a workplace, such as at home, a leak-proof plastic bag may be sufficient. The workplace should provide advice to the patient being treated at home on appropriate waste packaging and any labelling requirements. Also see Administering cytotoxic medicines and caring for patients:
  • 'Spills in home and community care settings'.
  • 'When patients leave a treating facility'.
• Store sharps in a rigid-walled container according to AS 23907:2023 Sharps injury protection - Requirements and test methods.

Segregating waste

Cytotoxic waste should be segregated from other waste streams through the following control measures:

• Segregate waste at the point of generation and at the earliest possible stage.
• Keep cytotoxic waste separate from the rest of the waste stream during internal transport and storage.
• Minimise time between waste creation and waste disposal.
• Minimise human contact with waste.
• Ensure that non-rigid receptacles are placed in a rigid-walled container for transport to the collection area. For example, a wheelie bin of the appropriate colour and labelling.
• Keep labelled bins secured with mobile or fixed stands.

Develop procedures in consultation with:

• employees who work in areas that produce cytotoxic waste
• any HSRs
• those responsible for providing support services.

Storing waste

Employers should use the following control measures when storing cytotoxic waste:

• Store cytotoxic waste in a dedicated, identified and secure storage area. This should have adequate lighting and ventilation.
• Locate storage areas away from areas that may affect others and the environment, such as drains.
• Ensure storage areas are easy to clean and decontaminate (as per the Safety Data Sheet (SDS)).
• Seal cytotoxic waste bins before collection and do not open or reprocess on site.
• Place sealed bins or bagged material in specially designed large receptacles while awaiting collection for off-site transport.
• Refrigerate waste that is stored for more than 72 hours before disposal. This is particularly important where it is mostly organic and can decompose.
• Appropriately label designated waste areas and containers.

Transporting waste

Waste producers such as healthcare facilities have legal obligations for the cytotoxic waste they generate.

On-site waste transport

Employers should use the following control measures when transporting waste within the site:

• Train employees who manage cytotoxic waste.
• Maintain equipment used for transporting waste. For example, trolleys or wheelie bins.
• Collect waste frequently so it does not accumulate and cause housekeeping hazards at user sites.
• Manage spills that occur during on-site transport.
• Do not transport cytotoxic waste in waste disposal chutes. These are likely to cause breakages.

Off-site waste transport

EPA Victoria regulates the proper transport of cytotoxic waste in Victoria. The transport of reportable priority waste, which includes cytotoxic substances, is covered by: