What is a NIOSH hazardous drug?

Pharmaceuticals as Workplace Hazards


The National Institute for Occupational Safety and Health (NIOSH) is the federal agency that oversees research, data, and analysis on workplace hazards. They have looked into hazardous drugs that healthcare workers may be exposed to and categorized these compounds into three groups. Group 1 is antineoplastic drugs (roughly, chemotherapy medications). Group 2 is other drugs (not antineoplastic) that are hazardous, while Group 3 are drugs that may interrupt fertility in women or men or that may get into breast milk.

Group 1

ado-trastuzumab emtansine
afatinib
altretamine
amsacrine
anastrozole
arsenic trioxide
axitinib
azacitidine
Bacillus Calmette Guerin (BCG)
belinostat
bendamustine
bexarotene
bicalutimide
bleomycin
bortezomib
bosutinib
brentuximab vedotin
busulfan
cabozantinib
capecitabine
carfilzomib
carboplatin
carmustine
chlorambucil
cisplatin
cladribine
clofarabine
crizotinib
cyclophosphamide
cytarabine
dabrafenib
dacarbazine
dactinomycin
dasatinib
daunorubicin
decitabine
degarelix
docetaxel
doxorubicin
enfortumab vedotin
enzalutamide
epirubicin
eribulin
erlotinib
estramustine
etoposide
everolimus
exemestane
floxuridine
fludarabine
fluorouracil
flutamide
fulvestrant
gemcitabine
gemtuzumab ozogamicin
goserelin
histrelin
hydroxyurea
idarubicin
ifosfamide
imatinib
inotuzumab ozogamicin
irinotecan
ixazomib
ixabepilone
letrozole
leuprolide
lomustine
mechlorethamine
megestrol
melphalan
mercaptopurine
methotrexate
mitomycin
mitotane
mitoxantrone
nelarabine
nilotinib
omacetaxine
oxaliplatin
paclitaxel
panobinostat
pazopanib
pemetrexed
pentostatin
pertuzumab
pipobroman
polatuzumab vedotin
pomalidomide
ponatinib
pralatrexate
procarbazine
regorafenib
romidepsin
sacituzumab govitecan
sorafenib
streptozocin
sunitinib
tamoxifen
temozolomide
temsirolimus
teniposide
thioguanine
thiotepa
topotecan
trabectedin
trametinib
trastuzumab deruxtecan
trifluridine/tipiracil (combination only)
triptorelin
valrubicin
vandetanib
vemurafenib
vinblastine
vincristine
vinorelbine
vismodegib
vorinostat
ziv-aflibercept

What is a NIOSH hazardous drug?

Group 2

abacavir
alefacept
apomorphine
azathioprine
carbamazepine
chloramphenicol
cidofovir
cyclosporine
deferiprone
dexrazoxane
diethylstilbestrol
divalproex
entecavir
estradiol
estrogen/ progesterone combinations
estrogens, conjugated
estrogens, esterified
estropipate
fingolimod
fluoxymesterone
fosphenytoin
ganciclovir
leflunomide
lenalidomide
liraglutide recombinant
medroxyprogesterone acetate
methimazole
mipomersen
mycophenolate mofetil
mycophenolic acid
nevirapine
ospemifene
oxcarbazepine
palifermin
phenoxybenzamine
phenytoin
pipobroman
progesterone
progestins
propylthiouracil
raloxifene
rasagiline
sirolimus
spironolactone
tacrolimus
teriflunomide
thalidomide
tofacitinib
uracil
valganciclovir
zidovudine

Group 3

acitretin
alitretinoin
ambrisentan
bosentan
cabergoline
cetrorelix
choriogonadotropin
clomiphene
clonazepam
colchicine
dinoprostone
dronedarone
dutasteride
eslicarbazepine
ergonovine/methylergonovine
finasteride
fluconazole
ganirelix
gonadotropin, chorionic
icatibant
lomitapide
macitentan
mentropins
methyltestosterone
mifepristone
misoprostol
nafarelin
oxytocin
pamidronate
paroxetine
pasireotide
pentetate calcium trisodium
peginesatide
plerixafor
ribavirin
riociguat
temazepam
testosterone
topiramate
tretinoin
ulipristal
valproate/valproic acid
vigabatrin
voriconazole
warfarin
ziprasidone
zoledronic acid
zonisamide

Related: Safety FAQs


<p>
The Biotechnology Industry Organization (BIO) wishes to thank NIOSH for the opportunity to submit comments on the National Institute for Occupational Safety and Health&rsquo;s (NIOSH&rsquo;s) revisions to &ldquo;Appendix A. Drugs Considered Hazardous, in the NIOSH Alert: Preventing Occupational Exposures to Antineoplastic and other Hazardous Drugs in Healthcare Settings,&rdquo; DHHS Publication No. 2004-165 (2004). The safe handling of drugs and biologics is an important issue for healthcare workers and BIO supports the efforts NIOSH has taken to update the Hazardous Drugs List. We also strongly support NIOSH for incorporating well-accepted scientific principles in the decision-making process, such as consideration of mechanism, route of exposure, potency, and the principles of risk assessment.</p>

Re: Updating the List of Hazardous Drugs for the NIOSH Alert: Additions and Deletions to the NIOSH Hazardous Drug List; Federal Register Volume 74, Number 81, Pages 19570-19571; 29 April 2009; Docket Number NIOSH-105-A

Dear Sir or Madam:

The Biotechnology Industry Organization (BIO) wishes to thank NIOSH for the opportunity to submit comments on the National Institute for Occupational Safety and Health’s (NIOSH’s) revisions to “Appendix A. Drugs Considered Hazardous, in the NIOSH Alert: Preventing Occupational Exposures to Antineoplastic and other Hazardous Drugs in Healthcare Settings,” DHHS Publication No. 2004-165 (2004). The safe handling of drugs and biologics is an important issue for healthcare workers and BIO supports the efforts NIOSH has taken to update the Hazardous Drugs List. We also strongly support NIOSH for incorporating well-accepted scientific principles in the decision-making process, such as consideration of mechanism, route of exposure, potency, and the principles of risk assessment.

BIO represents more than 1200 biotechnology companies, academic institutions, state biotechnology centers and related organizations across the United States and in more than 30 other nations. BIO members are involved in the research and development of innovative healthcare, agricultural, industrial and environmental biotechnology products, thereby expanding the boundaries of science to benefit mankind by providing better healthcare, enhance agriculture, and a cleaner and safer environment. We appreciate both the opportunity to submit general and specific comments on the Hazardous Drug Alert and your inclusion of BIO as a representative stakeholder.

We support the scientific rigor in NIOSH’s process to identify those drugs “Fitting” the criteria described in “New FDA Drugs and Warnings Fitting NIOSH Criteria for Hazardous Drugs 2006” on the NIOSH web site. The inclusion of the National Academy of Sciences 4-step principles of risk assessment (hazard identification, exposure assessment, dose-response assessment and risk characterization) (NRC, 1983) is exemplified, and the risk-classification system identified only those drugs that are "hazardous" in the occupational context. This facilitates appropriate handling and exposure control precautions and properly directs limited health care resources. NIOSH has addressed the recommendations in our letter dated January 30, 2008 and we commend these changes to Appendix A of the Hazardous Drug Alert.

Need for Stakeholders to Understand the Process/Approach Used to Develop the Lists of Drugs "Fitting" and "Not Fitting" the NIOSH Criteria.

Comment 1: The “Update of NIOSH Hazardous Drug List (Appendix A) for the NIOSH Alert: Preventing Occupational Exposures to Antineoplastic and other Hazardous Drugs in Healthcare Settings (April 6, 2009)”, on the NIOSH web site, explains why some drugs have been included and others excluded, and the selection and evaluation process. BIO supports this transparency and the adoption of the weight-of-evidence approach that incorporates consideration of all scientifically relevant information, e.g., molecular weight and bioavailability by the routes of exposure traditionally considered in occupational health risk assessments (i.e., inhalation, oral, and dermal).

2. Exclusion of High Molecular Weight Proteins (HMWPs) from the Hazardous Drugs List

Comment 2: Occupational exposure traditionally focuses on three exposure pathways: dermal, oral and inhalation. For the reasons described below, and unlike for small molecular weight pharmaceuticals, none of these exposure pathways are likely to be of concern for high molecular weight protein (HMWPs) therapeutics.

The skin, pulmonary system, and gastrointestinal system are effective barriers to absorption of HMWP therapeutics (molecular weights ~50-150 kDa). There is an extremely low likelihood of absorption. Biotherapeutics are IgG-based and "immunoglobulins have restricted access across diffusional barriers unless transport is facilitated by specific mechanisms" (Roskos, 2004); this is the reason these drugs are administered only by injection. In addition, it has been suggested that a compound must be < 500 daltons (0.5 kDa) to penetrate the stratum corneum (the outermost layer of the epidermis) (Bos and Meinardi, 2000). Monoclonal antibodies (mAbs), for example, are 300 times larger than this maximum size. HMWP therapeutics are intricately folded proteins that are easily susceptible to denaturation (unfolding and subsequent aggregation) from environmental conditions (Vermeer and Norde, 2000), and loss of biological activity would occur in the acidic environment in the stomach. Due to the large particle size of HMWP therapeutics (approximately 10), the pulmonary system provides an effective barrier to absorption.

The risks of genotoxicity are non-existent or very low for biotherapeutics because they are not designed to interact directly with DNA or other chromosomal material (ICH S6, 1997).

BIO supports NIOSH’s approach to evaluating each drug on an individual basis and not on its classification. With few exceptions, HMWP therapeutics will not meet the criteria for a “hazardous drug” using this approach, after consideration of the available toxicological and clinical data scientific for each one. We encourage NIOSH to continue to apply this case-by-case, scientific approach. For example, we encourage NIOSH to carefully examine biologics proposed for addition to the list and consider the removal of those for which the only concern is potential mutagenicity at therapeutic doses that require parenteral administration over prolonged periods of time.

3. Harmonization with Other Handling Recommendations

Comment 3: BIO agrees that the current approach described in the “Update of NIOSH Hazardous Drug List (Appendix A) for the NIOSH Alert: Preventing Occupational Exposures to Antineoplastic and other Hazardous Drugs in Healthcare Settings (April 6, 2009)”, on the NIOSH web site, is harmonized with handling recommendations of other expert groups. Specifically, the current approach is harmonized with that of U.S. Food and Drug Administration (FDA) (referring to the reliance on Pregnancy Categories), and the British Centralized Intravenous Additives Group (ClVAS) and British Oncology Pharmacy Association (BOPA) ClVAS and BOPA (ClVAS/BOPA, 2001). By identifying only those drugs that are "hazardous" in the occupational context, appropriate handling and exposure control precautions will be taken and limited health care resources will be wisely used to protect against drugs that do represent a hazard in the workplace.

Conclusion

The scientific accuracy of the NIOSH Alert is essential in contributing to the use of best practices for worker occupational health and safety programs and hazard communication. BIO supports NIOSH’s transparency in the decision-making process, and use of a public comment process to solicit input on the proposed update to the Hazardous Drug Alert. We commend NIOSH in their use of well-accepted scientific principles to identify drugs that meet the Hazardous Drug Alert criteria, including relating low-dose effects of hazardous drugs to the hazard categories of organ, developmental, and reproductive toxicity.

For HMWP therapeutics, the use of hazard characterization vs. hazard identification allows consideration of the potential for many factors, such as absorption, bioavailability, potency, dose-response of drugs, and margin of safety between the exposure levels that a healthcare worker may be exposed to and the exposure levels known to cause adverse effects. To assure scientifically sound guidelines on the potential risk to healthcare workers handling hazardous drugs, we agree it is critical that these be taken into account. BIO supports NIOSH’s approach to evaluating each drug on an individual basis and not on its classification; with few exceptions, HMWP therapeutics will not meet the criteria for a “hazardous drug” based on the scientific evidence. The scientific approach used to update the Hazardous Drug Alert is consistent with those of other expert groups, and further strengthens its importance in providing guidance on risk assessment and exposure controls to employees and employers in healthcare settings.

We appreciate your consideration of these comments. We would be pleased to discuss them with members of the NIOSH staff at your convenience.

Respectfully submitted,

/s/

Sara Radcliffe

Vice President, Science & Regulatory Affairs

Biotechnology Industry Organization

cc: Debora Van der Sluis, Senior Manager, Product Stewardship Programs, Environment, Health and Safety, Genentech (BIO’s representative to the Hazardous Drugs Update panel)

____________________________________

References

Bos, J.D., and Meinardi, M.M. (2000) The 500 dalton rule for the skin penetration of chemical compounds and drugs. Experimental Dermatology, 9 (3): 165-169.

CIVAS/BOPA (2001) Monoclonal Antibodies. Hospital Pharmacist, 8:153, June.

NRC (National Research Council) (1983) Risk Assessment in the Federal Government: Managing the Process. National Academy Press, Washington, D.C.

Roskos, L. K., Davis, C. G., & Schwab, G. (2004). The clinical pharmacology of therapeutic monoclonal antibodies. Drug Development Research, 61 (3), 108-120.

ICH. (1997). ICH S6: Preclinical Safety Evaluation of Biotechnology-Derived Pharmaceuticals: International Conference on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use. 

What is a NIOSH drug?

The NIOSH List is an aid designed to enable employers to identify which drugs handled by employees are considered by NIOSH to be hazardous drugs. Because new drugs and new formulations are continuously brought to market between NIOSH's periodic updates hazardous drug evaluation should be a continual process.

What are the three types of hazardous drugs?

DHHS (NIOSH) Publication No. The format for the 2014 list was revised to include three groups of hazardous drugs: (1) Antineoplastic drugs; (2) Non-antineoplastic hazardous drugs; and (3) Drugs with reproductive effects.

Which of the following are NIOSH characteristics of hazardous drugs?

The National Institute for Occupational Safety and Health (NIOSH) considers a drug to be hazardous if it exhibits one or more of the following characteristics in humans or animals: carcinogenicity, teratogenicity or developmental toxicity, reproductive toxicity, organ toxicity at low doses, genotoxicity, or structure ...

What medications are hazardous drugs?

Antineoplastic cytotoxic medications, anesthetic agents, anti-viral agents, and others, have been identified as hazardous. These hazardous medications are capable of causing serious effects including cancer, organ toxicity, fertility problems, genetic damage, and birth defects.