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Managing Dental Mercury

6 NYCRR Part 374-4 

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Information on 6 NYCRR 

Part 374-4 Regulations

NY Dental Mercury & 

Amalgam Recycling Law

Recycling of Mercury By 

Dentists FAQ

Guide for Dentists for 

Managing Mercury and 

Amalgam Wastes

List of Mercury and Dental 

Amalgam Recyclers & 

Hazardous Waste Haulers

List of Amalgam Separator 

Manufacturers

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Hazardous Waste Programs 

That Accept Mercury From 

Dentists

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NYSDEC 

Bureau of Solid 

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Recycling 

625 Broadway 

Albany, NY 12233-

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Managing Dental 

Mercury 

Effective March 16, 2003, New York 

State Law requires that all dentists 

recycle mercury and mercury amalgam 

waste generated in their practices. The 

law also requires that dentists use 

encapsulated mercury and prohibits, in 

the practice of dentistry, the use or 

possession of elemental mercury not in 

capsules. Effective May 12, 2006, dental 

facilities are required to install amalgam 

separators that remove waste amalgam 

from the dental facilities' wastewater. 

A list of amalgam separator 

manufacturers is available. This is an 

informational list and is not endorsed by 

the Department. Specific regulatory 

requirements are provided under 

Subpart 374-4. Multiple questions dental 

facilities may have concerning the 

installation of amalgam separators are 

also addressed. 

Elemental Mercury (also referred to as 

free, bulk, or raw mercury) 

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Publications, Forms, Maps

About DEC

New York State Law forbids the use 

or possession of elemental mercury in 

the practice of dentistry. Amalgam 

capsules must be used. 

In the event that elemental mercury is 

present in your dental office: 

z Recycle all elemental mercury. Many 

hazardous waste haulers and dental 

amalgam recyclers will accept 

elemental mercury for recycling. 

z Never rinse elemental mercury down 

the drain. 

z Never dispose of elemental mercury 

in the trash. 

z Never dispose of elemental mercury 

in the sharps container or as medical 

waste. 

z If only a small amount of elemental 

mercury is to be recycled, it may be 

possible to initiate a reaction with an 

amalgam alloy to form scrap 

amalgam, which must then be 

recycled through your amalgam 

recycler. 

Some solid waste planning units (such 

as in Erie, Monroe, Otsego, Rockland, 

Oneida-Herkimer and Cayuga Counties) 

offer elemental mercury recycling 

programs, which allow dentists to safely 

manage their elemental mercury. Some 

will charge a fee for this service. Call 

your local solid waste district to inquire 

about such programs. A list of New York 

State recycling coordinators. 

Additionally, a list of household 

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hazardous waste collection contacts. 

If you are concerned about the possible 

uncontained presence of mercury in your 

dental office due to historical or recent 

mercury spills, equipment is available for 

the detection of mercury vapor and 

mercury spill locations in the workplace 

environment. This equipment can be 

rented from rental test equipment 

companies. 

Amalgam Capsules

New York State Law requires that all 

amalgam capsule waste be recycled. 

If your dental practice continues to utilize 

dental amalgam, New York State Law 

requires the use of single-use amalgam 

capsules. This minimizes the chance of 

accidental mercury spills. 

Minimize the generation of amalgam 

waste. Don't mix a double-use capsule if 

a single-use capsule will do. Less waste 

means less amalgam that needs to be 

recycled. 

In the event of a mercury spill, put on 

disposable nitrile gloves and immediately 

clean up the spill utilizing a mercury spill 

kit. Do not use latex gloves as mercury 

can penetrate latex. Mercury spill kits are 

available from a number of sources 

including: companies that specialize in 

Occupational Safety and Health 

Administration (OSHA) compliance 

supplies and equipment; amalgam 

recyclers; and dental product suppliers. 

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Before purchasing a kit, make sure it 

comes with complete instructions on how 

to perform a spill clean up. Train several 

staff members in proper spill clean up 

procedures. 

Dental Amalgam

z Never put scrap amalgam in the 

sharps container. 

z Never put scrap amalgam in the red 

biohazard bag. 

z Never discard scrap amalgam in the 

trash. 

z Never rinse scrap amalgam down the 

drain. 

z Never remove excess amalgam from 

the amalgam well with the high-speed 

suction vacuum line. 

z Never clean up a mercury spill using 

a vacuum cleaner. 

z Never place extracted teeth with 

amalgam restorations in the red 

biohazard bag. They should be placed 

in a container that is acceptable to 

your recycler. Precautions, such as 

glasses, gloves, and mask, should be 

used when handling extracted teeth. 

Recycling Scrap Amalgam

New York State Law requires you to 

recycle all amalgam waste. Follow the 

requirements of your amalgam 

recycler for the storage, disinfection 

and shipping of scrap amalgam. 

z Collect and store all contact and nonManaging Dental Mercury - NYS Dept. of Environmental Conservation Page 4 of 16

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contact scrap amalgam, capsule 

waste and extracted teeth with 

amalgam restorations in separate, 

appropriately labeled, tightly closed 

containers. 

z Recycle scrap amalgam through an 

amalgam recycler. 

z Do not use heat. If contact amalgam 

must be disinfected before shipment 

to your recycler, do not use any 

method that utilizes heat. The heat 

will cause the mercury to volatilize 

and be released into the environment. 

z Do not decant liquid. If you store 

scrap amalgam under used 

radiographic fixer, water, or other 

liquid, do not, under any 

circumstances, decant the liquid down 

the drain. Contact your dental 

amalgam recycler or hazardous waste 

hauler for more information on how to 

dispose of this material properly. 

Chair-side Traps

The control of waste dental amalgam 

includes proper management of the 

traps and filters used in your office 

vacuum system. Disposable amalgam 

traps are preferable to reusable traps 

because of the difficulty in effectively 

removing amalgam particles from the 

trap without spilling the particles into the 

drain or garbage. In addition, consider 

replacing size 40 mesh traps with size 

100 mesh traps if your suction system 

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can function adequately with the smaller 

mesh. Although finer screens may be 

more effective at trapping amalgam 

particles, they may require cleaning and 

changing more often. 

Check with your dental amalgam 

recycler to determine if disposable 

amalgam traps are accepted. Disposable 

amalgam traps should not be placed in 

the regular garbage or with medical 

waste and must also be sent for 

recycling. 

Amalgam Traps

Precautions, such as glasses, gloves 

and mask, should be used when 

handling the chair-side trap. These traps 

should be changed as often as 

necessary. 

The vacuum system should be flushed 

with disinfecting line solution before 

changing the chair-side trap. Research 

has suggested that some types of line 

cleansers, such as those that contain 

bleach, may dissolve mercury from 

amalgam particles. This would increase 

the release of mercury into the dental 

wastewater. 

According to the American Dental 

Association, the following line cleansers 

do not contain bleach or chlorine and do 

not appear to dissolve mercury from 

amalgam. This is an informational list 

and is not endorsed by the Department 

or the American Dental Association. You 

should check with your equipment 

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manufacturer to determine the 

appropriate line cleanser for your 

equipment: 

z Biocide (Biotrol International) 

z BirexSe (Biotrol International) 

z DRNA Vac (Dental Recycling North 

American, Inc.) 

z E-Vac (L&R Manufacturing Co.) 

z Fresh-Vac (Huntington) 

z GC Spray-Cide (GC America Inc.) 

z Green and Clean (Metasys) 

z Microstat 2 (Septodont USA) 

z Patterson Brand Concentrated 

Ultrasonic Cleaner/Disinfectant 

Solution (Patterson Dental Supply, 

Inc.) 

z ProE-Vac (Cottrell Ltd.) 

z Pure-Vac (Sultan Chemists Inc.) 

z Sani-Treet Plus (Enzyme Industries 

Inc.) 

z SRG Evacuation (Icon Labs) 

z Stay Clean (Apollo Dental Products) 

z Turbo-Vac (Pinnacle Products) 

z Vacusol Ultra (Biotrol International) 

z Cavicide (Metrex Research Corp.) 

z Vacuum Clean (Palmero Health Care) 

The best method is to flush the line with 

an appropriate line cleanser at the end of 

the day. The trap should be changed the 

next morning before the suction is used. 

This method will allow the particles in the 

trap to dry. 

An alternative method is to flush the 

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system with a cleaning solution 

according to the product's directions. 

The lid may then be removed from the 

trap. This allows air to pass through the 

trap until the contents are dry (usually 

not more than five minutes). 

Replaceable Amalgam Traps

Steps to clean this type of trap are: 

z Open the chair-side dental unit to 

expose the amalgam trap. 

z Remove non-amalgam fragments 

such as cement from the trap with 

cotton forceps and discard in the 

garbage. 

z Remove all visible amalgam by 

tapping the contents into a properly 

labeled container. Close the cover 

tightly. 

z If the trap is visually clean, it can be 

reused. A heavily contaminated trap 

should always be recycled. Store 

contaminated traps in the properly 

labeled container. 

Disposable Amalgam Traps

z Remove the amalgam trap and place 

it in a properly labeled container. 

z Do not clean disposable traps under 

running water or discharge the 

trapped amalgam into the wastewater 

system. 

z Do not discharge the trapped 

amalgam into the sharps container, as 

medical waste, or in the trash. 

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Vacuum Pump Filters (by the central 

suction pump) 

z Replace vacuum pump filters 

regularly as recommended by the 

equipment manufacturer. 

z Remove the filter. While holding it 

over a tray or other container that can 

catch spills, decant as much liquid as 

possible without losing visible 

amalgam. The decanted, amalgamfree liquid can be rinsed down the 

drain. 

z Put the lid on the filter and place it in 

the box in which it was originally 

shipped. When the box is full, the 

filters must be recycled. Be sure to 

check with your amalgam recycler to 

ensure that they will take these filters. 

z Do not dispose of used vacuum pump 

filters in the sharps container, as 

medical waste, or in the trash. 

Amalgam Separators

New York State regulations now 

require the installation and use of 

dental amalgam separators for new 

dental facilities starting operations 

after May 12, 2006. Dental facilities 

operating prior to May 12, 2006 are 

allowed a two-year phase in period 

(by May 12, 2008) to install and 

maintain in operation dental amalgam 

separators. Other specific 

requirements apply and are stated in 

Subpart 374-4.

Dental amalgam separators will remove 

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the maximum amount of amalgam waste 

and are much more efficient in removing 

amalgam from the dental wastewater 

than filters and traps used in chair-side 

dental units and vacuum lines. Most 

amalgam separators can attain an 

efficiency of 99 percent removal of 

amalgam. 

An amalgam separator must be installed 

in dental facilities where dental amalgam 

is applied, altered, maintained, removed, 

disposed, generated or where elemental 

mercury is used or possessed by 

licensed dentists. An amalgam separator 

must treat all dental facility waters likely 

to come into contact with dental 

amalgam waste prior to discharge. This 

includes wastewater from chair-side 

water collection units as well as sinks 

and drains. 

The only dental facilities not required to 

install an amalgam separator are 

specialties where orthodontics, 

periodontics, prosthodontics and oral 

and maxillofacial surgery are exclusively 

performed. 

Although the department does not 

endorse any specific amalgam 

separators, a list of dental amalgam 

separator companies is available. The 

following criteria should help you select 

the right system for your facility: 

z The system must be effective. The 

manufacturer must be able to prove 

that the system can remove the 

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amalgam from the wastewater 

regardless of particle size. An 

amalgam separator placed into 

service after May 12, 2006 must 

achieve 99 percent removal 

efficiency. 

z The separator must be properly sized 

for the volume and flow of the dental 

facility amalgam wastewater in 

accordance with the manufacturer's 

specifications and recommendations. 

The maximum allowable flow rate 

through the amalgam separator may 

not exceed the maximum flow rate 

capacity that the separator was tested 

at and passed in meeting International 

Standards Organization (ISO-11143). 

z Available space for the installation 

and subsequent access to that space 

for equipment replacement and 

maintenance should be considered. 

z There should be no compromise in 

suction power. 

z You may want to consider a unit that 

is hands-off. The dentist or staff 

should not have to perform a series of 

manual operations or be required to 

handle and change filters. 

z The captured amalgam must be 

recycled. Consider a company that 

both sells the system and arranges for 

the recycling of the captured 

amalgam. You should, at minimum, 

request information from the company 

that sold you the unit about how to 

assure that the captured amalgam is 

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recycled. 

z Simplicity of design is a plus. There 

will be fewer chances for something to 

go wrong. 

z The unit should operate quietly. 

z The unit should come with a fail-safe 

mechanism that protects you from a 

spill or back-up in the event that a 

blockage occurs. 

z The unit should install centrally so that 

the appropriate wastewater streams 

pass through it before discharging into 

the sewer system. 

z The unit should be reasonably priced. 

Obtain information from the 

companies on both short and long 

term costs (including maintenance 

and parts replacement) over a five to 

ten year period before making a 

decision. 

Plumbing Replacement and Repairs

Mercury from prior dental procedures 

often settles at low points in the 

plumbing such as sink traps and sumps. 

The slow dissolution of the mercury in a 

sink trap or sump can release mercury 

into the wastewater for years after past 

disposal practices have been corrected. 

When there is a possibility that plumbing 

repairs or demolition may disturb 

adhered amalgam waste, dental offices 

should follow common sense 

approaches and guidelines to protect the 

environment and those working in the 

dental facility. For instance, you should 

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advise your plumber that whenever 

plumbing parts are removed or cleaned, 

caution should be taken to avoid spilling 

the contents in case amalgam or 

mercury are present. The sludge from 

the pipes should be poured or brushed 

out and handled as contact amalgam. 

The plumbing parts can then be put back 

in place or recycled. 

Additional Sources of Mercury in 

Dental Offices

Electrical equipment with switches, 

relays or temperature controls 

(thermostats) may contain mercury and 

should be properly recycled when 

replaced. 

Mercury thermometers and blood 

pressure units are also sources of 

elemental mercury. The following steps 

should be followed in the event that one 

of these items break: 

z Put on nitrile gloves. Do not use latex 

gloves as mercury can penetrate 

latex. 

z Clean up all visible elemental mercury 

using a mercury spill kit. Mercury spill 

kits are available from a number of 

sources including: companies that 

specialize in Occupational Safety and 

Health Administration (OSHA) 

compliance supplies and equipment; 

amalgam recyclers; and dental 

product suppliers. Before purchasing 

a kit, make sure it comes with 

complete instructions on how to 

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perform a spill clean up. Train several 

staff members in proper spill clean up 

procedures. 

z Place all contaminated items 

(materials used during the clean up 

procedure and broken pieces of 

glass) in a sealable plastic bag or 

container. Label the bag or container 

as "Mercury Waste". 

z Dispose of all contaminated materials 

through a hazardous waste hauler. 

z Never dispose of mercury 

contaminated waste in the sharps 

container, as medical waste, or in the 

trash. 

z Never dispose of elemental mercury 

down the drain or in the sharps 

container, as medical waste, or in the 

trash. 

z Consider replacing mercurycontaining equipment with nonmercury containing alternatives. Nonmercury containing products are 

usually available for many of these 

products at cost-competitive prices. 

Office Renovations

Alert renovators to the possibility of 

historical mercury spills that may have 

resulted in the presence of mercury in 

carpets, floor cracks, behind mouldings 

and other areas where elemental 

mercury may have been used or where 

amalgam capsules may have been 

spilled. 

The above procedures were adapted for 

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New York State's use from "The 

Environmentally Responsible Dental 

Office: a Guide to Proper Waste 

Management in Dental Offices", 

prepared by the Northeast Natural 

Resource Center of the National Wildlife 

Federation and the Vermont State 

Dental Society, June 1999.

Additional information may be obtained 

by contacting the New York State 

Department of Environmental 

Conservation, Bureau of Solid Waste, 

Reduction & Recycling at (518) 402-

8705 or by e-mail at: 

dshmwrr@gw.dec.state.ny.us

More about Managing 

Dental Mercury: 

6 NYCRR Part 374-4 Express Terms - 

Standards for the Management of 

Elemental Mercury and Dental 

Amalgam Wastes at Dental Facilities. 

Information on 6 NYCRR Part 374-4 

Regulations - Describes the regulations 

for managing mercury and dental 

amalgam wastes at dental facilities. 

NY Dental Mercury & Amalgam 

Recycling Law - Recycling of 

Elemental Mercury and Dental 

Amalgam -- It's the Law in New York 

State. Chapter 506, Laws of New York, 

2002. 

Recycling of Mercury By Dentists FAQ - 

Frequently Asked Questions From 

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Dentists. 

Guide for Dentists for Managing Mercury 

and Amalgam Wastes - Recycling of 

Elemental Mercury and Dental 

Amalgam by Dentists. 

List of Mercury and Dental Amalgam 

Recyclers & Hazardous Waste Haulers

- List of companies and hazardous 

waste haulers that will accept 

elemental mercury for recycling. 

List of Amalgam Separator 

Manufacturers - A list of manufacturers 

that have submitted the appropriate 

certifications/test reports to DEC. 

Community Household Hazardous 

Waste Programs That Accept Mercury 

From Dentists - List of Communities in 

NYS that mercury dental waste. 

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