Best Management Practices for 

Common Dental Office Wastes 

{ Regulatory Considerations 

{ Best Management Practices 

{ Dental Amalgam 

{ X-ray Fixer 

{ X-ray Developer 

{ Dental Film

{ Lead Foil 

{ Cleaners for X-ray Developer 

Systems 

{ Sterilizing and Disinfectants 

{ Ultrasonic Cleaners 

{ Expired Pharmaceuticals 

{ Universal Wastes 

{ Regulated Medical Waste 

{ Office Waste 

{ More Resources 

{ State Resources

 AL | CA | CO | CT | FL | IN | ME | MA | MN | NY | OH | OR | VT | VA | WA | WI

This fact sheet provides an overview of best management practices for handling and recycle/disposal of 

wastes commonly generated at dental offices. Some of these wastes are designated as hazardous wastes, 

and in some cases universal wastes. Such designations require that you follow special federal and state 

regulations for management of these materials. The best management practices presented here are to the 

best of our knowledge, consistent with the federal hazardous and universal waste regulations, however, 

these practices should be used in conjunction with an overall program that assures compliance with all 

applicable federal and state rules. To assist you in investigating and complying with the regulations, a short 

discussion on regulations with links to more detailed information has been included in this section. 

Regulatory Considerations 

The focus of this section is on best management practices for wastes that are commonly generated in dental 

offices. Some of these wastes are defined as hazardous waste under the Resource Conservation and 

Recovery Act (RCRA) and therefore require special attention. 

Federal Hazardous Waste Regulations. From a regulatory standpoint, nearly all dental offices meet the 

RCRA definition of Conditionally-Exempt Small Quantity Generators (CESQGs), which are businesses 

who generate less than 100 kg of non-acute hazardous waste a month and less than 1 kg of acute 

hazardous waste a month. As such, the vast majority of dental offices are exempt from the federal

hazardous waste regulations as long as they comply with three basic management requirements: 

z you must identify all hazardous waste that you generate, 

z you may not store more than 2,200 lbs (1,000 kg) of hazardous waste on site at any time, and 

z you must ensure delivery of your hazardous waste to an off-site treatment, recovery or disposal 

facility. 

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For a detailed discussion of hazardous waste regulations, see HERC’s Hazardous Waste section. 

State Hazardous Waste Regulations. It is very important to note that some states have additional 

requirements for CESQGs and several states do not recognize this category and therefore have fewer 

exceptions from the rules. For example, some states require CESQGs to follow some or all of the 

requirements of “small quantity generators” (SQGs) such as obtaining an EPA identification number, or 

complying with storage standards. You can investigate your state requirements using the HERC Hazardous 

Waste State Locator. This locator will provide an overview of your state rules, specific information for 

CESQGs, links to guidance documents and a point of contact at your state environmental agency. 

Universal Wastes. Certain types of hazardous wastes that are discussed in this section have been 

designated by EPA as universal wastes. The universal waste regulations streamline collection 

requirements for certain hazardous wastes in the following categories: batteries, pesticides, mercurycontaining equipment (e.g., thermostats) and lamps (e.g., fluorescent bulbs). The universal rule is designed 

to reduce hazardous waste in the municipal solid waste stream by making it easier for businesses to collect 

these items and send them for recycling or proper disposal. For more information on universal waste 

regulations, see HERC’s Universal Waste section. 

State definitions and regulations relating to universal wastes often differ from the federal rules. Therefore, 

you are encouraged to check the page for your state on the HERC Universal Waste State Resource Locator

for state-specific information. 

Best Management Practices 

The following provides an overview of best management practices and links to more detailed information for 

common dental office wastes. Be certain to check your state hazardous and universal waste rules to make 

sure that these practices do not violate state regulations. 

Portions of the information in this section are drawn from several sources, including: 

z A Guide for Dentists – How to Manage Waste Solid & Hazardous Waste, University of Wisconsin, Solid 

& Hazardous Waste Education Center (SHWEC). 

z Dental, Medical and Veterinary Offices: Managing Your Hazardous Waste, California Department of 

Toxic Substances Control. 

z Best Management Practices for Amalgam Waste, American Dental Association. 

Dental Amalgam 

Dental amalgam contains a mixture of metals such as silver, copper and tin, in addition to mercury, which 

chemically binds these components into a hard substance. In recent years there has been controversy over 

the use of this material for dental fillings. The Federal Drug Administration (FDA) identifies amalgam as a 

potential health risk when amalgam fillings are placed in or removed from teeth. Mercury vapor is also 

released during chewing. See FDA Q&A on dental amalgam for more information on dental amalgam and 

alternatives. 

In addition to proposed federal regulations, some states have enacted or proposed laws that limit the use of 

amalgam, that require dentists to inform patients of the risks involved in using amalgam, or that offer 

alternatives (see EPA summary of state legislation). 

The focus of this section is best management practices. We have not attempted to present a summary of the 

controversy regarding the widespread historical and continuing use of dental amalgam. (The Internet 

provides numerous references for learning more about the issues involved.) On this page, you will find 

recommendations from several sources on how to best manage waste dental amalgam. 

Common dental amalgam wastes include: 

z clean unused scrap including excess material and damaged capsules (non-contact amalgam), 

z used amalgam (contact amalgam) including sink trap cleanout, and 

z amalgam contained in extracted teeth. 

Dental amalgam should not be disposed of in the garbage, infectious waste “red bag,” or sharps container. 

Amalgam also should not be rinsed down the drain. These cautions are important because some 

communities incinerate municipal garbage, medical waste, and sludge from wastewater treatment plants. If 

amalgam waste ends up in one of these incinerated waste streams, the mercury can be released to the 

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environment due to the high temperatures used in the incineration process. Increasingly, local communities 

are enacting restrictions on the incineration of wastes containing mercury. 

American Dental Association. The American Dental Association (ADA) encourages dentists to implement 

best management practices (BMPs) to help reduce the effects of amalgam waste on the environment. ADA’s 

guidance for amalgam waste includes a series of waste handling and disposal practices: 

z pollution prevention (e.g., stock amalgam capsules in a variety of sizes to minimize the amount of 

amalgam waste generated), 

z initiate bulk mercury collection programs, 

z using chair side traps, amalgam separators compliant with ISO 11143 and vacuum collection, 

z inspecting and cleaning traps, and 

z recycling or using a commercial waste disposal service to dispose of the amalgam collected. 

These BMPs were approved by the ADA Board of Trustees in January 2003 and updated in 2007 to include 

amalgam separators. The BMPs are available on the web in both text and video formats at: 

http://www.ada.org/prof/resources/topics/amalgam_bmp.asp. 

State of Connecticut. Connecticut statutes require dental practitioners and dental schools to store, use 

and handle mercury amalgam in accordance with state and federal law and any best management practices 

(BMPs) adopted by the State. BMPs were originally adopted in October 2003 and revised in January 2006. 

DEP has also developed a Certification Form on which dental practitioners certify that their practice or clinic 

is in compliance with the state adopted BMPs. 

Additional Connecticut BMPs, not among those recommended by the ADA include: 

z use of amalgam substitutes in cases where they are appropriate (i.e., Connecticut requires dentists to 

make available information about alternative dental practices), 

z procedures for spill cleanup. 

The full text of the Connecticut BMPs are located here. 

State of Florida. BMPs published by the Florida Department of Environmental Protection cover additional 

details of handing and decontamination of contact amalgam. 

The full text of the Florida BMPs are located here. 

Other State Agencies. Environmental agencies of other states also offer BMPs, most of which are covered 

by the practices referenced above. Some of the more detailed BMPs include: 

z New York Department of Environmental Conservation (NY requires amalgam separators and provides 

detailed information on their use), and 

z State of Washington. 

X-ray Fixer 

Used X-ray fixer is a hazardous waste (RCRA waste code D011) because of its high silver content (the 

regulatory level is 5 mg/l silver, used fixer typically contains 3,000 to 8,000 mg/l of silver). As such, it 

cannot be sewered or disposed of as common solid waste. 

There are three common ways of dealing with used fixer: 

z dispose of it off-site as a hazardous waste, 

z pay someone that operates a silver recovery unit to take your fixer, or 

z use a silver recovery unit on-site. 

From a regulatory standpoint, sending fixer off-site for recovery is significantly less burdensome than 

sending it to a disposal site. For starters, to send used fixer to a disposal site, you must contract with a 

registered hazardous waste transporter; whereas, a common carrier can be used to send silver-bearing 

materials to a recovery facility, such as a refiner. In general, under RCRA, if waste is destined for precious 

metals recovery then reduced standards apply. These materials are subject to administrative requirements 

only, including obtaining an EPA identification number, complying with recordkeeping requirements, using a 

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manifest when shipping materials off site, and complying with land disposal restrictions notification 

requirements (40 CFR 261.6 Requirements for recyclable materials). 

On-site silver recovery is a possibility, but, it is often the most expensive alternative. Most dental offices 

generate between 0.5 and 1.0 gal./month of used fixer. The cost of a silver recovery unit ($200 or more) to 

process this quantity, plus the operation and maintenance costs (typically $100 to $400/year) generally 

exceed the cost of having an outside service pick-up and process the waste (usually about $4/gal.). 

If you use a silver recovery unit, the liquid that has run through the unit may be sewered if approved by 

your city/county wastewater treatment plant and the discharge meets your state and local standards (most 

state/local standards are between 0.1 ppm to 5.0 mg/l silver). To meet discharge standards, you may need 

to use two recovery units in series to be certain that most of the silver is recovered. Although recovering 

silver on-site can eliminate off-site shipping, in most states, hazardous waste rules still require you to report 

the fixer waste on your Hazardous Waste Annual Report and the Notification of Hazardous Waste Activity (if 

these rules apply). 

For additional information and guidance, see EPA’s publication: RCRA in Focus – Photo Processing. 

Many dental offices are now avoiding the hassles and costs associated with used photographic fixer and 

associated wastes by installing digital imaging (dental radiographs) equipment. Digital imaging is a dry 

system; no liquid chemicals are used in taking and developing the image. Because digital imaging uses a 

laser and computer system, no waste is produced from the imaging process. Ultimately waste will include 

outdated electronics, video cards and possibly paper images, if they are printed. The American Dental 

Association website has various resources that describe this process. For starters, see Digital radiographs 

Imaging technology for the dental office.ADA also sponsors workshops covering this topic. 

X-ray Developer

Developer solutions are typically not hazardous waste because of their low silver content (usually below the 

regulatory level of 5 mg/l silver) and lack of other constituents or characteristics that would make it 

hazardous waste. However, keep in mind that the burden of determining if your waste is hazardous is your 

responsibility and if there is any concern, then testing should be performed. 

Waste developer should not be mixed with fixer, otherwise, the combined solution will most likely be a 

hazardous waste. Unfortunately, some development units mix the fixer and developer after they are spent, 

making the entire solution hazardous waste. in such cases, consider changing or modifying your equipment 

(you may be able to purchase an adapter kit to keep the fixer and developer separate). 

In most areas, used waste developer can be sewered, although, you should check with your local 

wastewater treatment plant for any restrictions or guidance. 

Unused developer typically cannot go down the drain because it contains 1 to 5% hydroquinone. Although 

unused developer is not hazardous under RCRA (either by listing or characteristic), many states and local 

governments restrict disposal of hydroquinone. This is not an issue with used developer since hydroquinone 

is consumed in the developing process. 

Dental Film 

Used x-ray film may contain sufficient amounts of silver to 

be a hazardous waste (film with large dark areas contains 

more silver than film with smaller dark areas). The silver 

on film can be reclaimed. Often reclamation companies 

that accept used fixer also often take x-ray film. 

Lead Foil 

Lead foil that shield X-ray film or protective lead shields 

should not be disposed of in the trash. These materials are 

hazardous waste (D008) unless they are recycled for their 

scrap metal content. Studies suggest that a high 

percentage of dentists are presently recycling lead foil. 

Companies which recycle dental amalgam or fixer often 

also accept lead waste. 

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Cleaners for X-ray Developer Systems 

Many cleaners for X-ray developer systems contain chromium (or “chromate”) and are hazardous waste 

(D007) when discarded. Also, some developer system cleaners meet the definition of corrosiveness or 

reactivity (contain oxidizing chemicals) and may need to be handled as hazardous waste when spent. The 

onus for such determinations is on the generator of the waste, so be certain to fully investigate these 

materials. One source of information is the Material Safety Data Sheet (MSDS). Although MSDSs contain 

sparse information with regard to RCRA, you can at least determine if the product contains chromium. 

As an alternative, it is easier and cheaper to use a system cleaner that does not contain chromium or other 

components that would cause it to be hazardous when spent. Often “environmentally safe cleaners” are as 

effective as the chromium-based products. 

Sterilizing and Disinfectants 

In a dental office, it is essential to be able to control infectious organisms. Sterilants and disinfectants are 

important tools for meeting that need. But because they are necessarily toxic to living organisms, sterilants 

and disinfectants must be handled carefully, and their associated wastes must be managed properly, to 

avoid causing unintentional harm as they fulfill their intended function. 

See HERC section on Sterilants and Disinfectants in Healthcare Facilities for information on properties, risks, 

compliance requirements, disposal options, P2 alternatives and other information. 

Ultrasonic Cleaners 

These cleaners may be enzymatic, or contain alcohol, glutaraldehyde, or potassium hydroxide. The least 

toxic of these are the enzymes, although they may contain hazardous ingredients such as butoxy ethanol or 

nonylphenylethoxylates. After use these cleaners must be evaluated to determine if they are hazardous 

waste. They may be flammable or corrosive. Hazardous waste can be minimized by using enzymatic 

cleaners without butoxyethanol or other hazardous materials. Used cleaners may be disposed to the sanitary 

sewer with permission from the local ser plant. 

Expired Pharmaceuticals

All dental offices have some pharmaceutical materials in inventory. Any of these materials can enter the 

waste stream, and some must be managed as hazardous wastes. For information on this topic, see HERC’s 

special section that deals with Pharmaceutical Wastes in Healthcare Facilities. 

Universal Wastes

EPA developed the universal waste rule as a way of streamlining the recycling efforts for businesses. Under 

this rule, a hazardous waste generator has the option of designating certain hazardous waste as universal 

waste, making them subject to less stringent environmental regulations. These wastes include, among 

others batteries, mercury-containing thermostats, and certain fluorescent lamps. 

All handlers of universal waste, whether one fluorescent light bulb or a million fluorescent light bulbs, need 

to manage their universal waste in such a way as to prevent releases of the universal waste or component 

of the universal waste to the environment. For example, lamps, because they can easily break, must always 

be kept in containers or packages that are closed, structurally sound, adequate to prevent breakage, and 

compatible with the contents of the lamp. 

For information on this topic, see HERC’s special section that deals with Managing Universal Wastes. 

Regulated Medical Waste 

Regulated medical waste (RMW), also known as 

‘biohazardous’ waste or 'infectious medical’ waste, is the 

portion of the waste stream that may be contaminated by 

blood, body fluids or other potentially infectious 

materials, thus posing a significant risk of 

transmitting infection. 

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RMW is unique to the healthcare sector and presents a number of compliance challenges. Unlike many 

regulations that apply to healthcare, most regulations governing medical waste are defined at a state, rather 

than a federal level. Adding yet a further level of complexity, authority for medical waste rules often comes 

from multiple agencies at the state level. 

HERC has prepared a detailed section covering Regulated Medical Waste, including state-specific rules, 

disposal options, and suggestions for reducing the volume of RMW generated. 

Office Waste

Although office waste is usually not hazardous, we wish to remind you that aluminum, glass, plastics, 

newspaper, corrugated paper, and office paper can be recycled through your trash hauler or recycling 

center. It is mandatory to do so under many state and local laws. 

For more information, see the HERC section on Solid Waste Reduction. 

More Resources 

National/Global Resources 

U.S. Environmental Protection Agency (EPA) 

z State Mercury Medical/Dental Waste Programs 

American Dental Association (ADA) 

z Best Management Practices for Amalgam Waste (American Dental Association (ADA). 

z Maximizing Voluntary Reductions in Dental Amalgam Mercury Reduction in Mercury Discharges: EPA 

#E0000127, PI-98765101-0, Brief Summary Report, November 2007 

z Guidelines on Amalgam Accumulations in Dental Office Plumbing (American Dental Association (ADA). 

z Directory of Dental Waste Recyclers (American Dental Association (ADA), Nationwide, State and 

Regional Services 

z State Dental Associations. 

Center for Disease Control (CDC) 

z Guidelines for Infection Control in Dental Health Care Settings (Center for Disease Control (CDC). 

Naval Institute for Dental and Biomedical Research 

z Naval Dental Research Institute (NDRI) Mercury Publications. 

Northeast Waste Management Official’s Association (NEWMOA)

z Mercury Management Guidance for Dental Offices 

Quicksilver Caucus

z Dental Mercury Amalgam Waste Management White Paper 

 

State Resources 

CA | CO | CT | FL | IN | ME | MA | MN | NY | OH | OR | VT | VA | WA | WI 

 

California

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z Dental, Medical and Veterinary Offices: Managing Your Hazardous Waste. 

z Amalgam Waste Management (CA Dental Association) 

z CDA Best Management Practices: Amalgam Waste (CA Dental Association) 

z CDA Waste Management Guide for Dental Offices (CA Dental Association) 

z ADA Directory of Dental Waste Recyclers (CA Dental Association) 

z Cross Connection/Backflow Prevention (CA Dental Association) 

Colorado

z Dental Mercury and the Environment – A Fact Sheet for Dentists (CDPHE) 

z Dental Wastes Compliance Bulletin (CDPHE) 

Connecticut

z Best Management Practice for Dental Offices Waste Handling in Connecticut 

Florida

z Best Management Practices for Scrap Dental Amalgam 

z Appendices for Best Management Practices for Scrap Dental Amalgam 

z Scrap Dental Amalgam Recyclers 

Indiana

z Compliance and Technical Assistance Program: Sectors: Hospitals 

Maine

z Mercury Management in the Health Care Environment 

z Medical Pollution Prevention Agreement Program 

z Release of Mercury from Consumer Products: Medical Legislation 

z Health Effects of Mercury Fillings Legislation/Medical Legislation (PDF) (1 pg., 6 KB) 

z Mercury in Dental Fillings Brochure 

Massachusetts

z Massachusetts Department of Environmental Protection's Dental Amalgam Mercury Recycling Program 

z PPIS Hospital Project Description 

z Dental Elemental Mercury Collection Program 

Minnesota

z Great Lakes Dental Mercury Reduction Program 

New York

z Managing Dental Mercury (NY DEC) 

z Subpart 374-4: Standards for The Management Of Elemental Mercury and Dental Amalgam Wastes At 

Dental Facilities 

z Information on 6 NYCRR Part 374-4 Regulations 

z NY Dental Mercury & Amalgam Recycling Law 

z Recycling of Mercury By Dentists FAQ 

z Guide for Dentists for Managing Mercury and Amalgam Wastes 

z List of Mercury and Dental Amalgam Recyclers & Hazardous Waste Haulers 

z Community Household Hazardous Waste Programs That Accept Mercury From Dentists 

Ohio

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z Mercury Challenge Medical Program 

z Mercury Challenge Handbook Medical Programs (PDF) (33 pp., 101 KB) 

Oregon

z SB 681: Prohibits use of dental materials containing mercury after July 1, 2007 

z SB 695: Directs Department of Human Services to conduct a study of mercury amalgam fillings in 

human teeth and environmental sources of mercury ingestion 

Vermont

z Mercury Education and Reduction Campaign 

Virginia

z Dental Mercury Collection Program Description 

z SB 187 (LS: 05): Would require the Board of Dentistry to promulgate regulations for the appropriate 

and safe use of dental amalgams containing mercury 

Washington

z Best Management Practices for Dental Office Wastes (Washington State Department of Ecology) 

Wisconsin 

z A Guide for Dentists – How to Manage Waste (University of Wisconsin, Solid & Hazardous Waste 

Education Center (SHWEC)) 

z Amalgam Management for Dental Offices (University of Wisconsin, Solid & Hazardous Waste 

Education Center (SHWEC)) 

z Choosing an Amalgam Separator for Your Office (University of Wisconsin, Solid & Hazardous Waste 

Education Center (SHWEC) 

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