# 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 overvie w 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 univ ersal 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 practi ces 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 Quan tity 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 majori ty of dental offices are exempt from the federal hazardous waste regulations as long as they co mply 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 si te 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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7/7/2008 htt p ://www.hercenter.or g /dentistwastes.cfmFor a detailed discussion of ha zardous waste re gulations, 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 quan tity generators” (SQGs) such as obtain ing 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 fo llowing 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 muni cipal 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 relati ng to universal wastes often differ from the federal rules. Therefore, you are encouraged to check th e 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 So lid & 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 in to a hard substance. In recent years there has been controversy over the use of this material for dental fillings. The Fede ral 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 regula tions, 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 practice s. 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 ho w 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 garb age, 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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7/7/2008 htt p ://www.hercenter.or g /dentistwastes.cfmenvironment due to the high temperat ures used in the incineration proc ess. 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 amalga m 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 comp liant 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 Truste es 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 prac titioners and dental schools to store, use and handle mercury amalgam in accordance with stat e 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 case s 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 Conn ecticut BMPs are located here

. State of Florida. BMPs published by the Florida Department of Environmental Protec tion cover additional details of handing and decontamination of contact amalgam. The full text of the Fl orida 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 co de D011) because of its high silver content (the regulatory level is 5 mg/l silver, used fixer typically co ntains 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 us ed fixer to a disposal site, you must contract with a registered hazardous waste transporte r; 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 standa rds apply. These materials are subj ect to administrative requirements only, including obtaining an EPA identification number, complying with recordkeeping requirements, using a 

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7/7/2008 htt p ://www.hercenter.or g /dentistwastes.cfmmanifest when shipping materials of f 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 ofte n the most expensive alternative. Most dental offices generate between 0.5 and 1.0 gal./month of used fixer. The cost of a silv er recovery unit ($200 or more) to process this quantity, plus the operation and maintena nce 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 recove red. 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 Wa ste Annual Report and the Notificati on 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 de veloping the image. Because digital imaging uses a laser and computer system, no waste is produced from the imaging proc ess. 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 ch anging or modifying your equipment (you may be able to purchase an adapter ki t to keep the fixer and developer separate). In most areas, used waste deve loper 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 hydr oquinone. 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 al so 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 th ey are recycled for their scrap metal content. Studies suggest that a high percentage of dentists are presently recycling lead foil. Companies which recycle dent al amalgam or fixer often also accept lead waste. 

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## Cleaners for X-ray Developer Systems Many cleaners for X-ray develope r systems contain chromi um (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 pr oduct contains chromium. As an alternative, it is easier and cheaper to use a system cleaner that does no t 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 contro l infectious organisms. Ster ilants and disinfectants are important tools for meeting that need. But because they are necessarily t oxic to living orga nisms, sterilants and disinfectants must be handled carefully, and thei r 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, alth ough 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. Haza rdous waste can be minimized by using enzymatic cleaners without butoxyethanol or other hazardous materi als. 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 th ese 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 haza rdous waste as universal waste, making them subject to less stringent enviro nmental 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 environm ent. For example, lamps, because th ey 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 'infec tious 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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7/7/2008 htt p ://www.hercenter.or g /dentistwastes.cfmRMW 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 de tailed 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 Wa ste (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 Of fice Plumbing (American Dental Association (ADA). z Directory of Dental Waste Recyclers (American De ntal 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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7/7/2008 htt p ://www.hercenter.or g /dentistwastes.cfmz 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 Dent al Waste Recyclers (CA Dental Association) z Cross Connection/B ackflow 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 Assistan ce 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 Protec tion's Dental Amalgam Mercury Recycling Program z PPIS Hospital Project Description z Dental Elemental Mercury Collection Program
Minnesota

z Great Lakes Dental Merc ury 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 Facilitie s z Information on 6 NYCRR Part 374

- 4 Regulations z NY Dental Mercury & Amalgam Recycling Law z Recycling of Mercur y 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 Progra ms That Accept Mercury From Dentists Ohio 

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7/7/2008 htt p ://www.hercenter.or g /dentistwastes.cfmz 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 Dentis try 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 (Unive rsity of Wisconsin, Solid & Hazardous Waste Education Center (SHWEC)) z Choosing an Amalgam Separator for Your Office (U niversity of Wisconsin, Solid & Hazardous Waste Education Center (SHWEC)



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