Best Management Practices for
Common Dental Office
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
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
must identify all hazardous waste that you generate,
may not store more than 2,200 lbs (1,000 kg) of hazardous waste on site at
any time, and
must ensure delivery of your hazardous waste to an off-site treatment,
recovery or disposal facility.
detailed discussion of hazardous waste regulations, see HERC’s Hazardous
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,
mercury-containing 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.
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.
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
Portions of the information in this section are drawn from
several sources, including:
New dental amalgam info. posted on the EPA mercury portal!
OPA has posted comprehensive info. that summarizes their existing information on dental amalgam, with links to more detailed information. More...
Also, use the Mercury State Resource Locator to find additional amalgam information in your state.
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:
unused scrap including excess material and damaged capsules (non-contact
amalgam (contact amalgam) including sink trap cleanout, and
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 environment due to the high temperatures used in the
incineration process. Increasingly, local communities are enacting restrictions
on the incineration of wastes containing mercury.
In most areas of the country, the best method of amalgam disposal is offsite recycling using a "mail away" service. Examples of commercial mail away services include:
- Amalgaway, IN – all amalgam wastes (800) 267-1467
- Bethlehem Apparatus Co, Inc., PA – all amalgam wastes (610) 838-7034
- Dental Recycling of North America, NJ – all amalgam wastes (800) 360-1001
- Dental Refiners, NV – offers pick-up services throughout Idaho (800) 786-1742
- Maguire & Strickland Refining, Inc., MN – all amalgam wastes (800) 486-2858
- Mercury Refining Company, Inc. – only non-contact amalgam (800) 833-3505
- Enviro-Chem Inc (763) 428-4002
- Mercury Waste Solutions (800) 664-1434
Your state environmental agency may be able to provide you with additional choices.
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:
- pollution prevention (e.g., stock amalgam capsules in a
variety of sizes to minimize the amount of amalgam waste generated),
- initiate bulk mercury collection
chair side traps, amalgam separators compliant with ISO 11143 and vacuum
and cleaning traps, and
or using a commercial waste disposal service to dispose of the amalgam
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/1540.aspx.
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:
- use of
amalgam substitutes in cases where they are appropriate (i.e., Connecticut
requires dentists to make available information about alternative dental
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:
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:
- dispose of it
off-site as a hazardous waste,
- pay someone
that operates a silver recovery unit to take your fixer, or
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 manifest when shipping materials off site, and complying
with land disposal restrictions notification requirements (40
CFR 261.6 Requirements for recyclable materials).
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.
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
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.
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.
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 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.
Cleaners for X-ray Developer
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,
and other information.
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.
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
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
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
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
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.
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
U.S. Environmental Protection
Center for Disease
Naval Institute for
Dental and Biomedical Research
Northeast Waste Management
Official’s Association (NEWMOA)
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