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Best Management Practices for
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. 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:
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, 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. 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. 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:
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. Common dental amalgam wastes include:
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:
Your state environmental agency may be able to provide you with additional choices. 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:
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:
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:
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). 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. 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. 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 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. 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. 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 Healthcare Facilities. 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 (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. 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. 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 ResourcesNational/Global Resources U.S. Environmental Protection Agency (EPA) American Dental Association (ADA)
Center for Disease Control (CDC) Naval Institute for Dental and Biomedical Research Northeast Waste Management Official’s Association (NEWMOA) Quicksilver Caucus
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