Appendix 5

WASTE MANAGEMENT GUIDE
FOR DENTAL OFFICES

Introduction

Dentists and their support staff use and generate certain substances that may be or are regulated under federal, state or local environmental regulations. Examples include chemical solutions, lead foil film backing, mercury, scrap dental amalgam, fluorescent tubes and batteries. If liquid hazardous wastes are discharged into a sewer system, they potentially impact the wastewater treatment plant, and/or pass through the treatment plant into the bay, ocean, river, or other receiving waters.  Alternatively, if materials are disposed of in the trash, they may eventually contaminate the soil, ground water, or create a public health problem. Most chemical waste streams generated in the dental office can be managed as non-hazardous waste, if proper disposal guidelines are followed.  For example, glutaraldehyde waste can be neutralized; amalgam and lead waste can be recycled, as can silver-containing waste; and liquid developer that is slightly basic can be disposed down the drain if local pH limits are not exceeded. To ensure compliance with the law, of these materials must be properly handled, recycled, treated and/or disposed.  Recycling these materials minimizes potential impacts on the environment and liability for the dental practice.  Therefore, recycling should be the option selected whenever possible.

This guide describes the general hazardous waste management, recycling, and disposal procedures that dental offices must follow and contains compliance information required by the California Department of Toxic Substances Control (DTSC), a Division of the California Environmental Protection Agency. Hazardous waste management is enforced by the DTSC or by a designated local Certified Unified Program Agency (CUPA) which often resides in the Environmental Department or Fire Department for your city or county. Contact your local CUPA for specific requirements in your area.  Appendix C contains a directory of local CUPAs in California.  Appendix D contains a list of counties which have waste collection events that are open to small businesses.

This guide is divided into three sections:  The first section describes the general control strategies that should be incorporated into dental office policies and procedures; the second section identifies the most common hazardous waste streams encountered in the dental office and addresses the management of each one individually; the latter part of this guide contains additional regulatory issues which pertain to dental offices that generate hazardous wastes.  Following the three sections are additional reference information.  Dental personnel can also refer to the “Frequently Asked Questions” section of the CDA's Regulatory Compliance Manual for additional information on the management of regulated waste.* 

*CDA maintains a Regulatory Compliance Manual which includes training information and template plans for the various environmental health and safety issues pertaining to dentistry.  The manual is available online to members free of charge; a hard copy of the manual can be purchased by contact the CDA Contact Center, (866) 232-6362.  The online version is organized by section to enable members to download/access information by topic.


TABLE OF CONTENTS

INTRODUCTION

SECTION I:  POLLUTION PREVENTION STRATEGIES

Product Substitution

Safe Work Practices
Good Housekeeping
Equipment Maintenance
Labeling
Storage
Recordkeeping

Employee Training

Recycling

SECTION II:  MANAGEMENT OF HAZARDOUS WASTE STREAMS

Dental Amalgam Wastes
Best Management Practices (BMPs)
Amalgam Traps
Bulk Mercury
Contact Amalgam (i.e. Extracted Teeth Containing Amalgam)

Other Scrap Heavy Metals such as Lead Foils

X-ray Processing Wastes
Silver-Containing Wastes (X-ray Photographic Fixer)
X-ray Photographic Developer
X-ray System Cleaners Containing Chromium

Waste Glutaraldehyde and OPA

Waste Formalin

Medical Waste
Sharps Waste
Biohazardous Waste

SECTION III:  GENERAL REGULATORY REQUIREMENTS

Local CUPA Authority

California ID Number
Verification Questionnaire

Small Quantity Generators

Accumulation

Shipment

Hazardous Waste Manifests/Codes

Hazardous Materials Business Plan

Silver-Only Generators

Universal wastes



SECTION I:  POLLUTION PREVENTION STRATEGIES

With respect to pollution prevention in the dental office, control strategies must be implemented to reduce the generation of waste and minimize the potentially detrimental effect on employee safety and the environment.  Such practices include product substitution where appropriate, safe work practices, employee training, and recycling.

Product Substitution                                                                              

Product substitution practices include using alternative products with less or non-hazardous components or using technologies that generate less toxic or less volume of waste. For example, you may wish to consider alternatives such as:

However, when making any changes, carefully evaluate the new product, material or technology for its effectiveness, durability, ease of use, and potential to contain other toxic or hazardous chemicals. Sources of information for evaluating products or technology include CDA, vendors, regulatory agencies, and other dental offices that have used such products.
In 2004, the Federal Environmental Protection Agency issued a grant to a project team that developed Pollution Prevention Fact Sheets for dentistry which can be accessed at http://www.westp2net.org/dental/index.cfm . The factsheets, which were released in 2005, are in the public domain. You may freely copy and use them, provided that the Dental Pollution Prevention Project and this website are cited as the source.  They include information which can help dental professionals make informed choices about their chemical selection and use.

Safe Work Practices                                                                               

Safe work practices should be incorporated into office policy and procedure documents.  Some examples of such practices include good housekeeping procedures, routine equipment maintenance, proper storage and labeling, and effective recordkeeping.

Good Housekeeping

Equipment Maintenance

All dental equipment - dental units, waterlines, vacuum systems, x-ray equipment, sterilizers, etc., should be inspected and maintained regularly.  Check with the equipment manufacturers for specific recommendations on maintenance.  Some general guidelines with respect to mercury hygiene are included below. 

Labeling

Waste streams that are designated for recycling/reclamation and meet specific requirements can be labeled as recyclable materials, e.g., "Scrap metal - to be recycled."  Containers that store hazardous waste must be labeled with the words “Hazardous Waste” and words that identify the contents. The label must also have the following information as required by state law:

  1. Accumulation start date;
  2. Name and address of office generating the waste;
  3. An indication of the type of hazard, i.e., flammable, corrosive, reactive or toxic.

Containers that store Universal Wastes such as fluorescent lamps and batteries need to be labeled as follows”

  1. “Universal Waste—Batteries”, “Universal Waste—Lamps”, or “Waste Dental Amalgam”

Appropriate labels are usually available from your licensed hazardous waste recycler or hauler.

Storage

Store all hazardous waste in containers that can be tightly closed.  Be sure that the container is compatible with the nature of the waste you are storing.  Your hazardous waste recycler or hauler may also have specific packaging requirements for each type of waste.  Be sure you know the requirements of your recycler and/or hauler to avoid extra charges.

Containers should be kept secondarily contained and protected from damage in a secure area.  This area must be away from the public and must be inspected once a week for leakage or deterioration.  Inspection logs are not required by law, unless the local CUPA requires it.  However, CDA recommends that dental personnel maintain a written log indicating the inspection date, the identification of the inspector, and any comments or corrective actions taken.  

Recordkeeping

You must keep records of the hazardous waste you generate whether it is recycled or disposed offsite. In general, if you send your hazardous waste offsite for recycling or disposal, you must utilize a hauler licensed by DTSC and you must complete and file a hazardous waste manifest for each shipment.  In some cases, the hauler will provide you with a receipt instead of a manifest.  You must maintain a copy of either type of shipping paper for a minimum of three years. Local agencies may require longer periods of recordkeeping.  For example, the City of Los Angeles inspects dental offices once every five years and requires that records be maintained for that period.  Inspectors from regulatory agencies may ask to review these records at any time.

If you transport hazardous waste yourself (“self-haul”) to a licensed facility such as a community Small Quantity Generator collection location, you should keep a disposal log of the date, type and quantity of waste delivered.  Attach the receipt for each shipment to your log.

Employee Training                                                                                

Recycling                                                                                             

Mercury, zinc, and silver from amalgam, silver from used x-ray fixer, and lead from film backings can be recycled and/or reclaimed.  In addition to the environmental benefits, reclaiming these resources can also reduce the regulatory requirements, liability, and costs associated with management and disposal.  If dentists send dental amalgam or lead foils for recycling, they are considered to be scrap metal, not hazardous waste.  If these wastes are not recycled/reclaimed, they must be managed and disposed as hazardous wastes. 


SECTION II:  MANAGEMENT OF HAZARDOUS WASTE STREAMS

The following section addresses the proper management of materials commonly used in dental offices which are potentially hazardous or otherwise regulated materials. These materials include mercury and dental amalgam (elemental mercury, amalgam capsules, scrap amalgam, contact amalgam) x-ray processing wastes, lead foils or other heavy metals, disinfectants and medical waste.

Dental Amalgam Wastes

Dental amalgam waste should never be discharged to the sewer or discarded with solid waste or medical waste. Dental amalgam is nearly 50% mercury, a metal that is classified as either a hazardous or universal waste when discarded, and also contains other heavy metals such as silver, zinc, copper and tin.  If scrap dental amalgam is collected and sent away for recycling, then it is considered universal waste, as long as certain best management practices are followed (see asterisks below).  If dental amalgam waste is discarded, then it must be removed offsite as hazardous waste.  CDA recommends that all dentists recycle dental amalgam wastes to the extent possible.

Not all recycling companies accept every type of amalgam waste stream, and the services offered by recyclers vary widely.   Appendix B of this guide contains a list compiled by the American Dental Association of questions to ask potential recyclers. The American Dental Association (ADA) also maintains a directory of amalgam recyclers on its web site, http://www.ada.org/prof/resources/topics/topics_amalrecyclers.pdf.
as does the San Francisco Public Utilities Commission at  http://sfwater.org/detail.cfm/C_ID/1649/MC_ID/4/MSC_ID/85/MTO_ID/157  

Best Management Practices (BMPs)

*Mandatory per California Code of Regulations Title 22

Amalgam Traps

Bulk Mercury

Maintain a mercury clean-up kit in your office to manage accidental spills, which may occur regardless of the delivery form of the mercury

Contact Amalgam (e.g., Extracted Teeth Containing Amalgam)

Contact amalgam is amalgam that has been in contact with the patient.  Examples are extracted teeth with amalgam restorations, carving scrap collected at chair-side, and amalgam captured by chair-side traps, filters, or screens.  Many scrap amalgam recyclers accept teeth with amalgam as long as the sender certifies that they are not infectious wastes.  Extracted teeth without attached tissue are considered non-medical wastes, unless the extracted teeth are deemed as biohazardous by the attending surgeon or dentist.  However, extracted teeth with amalgam should be managed as hazardous waste or recycled.

To dispose of contact amalgam, dentists can choose to either collect and store it as hazardous waste or collect and store as recyclable waste, if the metal recycler accepts contact amalgam.  Consult with amalgam waste recyclers about any special requirements to follow prior to disposal (see Appendix B). 

Other Scrap Heavy Metals such as Lead Foils                                                   

In addition to dental amalgam, other sources of heavy metals in the dental office should be recycled/reclaimed as much as possible.  The most common source of regulated heavy metals in the office is lead from lead foil and lead shields.  Lead cannot be placed in the regular solid waste containers nor can it be disposed of down the drain; it must be managed as either recyclable metal or hazardous waste.  Other metal sources include nickel and chromium from stainless steel orthodontic wires and crowns, and beryllium and nickel from crowns.  These materials should not be discharged to the sanitary sewer system.  X-ray photochemicals also contain heavy metals; these chemicals are discussed in the section below.  Contact your local CUPA for any local requirements that may apply.

X-ray Processing Wastes

Dental offices that house and operate standard radiography equipment must process the x-ray films using photochemicals - fixer, developer, and equipment cleaner.  Each of these chemical solutions is unique and requires special handling and disposal procedures.  Information on each waste stream is detailed below.

Silver-Containing Wastes (X-ray Photographic Fixer)

Silver from used fixer is a valuable resource that should be recycled.  There are two basic management options for fixer: (1) onsite treatment and disposal; or (2) offsite treatment and disposal.  Whether treated onsite or offsite, fixer is easily and economically recyclable and recycling is the preferred method of management. Untreated fixer can not be discharged to the sewer

Silver-rich photo processing wastewaters that are not treated onsite or hauled offsite for silver-recovery are subject to full regulation as hazardous wastes. 

Silver recovery units are commercially available to remove the silver from the fixer.  Prior to sewer discharge, treated solutions must meet the sanitation agency's pollutant discharge limits (i.e. most sanitation agencies have a 5 ppm or mg/l discharge limit for silver).  Treatment of silver-rich photo processing solutions (i.e. fixer) to remove silver does not require a California hazardous waste treatment permit.

When using a silver recovery unit, remember to:

Used x-ray fixer solutions can be hauled offsite for treatment and recycling at a Cal/EPA licensed recycling facility. If the silver is reclaimed, the waste stream may qualify for exemption or reduction in generator and hauling requirements. For offsite recycling, the generator should collect and store the used fixer solution in a labeled closed plastic container. The label affixed to the container should indicate the contents - "Silver-containing Used Fixer - To Be Recycled" and include the accumulation start date.

X-ray Photographic Developer

Do not mix used developer and fixer solutions. Waste developer may be flushed down the drain, as long as the pH of the solution does not exceed the pH standard of the local sanitation agency. Most developer solutions are slightly caustic in nature, i.e., they have a high pH. Caustic solutions with a pH greater than the local pH limit may not be discharged down the sanitary sewer. To determine the pH level, check the Material Safety Data Sheet (MSDS) or contact the chemical manufacturer. Contact the local sanitation agency for guidance on disposal procedures for the developer solution. 

X-ray System Cleaners Containing Chromium

Cleaners used to clean the x-ray developing systems may contain chromium. Check the cleaner's MSDS. If the MSDS lists some form of chromium, such as sodium dichromate, the waste cleaner solution must be managed as hazardous waste. If possible, switch to a non-chromium containing cleaner which can be discharged to the sanitary sewer. Otherwise, the waste must be handled as hazardous waste, requiring proper collection, labeling, and disposal.

Waste Glutaraldehyde and OPA                                                              

Glutaraldehyde and orthophthaldehyde (OPA) are the active ingredients in several brands of sterilizing solutions. As per the California Environmental Protection Agency, Department of Toxic Substances Control, these waste streams can be neutralized onsite by dental facilities without a permit, (see Fact Sheet at http://www.dtsc.ca.gov/HazardousWaste/Mercury/upload/OAD_DocVet_FS.pdf).   Please note  that the following conditions apply:

  1. The waste is generated by a medical facility during the disinfection of dental devices;
  2. The waste is treated at the site where it was generated;
  3. The sole active chemical of the neutralizing solution in glycine.

Note:  Glutaraldehyde degrades after activation and most likely will become non-hazardous within the allowed hazardous waste accumulation time (90-180 days). Generators of waste glutaraldehyde who wish to claim that it has degraded to non-hazardous levels should check with their suppliers to see if they have data to support determinations that the waste will degrade to non-hazardous levels over a set period of time. If the data is not available, then generators will have to produce their own supporting data to make the determination, or either neutralize the solutions with glycine or handle as hazardous wastes. This does not apply to OPA solutions.    

Waste Formalin                                                                                    

Formalin is commonly used as a tissue preservative.  Formalin is a generic mixture containing formaldehyde; it may also contain methanol and other chemicals.  Harvey's Vaposteril solution also contains small levels of formaldehyde as an active ingredient.

Waste formalin cannot be discharged to the sewer unless the following requirements are met:

  1. Solution must be non-hazardous (i.e. must pass the state's aquatic bioassay test for toxicity);
  2. Solution must have flash point no less than 140° F;
  3. Solution must have pH that is within the local sewer sanitation limits.

Generators of waste formalin should check with their suppliers or treatment vendors if they have data to support determinations that the above requirements are met.  If the information is not available, generators will have to produce their own supporting data through laboratory analyses or haul the solutions offsite as hazardous waste.  Generators should also contact the local sanitation agency for additional guidance on formalin waste disposal.

Contact your local Certified Unified Program Agency (CUPA) (see Appendix C), your local sanitation agency, or CDA for more information.

Medical Waste* 

As mandated by the Medical Waste Management Act (Health and Safety Code, Sections 117600 - 118360), the Department of Health Services (DHS) Environmental Management Branch regulates the storage, transportation,  and disposal of regulated medical waste.  In some counties, the management and enforcement of the Medical Waste Management Act has been delegated to the local Health Department.  Regulated medical waste consists of sharps (hypodermic needled, blades, syringes) and biohazardous wastes (e.g. laboratory wastes, solid 'red-bag' wastes covered with blood or other potentially infectious materials, and pharmaceuticals).  Medical wastes should be managed and disposed according to the requirements set by the Medical Waste Management Program of DHS or your local health department.  Please refer to CDA's Regulatory Compliance Manual for more detailed instruction on how to manage medical waste in California.  A brief description of the handling requirements for each waste stream is given below.

Note that wastes containing mercury or contaminated with mercury should never be placed with the medical wastes as these wastes will be incinerated and release mercury into the environment.
 
Sharps Waste

Disposable sharps should be placed in a proper sharps container.  A sharps container should be located in each operatory and the sterilization lab per Cal/OSHA requirements.  Full sharps containers should be disposed as medical waste; a registered hauler should transfer the sharps waste to a DHS-licensed treatment facility.  Proper treatment by a permitted facility consists of either autoclave sterilization or incineration.

 

Biohazardous Waste

* Refer to the "Medical Waste Management" section of CDA's Regulatory Compliance Manual for more detailed information on medical waste handling and disposal requirements.


SECTION III:  GENERAL REGULATORY REQUIREMENTS

Dental offices must consider carefully what requirements apply if they generate a waste that can be regulated as hazardous waste.  If you have questions whether or not you are generating hazardous wastes or for any other hazardous wastes issues (i.e. storage, handling, treatment, and disposal) call your local Certified Unified Program Agency (CUPA) or DTSC's Public and Business Liaison at 800-728-6942.

Certain requirements will be waived if the waste is recycled or reclaimed.  Hazardous wastes must be hauled by haulers licensed or approved by the state.  Generators may “self-haul” their own waste in volumes less than 5 gallons or 50 pounds without being licensed.  Facilities receiving hazardous waste, whether for recycling, treatment or disposal must be licensed by the state, or in some cases, the local agency. Dentists may also be able to take their wastes to local hazardous waste collection events for small businesses.  A list of counties known to offer this option can be found in the Appendix.

The following requirements apply to generators of hazardous waste except for generators that generate no more than 100 kg/month exclusively of silver-only hazardous waste.  Keep in mind, however, that local CUPAs still reserve the right to inspect those generators that produce a small amount of silver-only waste, and can even assess a generator fee.  A "generator" is any person, by site, whose act or process produces hazardous waste or whose act first causes a hazardous waste to become subject to regulation.  (Title 22, CCR, Section 66260.10.)

Local CUPA Authority  

DTSC oversees the implementation of the hazardous waste generator and onsite treatment program, at the local level consolidated within Cal/EPA's Unified Program. The Unified Program (UP) was created by Senate Bill 1082 (1993) to consolidate, coordinate, and make consistent the administrative requirements, permits, inspections, and enforcement activities for the following environmental and emergency management programs.  It is intended to provide relief to businesses complying with the overlapping and sometimes conflicting requirements of formerly independently managed programs. The Unified Program is implemented at the local government level by Certified Unified Program Agencies (CUPAs).  Seventy-two Certified Unified Program Agencies (CUPAs), which are generally part of the local Fire Department or Environmental Health Department, have authority to enforce regulations, conduct inspections, administer penalties, and hold hearings.  All CUPAs are required to implement a single fee system to reduce the cost and burden to businesses that have sent multiple payments to multiple agencies in the past. The single fee system provides for a single billing to cover the costs of all consolidated programs.

California ID Number                                                                                                 

The State of California’s Department of Toxic Substances Control (DTSC) issues permanent California ID numbers to generators for the purpose of tracking hazardous waste. California ID Numbers are site-specific and owner-specific.  All businesses regulated by hazardous was law in California are required to have either a federal or a State ID number.  Only businesses that generate ”silver-only” wastes (fixer) are exempt from having an ID number. If required, you will be asked to provide this number by your recycler or other licensed hauler. 

This number identifies each handler on hazardous waste manifests and other paperwork. The identification number enables regulators to track waste from origin to final disposal ("cradle to grave"). There must be only one number at a single address. If you have a business that generates waste at multiple addresses, each address needs a separate identification number. Hazardous waste generators must have an identification number (section 66262.12) unless only silver waste was generated. (Health & Safety Code, Sections 25160.2 (b)(10) and 25160.2 (e)). 

Handlers of state regulated hazardous waste (and less than 100 kg per month of federally-regulated waste) who need an identification number should contact DTSC's Generator Information Services Section (GISS) at 800-618-6942 or  refer to DTSC's 2004 “Information and Instructions for Obtaining a Permanent California ID Number”  found at  http://www.dtsc.ca.gov/HazardousWaste/upload/GISS_FORM_1358.pdf

There is no fee to obtain an identification number. However, every generator number is subject to an annual verification, and for those with 50 or more employees a verification fee is assessed. (Health & Safety Code, Section 25205.16.)  If you generate more than 100 kg of federally-regulated waste per month, you will need to contact Federal EPA  to obtain an ID number at (415) 255-1136.

Verification Questionnaire

Health and Safety Code section 25205.16 requires DTSC to verify the accuracy of information related to generators, transporters and facilities authorized to treat, dispose of, store, or recycle hazardous waste. DTSC captures this data through the Verification Questionnaire and uses the collected information to ensure that the Hazardous Waste Information Network database is current and accurate. The EPA ID Number Verification Fee, which has been established by state legislation, funds this effort.  If your dental business has fewer than 50 employees and did not manifest hazardous waste, or your business recycled all of your hazardous waste, your fees will be zero.  You should receive annually a Verification Questionnaire or manifest assessment for each California EPA ID number that is active.

Refer to the DTSC Frequently Asked Questions webpage for more information at
http://www.dtsc.ca.gov/HazardousWaste/upload/GISS_FAQ_VQ.pdf.

Small Quantity Generators                                                                     

Most dentists qualify as small quantity generators (SQG) of hazardous waste, which are those that generate less than 100 kg/month or 220 lbs/month.  Such generators have less stringent requirements than large quantity generators.  This guide outlines the requirements for SQGs.  Note:  If you are a large quantity generator of hazardous waste you will likely have additional requirements.  Contact your local Certified Unified Program Agency (CUPA) or DTSC's Public and Business Liaison at 800-728-6942 for more information on large quantity generator requirements. 
   
SQGs must have a written emergency plan in place which delineates proper action to take in the event of a hazardous waste emergency.  An emergency coordinator must be designated to be in charge during such times.  All employees must be trained with proper waste handling procedures and emergency procedures.  

Accumulation                                                                                       

Note:  Stricter requirements may apply if acutely or extremely hazardous waste is generated.

Shipment                                                                                             

Certain requirements will be waived if the waste is recycled or reclaimed.  Hazardous wastes must be hauled by transporters licensed or approved by the state.  Generators may “self-haul” their own waste in volumes less than 5 gallons or 50 pounds without being licensed.  Facilities receiving hazardous waste, whether for recycling, treatment or disposal must be licensed by the state, or in some cases, your local agency.

When disposing of hazardous waste totaling more than 50 lbs or 5 gallons, at a minimum, the following procedures must be followed:

  1. Use only transporters that are registered with DTSC and have obtained the appropriate hazardous waste transporter registration number.   Use only transfer, treatment, storage and disposal facilities that have an ID number.
  2. Use a California Hazardous Waste Manifest DTSC Form 8022A, unless the receiving state requires otherwise.  A manifest is the paperwork that accompanies hazardous waste from the point of generation to the point of ultimate treatment, storage, or disposal.  Most registered transporters will provide these forms and provide assistance in filling out the necessary information on the manifest forms;
  3. Obtain the handwritten signature of the initial transporter and the date of acceptance on the manifest;
  4. Keep the generator copy of each manifest for three years or until the signed copy is returned by the designated facility.
  5. Generators of “silver only” hazardous wastes generally will not need to use a hazardous waste manifest or registered hazardous waste transporter.

Hazardous Waste Manifests/Codes                                                          

Following is a listing of EPA and State of California waste codes for hazardous waste materials commonly generated by a dental office.  You will need these numbers to complete your EPA ID Number application, and when filling out the manifest forms. The codes are not applicable if the waste is recycled.

          Waste                                                  EPA Code                Cal/EPA Code        

          Amalgam waste                                      D009, D011
          Waste mercury                                       D009
          Photographic fixer                                  D011
          Ignitable waste                                        D001
          Waste containing chromium                     D007
          Waste containing lead                             D008
          Corrosive waste (acids/bases)                 D002
          Waste containing <10% formaldehyde                                                  134              
          Waste containing <10% glutaraldehyde                                                 134
          Waste containing zinc oxide powder (unreacted impression material)      181

Hazardous Materials Business Plan                                                          

Dental offices which use and handle hazardous materials and hazardous wastes may be required to register and file a hazardous materials business plan or a business emergency/contingency plan with the local CUPA. Chapter 6.95 of the California Health and Safety Code requires that California businesses which use or store such materials at or above reporting thresholds submit this information.  If the volume of each container of oxygen, nitrogen, and nitrous oxide does not exceed 1,000 cubic feet, these gases are exempt from business plan and registration requirements.  It is important to note, however, that dental offices that do not handle hazardous materials above exempt amounts may still be required to register their hazardous materials inventory with the local CUPA. (Note: The local agencies reserve the right to require an HMBP for any facility upon determination that the manner of use or storage of hazardous materials is such that additional information is necessary for emergency response purposes.)

Silver-Only Generators                                                                           

For many dental establishments, the only hazardous waste you generate is x-ray fixer. Please note that even though many regulations relating to the management of silver-only wastes have become less stringent, the wastes are still considered hazardous wastes, and may not be disposed to the ground or sanitary sewer. Your local CUPA may regulate you as a hazardous waste generator, even though you treat your fixer and discharge the non-hazardous effluent under a pretreatment permit.

If you generate no more than 100 kilograms of hazardous waste per month, you no longer need an EPA  ID Number.  You may not, however, discharge the untreated fixer directly to the sewer. You must treat it first to remove the silver by using a silver recovery unit. All recovered silver must be reclaimed. Furthermore, you must notify your local sanitation department if you discharge to the sewer after treatment.  You may also take it to a permitted recycler, local hazardous waste collection event,  or have it hauled off by a service company.  You do not need to use a hazardous waste manifest or a transporter registered with DTSC when shipping either the recovered silver or the fixer. 

If you generate more than 100 kilograms of hazardous waste per month, you still do not need a permit to recover the silver from the spent fixer, but you do need an EPA ID number and are required to use a manifest when shipping the waste to a treatment facility.  You do not need to use a registered hazardous waste transporter.

Universal Wastes                                                                                   
In 2001, the State of California adopted the Universal Waste Rule to regulate the generation, storage and disposal for a special category of wastes. The category of “universal wastes” includes certain hazardous wastes which are commonly generated by businesses.  Because they pose a lower risk to people and the environment than other hazardous wastes, “universal wastes” are regulated based on a relaxed set of standards.

The Universal Waste Rule initially applied only to larger businesses, however, as of February 8, 2006, small businesses are no longer exempt and must now comply with universal waste management requirements.

The requirements direct small quantity generators to ship their waste to a qualified universal waste handler, a universal waste transfer station, a recycling facility, or a hazardous waste disposal facility.  The materials may also be accepted at some community hazardous waste collection events.  They may not be disposed of in the regular trash.

Managing these wastes is not complicated, but you do need to follow these rules:

  1. Do not accumulate more than 5,000 kg of universal waste at any one time.
  2. Do not accumulate for longer than one year.
  3. Document the length of time you began accumulation.
  4. Label or mark packages to identify the type.
  5. Never try to treat or alter the wastes in a way which may alter their characteristics.
  6. Clean up any releases of universal wastes and repackage cleanup debris.

Below is a list of wastes which are included in the “universal waste” category that may be present in a dental office:

Aerosol cans Not considered a hazardous waste when completely empty, however, non-empty containers may be a universal waste if the remaining propellant is ignitable, or toxic or the product itself is ignitable, corrosive, or toxic.  An aerosol containing pesticides, for example, would be considered a universal waste. 

Batteries Included in the regulation are rechargeable, alkaline, button and small, sealed, lead-acid batteries.  Batteries are a unique product comprised of heavy metals and other elements. Some of these toxic heavy metals include nickel, cadmium, mercury, nickel metal hydride and lead. It is these elements that can threaten our environment if not properly discarded.  (Note: Automotive batteries are NOT universal waste.  They must be managed like other hazardous wastes.)

Light tubes and lamps – Fluorescent light tubes, high intensity discharge, and sodium vapor lamps contain mercury and other hazardous elements.  They become a hazardous waste when the bulb or lamp no longer functions.  Businesses may accumulate fluorescent tubes and lamps for up to one year prior to disposal.  If you have a property management company that changes your light tubes and lamps for you, it is advised that you check with them to ensure they are being managed properly.  These items must be recycled or they must be managed as a hazardous waste.

Mercury containing itemsMercury-containing thermometers, thermostats, blood-pressure gauges and switches are considered universal wastes.  (Note:  Amalgam has been regulated as a universal waste for several years and was never exempted for small businesses like the other items listed). These items must be recycled or they must be managed as hazardous waste.

Computer monitors, televisions, and other electronic devices – Many of these devices can contain lead and other toxic metals which cannot be disposed of in the regular trash.  Cathode ray tubes (TV’s and computer monitors) must be recycled or they must be managed as a hazardous waste.

Managing these wastes does not need to be complicated, but you do need to follow these rules:

  1. Do not accumulate more than 5,000 kg of universal waste at any one time.
  2. Do not accumulate for longer than one year.
  3. Document the length of time you began accumulation.
  4. Label or mark packages to identify the type.
  5. Never try to treat or alter the wastes in a way which may alter their characteristics.
  6. Clean up any releases of universal wastes and repackage cleanup debris.

 

Household Hazardous Waste Online Resources

Community Hazardous Waste Collection Websites

 

Telephone

Number

 

Restrictions or

Additional information

Alameda County

510.670.6460

Brochure available online

 http://household-hazwaste.org/

   
     

Alpine County

530.694.2146

October and April only

http://www.co.alpine.ca.us/dept/health/eh.html

   
     

Amador County

209.223.6429

Afternoons only on designated days – call for information

http://www.co.amador.ca.us/depts/waste/index.htm

   
     

Butte County:

530.343.5488

Call to make an appointment

http://www.recyclebutte.net/hhw.html

   
     

Calaveras

209.754.6403

 

http://www.ccsolidwaste.org/Hazardous_waste.htm

   
     

Contra Costa County

800.7504096

3 drop-off locations

http://www.co.contra-costa.ca.us/depart/cd/recycle/options/v5951.htm

   
     

West Contra Costa County

888.412.9277

 

http://www.recyclemore.com/article.asp?key=3

   
     

Central Contra Costa County

800.646.1431

Brochure available online

http://www.centralsan.org/services/hhwcf.html#top

   
     

Del Norte

707.465.1100

1 event each summer- call in June for date

http://www.northcoast.com/~recycle/recycling.html

   
     

Fresno

559-262-4259

One in Spring and Fall – call for dates

http://www.fresno.gov/public_utilities/solidwaste
/solidwaste.asp

   
     

Humboldt County

707.441.2005

Call Tues, Weds, Thurs

http://www.co.humboldt.ca.us/health/envhealth/iwm/
default.asp?url=resources.html

 

15 gallon limit

     

Imperial County

760.337.4737

 

http://www.ivwmtf.org/IVWMTF.swf

   
     

Kern County

661.862922

See online brochure

http://www.co.kern.ca.us/wmd/Services/Hazardous/
smallbiz/smallbiz.html#top

   
     

Lake County

707.263.1980

Friday & Saturdays, 9 am – 1 pm

http://www.co.lake.ca.us/countygovernment/
publicservices/hazmobileevent.html

   
     

Lassen

530.252.1273

Once per year (usually Oct or Nov)

http://www.co.lassen.ca.us/solid_waste.htm

   
     

Los Angeles County

213.473.8277

See fact sheet – by appointment only

http://www.lacity.org/SAN/cesqg-fact-sheet.htm

   

Los Angeles, City of

213.473.8277

See above

http://www.lacity.org/SAN/hhw.htm

   
     

Marin

415. 485.6395

Call for appointment

http://www.marinrecycles.org/hazwaste_disposal.cfm

   
     

Mendocino

800..246..3939

Call for appointment

http://www.mendorecycle.org/haz.htm

   
     

Merced

209.381.1100

Or call 209.723.4753

http://www.mercedrecycles.com/

 

Appointment required

     

Napa

800.952.5566

Call for appointment

http://www.co.napa.ca.us/FileFrame.asp?
Title=Document&Section=gov&ExtURL=/GOV/
Departments/40500/Linked/HHW%20Information.pdf

   
     

Placer

916.645.5230

Call for appointment on ext. 1010

http://www.wpwma.com/hhw.htm

   
     

Plumas

800.300.1046

One event per year in summer.

http://www.countyofplumas.com/publicworks/
plumas_county_recycling_info.htm

   
     

Riverside County

800.952.5566  

Call for appointment

http://www.rivcoeh.org/hhhw.htm

   
     

Sacramento County

916.481.4316

Call for appointment.

Event on last Friday of the month

(8:30 – 12:30)

http://www.sacgreenteam.com/hazardous/default.htm

 

City of Sacramento businesses

should call 916-379-0500 x209

     

San Diego County

800.714.1195

Call for dates and times

http://www.sdcounty.ca.gov/deh/chd/hhwsmbusiness.html

   
     

San Francisco County

415.330.1425

Call for appointment

http://www.sfrecyclinganddisposal.com/sfhhw/vsqg.htm

   
     

San Joaquin

877.747.9699

Call for appointment

http://www.sjgov.org/solidwaste/HHW%20Facility.htm

   
     

San Luis Obispo County

800-400-0811

Call for appointment

http://www.iwma.com/householdhaz/dropoff.html

   
     

San Mateo County

650.363.4305

First and third Wednesday of month

http://www.co.sanmateo.ca.us/smc/department/
home/0,,1954_191102_187814,00.html

 

Call for appointment

     

Santa Barbara County

805.963.0583, extension 104

Fridays between 9:00am & 3:00 pm

by appointment only

http://www.lessismore.org/htdocs/text_only/
programs/hshold_hazwaste_cmplte.html

   
     

Santa Clara County

408.299.7300

Call for appointment. 

Must submit  inventory

before appointment

will be scheduled

http://www.hhw.org/channel/0,4770,chid
%253D15227%2526sid%253D11383,00.html

   
     

Santa Cruz County

831.454.2606

 

http://www.dpw.co.santa-cruz.ca.us/hazwaste.htm

   
     

Solano

707.421.6765

Call for information

http://www.co.solano.ca.us/SubSection/
SubSection.asp?NavID=245

   
     

Stanislaus

209-525-6700

 

http://www.co.stanislaus.ca.us/ER/PROJHHW.HTM

   
     

Sutter

   

http://www.sunsetscavenger.com/yuba_hhw.htm

530.671.6900

Shared service with Yuba County

Call for appointment

     

Trinity County

530.623.1319

 

http://www.trinitycounty.org/Departments/
Gen%20Serv/SolidWaste/solidwaste.htm

   
     

Ventura County

805.289.3333

Check the list of events online

for those open to small business

http://www.wasteless.org/5_5HHWCollect.html

   
     

Yolo

800.433.5060

Call for appointment

http://www.yolocounty.org/recycle/sqg2.htm

   
     

Yuba County

530.671.6900

Shared service with Sutter County.

Call for appointment

http://www.ysdi.com/hazardouswaste.htm

   
     

 

State and Federal hazardous waste laws limit the use of this type of hazardous waste collection program to businesses that qualify as Conditionally Exempt Small Quantity Generators (CESQGs). To qualify as a CESQG, a business must generate less than 27 gallons or 220 pounds of hazardous waste per month, including a maximum of 1 quart or 2.2 pounds of acutely hazardous waste.  Businesses that generate more than these amounts are required to use a licensed hazardous waste hauler to manifest and transport their waste.

CONTACT THE PROGRAM FIRST BEFORE YOU BRING YOUR MATERIALS – SOME REQUIRE APPOINTMENTS, PRIOR APPLICATION OR CERTIFICATIONS TO BE COMPLETED BEFORE YOU ARE ELIGIBLE TO PARTICIPATE!  Each event varies in terms of what they can accept and what they charge. You will also need to check with each program to determine if they can accept the wastes you have.

Typically, these events cannot accept:

Some of these events may be able to take electronic waste (e-waste) and appliances.    Most have a limit of 15 gallons or 125 lbs. per trip.