Skip to main content

Disposal of Hazardous Waste in a Dental Office

Written by Modern Practice Solutions on . Posted in Modern Practice Solutions.

Image of hazardous waste in dentist office.

Proper waste management in dental offices is crucial to protecting the environment and ensuring regulatory compliance. The Environmental Protection Agency (EPA) has identified pharmaceutical compounds in rivers, lakes, and drinking water, making it essential for healthcare facilities to handle waste responsibly. Below, we’ll outline key considerations and best practices for managing hazardous waste in dental settings.

Why Proper Waste Disposal Matters

Years ago, healthcare facilities often flushed unused pharmaceuticals down toilets or drains. Today, we know this contaminates water sources. Dental offices must evaluate the waste they generate and dispose of it appropriately. The Universal Waste and Hazardous Management guidelines highlight that a lack of environmental compliance can indicate a failure to meet legal standards.

Identifying Hazardous Waste


First, determine if the waste qualifies as hazardous under the Resource Conservation and Recovery Act (RCRA). According to EPA, the proper waste identification process involves determination of

  • Whether the waste is a “solid waste”
  • Determine if the waste is specifically excluded from RCRA regulations.
  • Is the waste is a “listed” hazardous waste
  • If the waste exhibits a characteristic of hazardous waste

Next we determine if the waste poses a chemical and physical hazard to merit regulation such as ignitable, corrosive, reactive and toxic.

RCRA Hazardous Waste Categories

RCRA defines hazardous pharmaceutical waste as the P list (acutely hazardous) and the U list (toxic). P- and U-listed chemicals include unused substances such as expired products, spill residues, or leftover residue in containers. Thus, P and U-listed chemicals apply to unused chemicals do not apply to manufacturing process wastes.

Any facility that generates a hazardous waste is subject to the RCRA generator regulations at 40 CFR 262.  There are three generator categories:

1. Conditionally Exempt Small Quantity Generators (CESQGs)

  • A facility that generates no more than 100 kg of hazardous waste in a month, or no more than 1 kg (2.205 pounds) of acutely hazardous (P list) in a month, is a conditionally exempt small quantity generator (CESQG) under the federal program.  CESQGs have the least stringent requirements.  They do not need to obtain an EPA identification number, document waste for off-site disposal, or adhere to storage time limits.  CESQGs can send hazardous waste to either a state-approved solid waste facility or to a hazardous waste disposal facility.
  • Most dental offices qualify as CESQGs, simplifying their compliance obligations.

2. Small Quantity Generators (SQGs)

  • A facility that generates more than 100 kg (220.46 pounds) but less than 1000 kg (2204.62 pounds) of hazardous waste in a month is a small quantity generator(SQG).  SQGs are subject to less requirements such as not having to complete the biennial report, less personnel training and contingency planning requirements and the allowance of 180 days rather than 90 days for waste accumulation.

3. Large Quantity Generators (LQGs)

  • A facility that generates 1000 kilograms (kg) (2204.62 pounds) or more of hazardous waste in a month or greater than 1 kg or acute (P list) hazardous waste in a month is a large quantity generator (LQG).  LQGs are subject to the full RCRA generator regulations.  This includes obtaining an EPA identification number, storing waste for only 90 days or otherwise obtaining a RCRA permit; meeting manifest and reporting requirements; and compliance with training requirements.

Hazardous Waste in Dentistry

  • Dental Amalgam: Should not be disposed of in the sharps container or red bags.  Red bags and sharps containers are sterilized and placed in solid waste landfills. 
  • Pharmaceutical Waste: Hazardous waste pharmaceuticals are treated by hazardous waste incineration and the incinerator ash is disposed of in a permitted hazardous waste landfill.
  • Fluorescent lamps: Must be recycled.  Store the used lamps in universal waste compliant containers and maintain documentation. Check with the store where the lamps were purchased to determine if a take-back program is available.
  • Batteries: Assess the batteries in use. With the exception of alkaline batteries, batteries may be considered hazardous waste.  Properly package, store, recycle and maintain documentation.
  • Sterilants and Disinfectants: Certain chemical sterilants and disinfectant waste may be considered hazardous.  Consult the Safety Data Sheet (SDS) to determine special disposal instructions.

Dispose of pharmaceuticals classified as hazardous waste properly, rather than treating them as medical or solid waste. Pharmaceutical waste includes expired drugs, unusable open drugs, drugs designated for disposal, waste materials with excess drugs, and contaminated absorbents used for spill cleanup. While the color of the waste receptacle is not regulated, select a color that clearly indicates the type of waste it contains to improve clarity and compliance.

P-listed medications are acutely hazardous including epinephrine (not epinephrine salts).  Generate more than 2.2 pounds of acutely hazardous waste in a month, and you may qualify as a “large quantity waste generator.” Therefore, it is very important to segregate such waste properly.

Medical supplies and containers classified as “RCRA empty” must meet all required criteria, including the following:

  • All removable material must be extracted using normal methods
  • Less than 3% by weight of the total container capacity remains
  • Supplies and containers do not contain residue from a P-listed waste

Best Practices for Dental Waste Management

Handle Anesthetic Carpules Properly

Unused anesthetic carpules and used carpules with more than 3% anesthetic residue must be treated as pharmaceutical waste.  Perform ongoing inventory control and stock rotation to avoid expired anesthetic. Tennessee supports EPA’s recommendation on the reverse distribution process for unused pharmaceuticals to the manufacturer for evaluation, possible credit and proper disposal.

Avoid Expiration

Always place the latest shipment of anesthetic toward the back of the stock so that you are utilizing the oldest product first to avoid expiration.  Write the expiration on the outside of the box as a visual reminder.

Use Waste Haulers Wisely

Most dental offices have a relationship with a waste hauler or service provider for biohazardous waste (red bags and sharps containers).  Consult with the provider to determine if the waste company is capable of handling hazardous waste to include pharmaceutical waste.  Based on the limited amount of waste generated, it may be advantageous to pay by pick up rather than a year-long contract. Determine your options prior to signing a contract.

Transportation

Unlike other types of wastes generated, hazardous waste must be transported to a permitted treatment, storage, and disposable facility.

Dental offices that meet the EPA’s definition of a Conditionally Exempt Small Quantity Generator may opt to ship hazardous waste rather than utilize a fuel service.  Keep in mind that offices are required to be a DEA-registrant to ship controlled substances.

Cost Effective Management

The most cost effective way to manage waste is to reduce the amount of waste generated.  Never mix non-hazardous waste with hazardous waste.  Recycle materials where appropriate.  Store hazardous products safely in containers to avoid costly clean up costs.

Waste Management Companies

Some of the waste management companies offer both mail in and pick up services.  The following companies represent a partial list:

MedSafe Waste

XMED Disposal, Inc.

Stericycle

Hazardous Waste Experts

Handle your waste properly and maintain documentation.  For more information about Modern Practice Solutions’ training programs and policy development, please contact (931) 232-7738 or visit www.DentalComplianceTN.com.

  • References:
  • Introduction to Hazardous Waste Identification, 40 CFR Parts 261, EPA, September 2005
  • 40 CFR 261
  • 40 CFR 261.33
  • Evaluating Pharmaceutical Waste, Kentucky Division of Compliance Assistance, 2009
  • Handbook for Hazardous Waste Generators, July 2002, Kentucky Division of Waste Management. www.kyenvironment.org/nrepc/dep/waste/dwmhome.htm

Author

  • Modern Practice Solutions

    If you need support with OSHA and HIPAA compliance, you’re in the right place. Since 2000, we’ve been helping dental practices navigate these complex regulations. We understand the increasing challenges posed by evolving compliance requirements, cyber threats, and the significant government penalties for non-compliance. Let us help you stay protected and compliant.

    View all posts

Compliance Law, Dental Law, Disposal of Hazardous Waste, Modern Practice Solutions

Modern Practice Solutions

If you need support with OSHA and HIPAA compliance, you’re in the right place. Since 2000, we’ve been helping dental practices navigate these complex regulations. We understand the increasing challenges posed by evolving compliance requirements, cyber threats, and the significant government penalties for non-compliance. Let us help you stay protected and compliant.