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Biomedical Waste Management Protocol

Classification of Types of Waste

  • Dental Amalgam Wastes
    • 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
  • Chemicals, Disinfectants and Sterilizing Agents
  • Medical Waste
    • Sharps Waste
    • Biohazardous Waste
  • Non Hazardous Office Waste

Best Management Practice for Waste Disposal

Dental amalgam waste

Mercury is a persistent, bio-accumulative toxin, risky to human health, wildlife and the environment. While there has been considerable public debate about the potential health effects of mercury fillings, little attention has been focused so far on the disposal of waste dental mercury. Mercury is a natural metallic element. Human activities--including the use of dental fillings contribute around 70% waste. Levels of mercury in the enviornment have increased dramatically, with a twenty fold increase over the past 270 years.

Mercury disposal and extracted amalgam materials by dental clinics is largely unregulated. It is often rinsed down the drain, usually to a municipal waste water system or septic systems or dental clinic, deposited it in biomedical waste containers destined for waste incineration or placed in trash disposed in a municipal waste landfill or incinerator.

  • Do not rinse amalgam-containing traps, filters or containers in the sink.
  • Do not place amalgam, elemental mercury, broken or unusable amalgam capsules, extracted teeth with amalgam or amalgam- containing traps and filters with medical or regular solid waste.
  • Recycle or manage as hazardous waste, the above mentioned materials. Empty dental amalgam capsules containing no visible materials may be disposed of as a non-hazardous waste.
  • Collect and store dry dental amalgam waste in a designated, airtight container. Amalgam which is designated for recycling should be labeled “Scrap Dental Amalgam” with the name, address and phone number of your office and the date on which you first started collecting material in the container. In the past, dental amalgam scrap may have been kept under photographic fixer, water or other liquid. If you should encounter amalgam stored in this manner, do not under any circumstances decant the liquid down the drain.
  • Keep a log of your generation and disposal of scrap amalgam.
  • Check with your amalgam recycler for any additional requirements. Some recyclers do not accept contact amalgam (amalgam that has been in the patient’s mouth); others may require disinfecting the amalgam waste. Separate excess contact dental amalgam from gauze that is retrieved during restoration and place in an appropriate container.
  • Use chair side traps to capture dental amalgam.
  • Change or clean chair side traps frequently. Flush the vacuum system before changing the chair side trap.
  • Change vacuum pump filters and screens at least monthly or as directed by the manufacturer.
  • Check the trap under your sink for the presence of any amalgam- containing waste.
  • Eliminate use of bulk elemental mercury and use only pre-capsulated dental amalgam for amalgam restorations.
  • Limit the amount of amalgam triturated to the closest amount necessary for the restoration, i.e. don’t mix two spills when one spill would suffice. Keep a variety of amalgam capsule sizes on hand to ensure almost all triturated amalgam is used.
  • Train staff to handle mercury-containing material in its proper use and disposal.
  • Do not use bleach to clean discharges as this may mobilise mercury and amalgam in the system.
Guidelines regarding
Amalgam Traps

Disposable amalgam traps are preferable to reusable traps because of the difficulty in removing amalgam particles from the trap without discharging them in to the sewer or garbage. Disposable traps should be changed weekly or more frequently if needed or as recommended by the manufacturer of your equipment.

Only traps on chairs used for amalgam placement or removal need special handling. Traps from chairs not used for amalgam procedures may be placed in the regular solid waste.

The use of reusable chair-side amalgam traps is not recommended. However, if reusable amalgam traps are used, please follow the following steps:

  • Use precapsulated dental amalgam.
  • Use proper work area to provide secondary containment and follow a written mercury spill clean-up procedure.
  • Maintain a mercury clean-up kit in your clinic to manage accidental spills. 
  • React triturate small amounts of unused elemental mercury with silver alloy to form scrap amalgam for recycling.
  • Elemental mercury from spills and absorbent from the clean up of mercury spills are accepted by some mercury recyclers.  Contact a mercury recycler on how to properly store, label and ship these waste materials.
Contact 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 or store it as hazardous waste or collect and store as recyclable waste, if the metal recycler accepts contact amalgam.

Other Scrap Heavy Metals

In addition to dental amalgam, other sources of heavy metals in the dental clinic 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 into the sanitary sewer system. X-ray photochemicals also contain heavy metals. Elemental nickel, chromium in stainless steel (does not include X-ray cleaning solutions) and other heavy metals should be recycled as scrap metal. As long as it is not fine powder, elemental metals other than lead or mercury can be disposed of as solid waste. Impression materials containing zinc oxide could be considered hazardous waste.

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.

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 into 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.

Onsite Treatment and Disposal

Silver recovery units are available to remove the silver from the fixer. When using a silver recovery unit, remember to:

  • Check the unit daily for leaks, spills and overflows.
  • Periodically check the flow rate of solution to the recovery system. Typically a lower flow rate and a longer retention time will maximize silver recovery.
  • If using an electrolytic unit, check the appearance of the silver plate. The plate should be tan to brown and grainy. If it is black, mushy and smells like sulfur, the amperage may be too high. If the silver plate is hard and white, the amperage is probably too low. Consult your user’s guide for specific guidance.
  • Test the silver concentration of the treated fixer monthly. The test can be performed with an analytical test kit or a lab analysis. Periodic testing will tell you how effective your unit is at capturing silver and will alert you to recovery unit problems.
  • Record test results in a silver recovery log.
Offsite Reclamation/Recycling

Used X-ray fixer solutions can be hauled offsite for treatment and recycling to a EPA(environmental protection agency) 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 should not be discharged down the sanitary sewer. 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. If possible, switch to a non-chromium containing cleaner which can be discharged in to the sanitary sewer. Otherwise, the waste must be handled as hazardous waste, requiring proper collection, labeling and disposal.

Chemicals, Disinfectants and Sterilizing Agents

The dental community uses a variety of chemicals for sterilizing, disinfecting and cleaning. Several of these products may contain active chemical ingredients (e.g. formaldehyde), that may be classified as hazardous. In addition, many municipalities place concentration limits on chemicals released to the sewer. Before discharging chemicals into the sewage system, consult the municipality for further information.

Some of these chemicals may be explosive if released into the sewers in large quantities. Other chemicals may disrupt the microbial process that breaks down wastes in sewage or damage the drainage and sewer pipes over time. Additionally, certain chemicals may negatively impact the environment and human health. Using less harmful alternatives, cleaning methods and/or surface barriers can reduce the impact on the environment and the need for special handling of waste in the dental practice.

If classified as special waste, used cleaning or disinfectant solutions should be stored in labeled, sealed and leak-proof containers in a secure location. This would minimize an accidental spill or leak and container failure will not result in the chemicals entering any sanitary sewer, septic system or storm drain. If this is not possible then, adequately sized secondary containment should be provided for this equipment or all floor drains in the area should be capped. Hazardous waste disposal vendors can provide pick-up services for special wastes or flammable wastes. If not classified as special waste, small quantities of cleaning solutions and disinfectants may be discharged to sanitary sewers (but not into storm sewers or septic systems).


If any chemical has a pH less than or equal to 6.0 or greater than or equal to 10.5, contact the municipality for disposal guidance. If any chemical contains formaldehyde and/or formalin, gluteraldehyde, ammonia or phenols, contact municipality for disposal guidance.

If any detergent contains nonyl phenol ethoxylates, determined to be toxic substances contact the municipality for disposal guidance. Discard pharmaceutical wastes such as unused drugs and narcotics through an approved waste carrier. Before discharging chemicals, disinfectants and sterilizing agents into the sewer ensure that guidelines are followed.

Thoroughly rinse empty disinfectant containers and recycle or dispose of them in regular garbage. Collect and transport chemicals, disinfectants or sterilizing agents in an appropriately labeled, sealed container to a dental clinic for disposal through an approved waste carrier.


Do not pour ignitable/flammable substances (straight alcohols, ethers, acetone, xylol, chloroform) or other solvents down the drain. Do not pour X-ray cleaning solutions containing chromium down the drain. Hexavalent chromium compounds are deemed toxic. Furthermore, this is classified as hazardous waste.

For portable dental equipment and mobile dental units, do not dispose of any accumulated chemicals, disinfectants or sterilizing agents in a remote site which does not have a disposal arrangement through an approved waste carrier.

If the dental practice is connected to a septic system, do not discharge sterilants or disinfectants (like bleach and ammonia based cleansers), chemical solvents and pharmaceuticals. These may disrupt the proper functioning of the septic system. Use alternatives or collect discharge for pickup by an approved waste carrier. Consult the municipality for further guidance.

Waste Gluteraldehyde and OPA

Gluteraldehyde and orthophthaldehyde (OPA) are the active ingredients is several brands of sterilizing solutions. The sole active chemical of the neutralizing solution is glycine.

To dispose of waste glutaraldehyde or OPA down the sanitary sewer drain

  • Before purchasing the neutralizing solution, check with your sanitation agency regarding any prohibitions for discharging the neutralized solution to the sanitary sewer.
  • Contact the manufacturers of the sterilizing solution and/or glycine solutions or your dental supply company for instructions on proper neutralization techniques.
  • Once the solution has been neutralized and if approved by the sanitation agency, dispose of the waste mixture down the sewer drain.

Gluteraldehyde 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 claim that it has degraded to non-hazardous levels should check with their suppliers to see if they have data to support their claim. 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 it 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.

To dispose waste formalin into the sewer the following requirements must be met:

  • Solution must be non-hazardous (i.e. must pass the state's aquatic bioassay test for toxicity).
  • Solution must have flash point no less than 140° F.
  • 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 the above requirements. 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.

Medical Waste

Regulated medical waste consists of sharps (hypodermic needleds, blades, syringes) and biohazardous wastes (e.g. laboratory wastes, solid wastes covered with blood or other potentially infectious materials and pharmaceuticals).


Wastes containing mercury or contaminated with mercury should never be placed with the medical wastes as these wastes will be incinerated and there by releasing mercury into the environment.

Sharps Waste

Sharps containers are designed specifically for the containment and disposal of sharps such as needles, syringes with needles, scalpel blades, clinical glass or other items capable of causing cuts or punctures. Sharps are to be placed into a puncture-resistant leak- proof container designed specifically for the management of sharps. If these containers are not resistant to penetration or compression, they pose a health risk to those involved in their handling and disposal.

Needlestick and puncture wound injuries and resulting infections have been recorded in situations where sharps have been improperly handled and/or disposed. All clinical sharps should be considered potentially infectious.

Disposable sharps should be placed in a proper sharps container. A sharps container should be located in each operatory and the sterilization lab. These should be:

  • Separated from other types of biomedical waste.
  • Placed in a rigid, puncture resistant, leak-proof container (provided by biomedical waste disposal vendors) and labelled “biohazard - waste sharps” .
  • Permanently sealed in the container (when full) and picked up by a biomedical waste disposal vendor for proper disposal.
  • To prevent injury do not fill sharps containers past the fill line or if no fill line exists, more than three-quarters.

Other types of biomedical waste including soiled rubber gloves, used swabs and other blood or body fluid-saturated items. These should be

  • Separated from waste sharps.
  • Placed in a red bag that is labeled “biohazard” .
  • Stored in a rigid leak-proof container. Picked up by a biomedical waste disposal vendor for proper disposal.

Waste sharps and other types of biomedical waste must not be mixed with or disposed of as municipal garbage.

Biohazardous Waste

Solid 'red-bag' waste must be collected and disposed as regulated medical waste. You must contact a registered medical waste hauler for transfer of solid waste to a licensed offsite treatment facility. Proper treatment by a permitted facility consists of either autoclave sterilization or incineration.

Anatomical Wastes (Human Tissue)

Human tissue waste generation is normally limited to oral surgeons and periodontists. In this context, all human tissue wastes are required to be treated as biomedical/pathological wastes.


Separate human tissue from sharps and blood soaked materials. Collect human tissue in red liners that are marked with the universal biohazard symbol (these liners are normally provided by a biomedical waste carrier). Store anatomical waste in an enclosed storage area that is locked and separate from other supply areas. Anatomical wastes should be stored at a temperature at or below 4 degree. The storage area must be marked as a Biomedical Waste Storage Area and must display the universal biohazard symbol. For portable dental equipment and mobile dental units, transport human tissue wastes in an appropriately labeled and sealed red liner to a dental practice for disposal through an approved waste carrier.


Do not dispose human tissue with the regular garbage.

Pharmaceutical waste

Either expired or partially-used, pharmaceutical waste must be collected and transferred by a registered hauler to a licensed incinerator. Store pharmaceuticals in labeled, sealed and leak-proof containers in a secure location in such a manner that an accidental spill, will not result in chemicals entering any sanitary sewer or storm drain. If such a location is not available, adequately sized secondary containment should be provided for this equipment or all floor drains in the area must be capped. Do not dispose off expired or excess pharmaceuticals into the garbage, the sewer system or mix them with biomedical wastes. Laboratory/surgical wastes must be collected and transferred by a registered hauler to a licensed incinerator.

Non-Hazardous Office Wastes

The following procedures are suggested to help operators improve their overall environmental performance:

  • Choose products with the least packaging and the highest recyclable material content.
  • Regular office waste generated by dental offices should be recycled whenever possible.
  • Waste paper, aluminum cans, newspaper, glass, cardboard and plastic containers should be recycled.

Pollution Prevention policies

We cannot afford to be negligent or ignorant towards the environment. It is essential that we follow norms and regulations in the dental clinic to ensure minimal damage to the environment. Control strategies must be implemented to reduce the generation of waste and minimize the potentially detrimental effect on employee safety and the environment, based on the following principles:

  • Avoid, eliminate or substitute polluting products or materials.
  • Reduce use of pollouting products or materials. 
  • Elimination and reducte of the generation of polluting by-products.
  • Reuse and recycle polluting by-products.
  • Energy recovery from polluting by-products.
  • Treatment or containment of polluting residual by-products.
  • Remediation of contaminated sites.

Such practices include the following:

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:

  • Precapsulated amalgam instead of bulk mercury.
  • Digital radiography.
  • Steam sterilization instead of chemical sterilization.
  • Non-hazardous biodegradable detergents for clean-up.
  • Non-chromium containing X-ray system cleaners.

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.

Safe Work Practices

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

Good Housekeeping

Inspect containers of potentially hazardous materials and wastes regularly to spot damaged or leakage containers. Repackage or place damaged containers in secondary containment immediately. Protect containers from damage by storing in a protected area. Store hazardous, universal, recyclable and non-hazardous wastes in separate and appropriate containers. Place liquid waste containers in secondary containers that can hold 110% of the waste volume.

Know and follow the requirements of your hauler or recycler for each type of waste.

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 guidelines with respect to mercury hygiene are included below.

  • Check that your high speed evacuation system is linked to a filter- equipped vacuum system. Periodically change filters/traps in accordance with manufacturer’s recommendations.  The used filters contain amalgam. The traps and filters that contain amalgam must be recycled or managed as hazardous waste.
  • Check that you are using the smallest available vacuum filter screen without compromising vacuum suction.  Ask manufacturer for the finest screen that will work with your unit.
  • Check that vacuum pumps are equipped with filters.  Even some dry turbine vacuum Check that vacuum pumps are equipped with filters.  Even some dry turbine vacuum pumps need filters.  Check with manufacturer.
  • For dry turbine vacuums, check to ensure that built up sludge in air/water separators is cleaned out regularly.
  • Check that sludge from filters and air water separators is recycled or disposed of as hazardous waste. Do not rinse sludge down the drain.
  • Check the traps under sinks.  Amalgam and mercury waste can accumulate in these traps.
  • Check that cuspidors have filters.  Contact equipment manufacturer or supplier for information.
  • Utilize traps and filters with the smallest screen size that your vendor says will work. 

Waste streams that are designated for recycling/reclamation 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”. The label must also have the following information as required by state law:

  • Date from which accumulation was started.
  • Name and address of office generating the waste.
  • 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- “Universal Waste—Batteries”, “Universal Waste—Lamps” or “Waste Dental Amalgam”.
  • Appropriate labels are usually available from your licensed hazardous waste recycler or hauler.
  • 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.
  • Containers should be kept securely closed 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. However, IDA recommends that dental personnel maintain a written log indicating the inspection date, the identification by the inspector and any comments or corrective actions taken.

You must keep records of the hazardous waste generate whether you get it recycled or disposed offsite. In general, if you send your hazardous waste offsite for recycling or disposal, you must utilize a licensed hauler.

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
  • Regarding the importance of pollution prevention.
  • Proper hazardous material and waste handling, including proper utilization of personal protective equipment, storage and disposal in accordance with government regulations. Provide re-training when there is a change in procedures or process.
  • Develop and keep  "a current  spill response plan". Make the plan available to employees.
  • Chemical manufacturers and suppliers provide these data sheets to outline the associated chemical and safety information regarding their products including emergency response and procedures.

Regulatory Bodies

In exercise of the powers conferred by section 6, 8 and 25 of the Environment (Protection) Act, 1986 the Central Government notifies the rules for the management and handling of bio-medical waste.The Pollution Control Boards in turn are responsible for implementation of the rules.

The Pollution Control Board is the overall regulatory body with respect to Biomedical Waste Management. The board has laid down rules and regulation regarding the correct method of waste classification, segregation,treatment and disposal.

The board has authorized certain waste disposal facilities with government recognition.

Inorder to find an authorized Waste Collection Facility near you,one can contact the Pollution Control Board of their State. There are penalties for not following all the guidelines correctly.

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