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Regulatory Compliance: Regulated Waste Management
CDA Practice Support
Dental practices have two types of regulated waste: hazardous and medical. Each type is regulated by separate laws and, in many communities, different agencies. This article summarizes what comprises each waste type, rules on storage and disposal and registration and documentation requirements.
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Hazardous Waste
Dental wastes in this category include glutaraldehyde, amalgam, photographic fixer and lead. State and federal hazardous waste laws regulate waste characterization. California imposes rules on storage and disposal of hazardous waste. Waste generators must register with their local agency, which works in conjunction with the state Department of Toxic Substances Control. A hazardous waste management plan and California EPA ID number may be required.
Glutaraldehyde waste must be managed as a hazardous waste unless it is treated to render it nonhazardous. Treatment of hazardous waste in California typically requires a permit. However, a permit is not necessary if glutaraldehyde waste is treated with a solution containing glycine as its only active ingredient. A dental practice should check with its local sanitation agency to verify that the treated solution may be disposed safely down the drain.
Although not categorized as a hazardous waste, large amounts of plaster disposed at a landfill can potentially lead to the formation of toxic hydrogen sulfide gas as the material decomposes. Recycling is the preferred option for disposing of this material. If closing a dental practice and in possession of a lot of models, contact the local landfill office for information on disposal options.
Other hazardous wastes generated by dental practices have the option of being managed as universal waste. Universal waste is a category of hazardous waste widely produced by households and different types of businesses. Universal wastes cannot be disposed in landfills and should be recycled. Hazardous and universal wastes may not be stored for longer than one year. Each type of waste should be collected in their own nonbreakable and closeable container and labeled with the contents and the date waste collection in the container was started. If using a mail-back service for disposal, the service will provide the appropriate container. Another disposal option is local household hazardous waste programs. Several programs in the state accept waste from very small-quantity generators. Contact information for these programs is available in “Household Hazardous Waste and Small-Quantity Generator Programs by County” on cda.org/practicesupport.
Medical Waste
Dental wastes in this category are contaminated sharps, pharmaceutical waste (not including controlled substances), used anesthetic carpules with aspirated blood and absorbent materials that are dripping or flaking blood. The California Medical Waste Management Act (MWMA) dictates the rules for medical waste management and disposal. Medical waste generators are required to register with either the California Department of Public Health (CDPH) or local enforcement agency and pay a regular fee. In some circumstances, a medical waste hauler will collect the fee. The MWMA applies different rules to small-quantity generators, such as dental practices, than to larger generators. A smallquantity generator generates less than 200 pounds of medical waste per month. Generators must have a written medical waste management plan.
Sharps are the most common medical waste generated by dental practices. It includes but is not limited to hypodermic needles, hypodermic needles with syringes, blades, needles with attached tubing, acupuncture needles, root canal files, broken glass items used in health care such as Pasteur pipettes and blood vials contaminated with biohazardous waste and any item capable of cutting or piercing from trauma scene waste. Contaminated sharps and anesthetic carpules with aspirated blood should be collected in FDA-cleared sharps containers that are closeable and difficult to reopen after sealing shut, puncture resistant and leak proof on all sides. Sharps containers can be any color and should be labeled “Biohazardous Waste” or “Sharps Waste” with fluorescent orange or orange-red labels with letters and the hazard symbol in a contrasting color. The container should be maintained upright, easily accessible to the immediate area of sharps use and not filled past the fill line.
The sharps container should be disposed of within 30 days of the container being three-fourths full or filled or within 90 days if the sharps container is stored at less than 32 F. If the sharps container is combined with biohazardous waste in another container, the combined waste must be disposed within the shorter disposal schedule for biohazardous waste.
Pharmaceutical waste includes expired drugs and unused drugs, but it does not include controlled substances. Expired or unwanted controlled substances must be disposed of through a DEA-registered service, sometimes the same ones that will accept other pharmaceutical waste. Pharmaceutical
waste should be placed in a leak-proof container that is closeable and has a tight-fitting lid. The container should be labeled “High Heat,” “Incineration Only” or have other wording approved by the CDPH on the lid and on the sides. The pharmaceutical waste must be disposed of within one year that waste accumulation starts if the dental practice generates less than 10 pounds of waste per year or within 90 days if more than 10 pounds per year is generated.
Biohazardous waste includes containers, equipment or disposables (e.g., gauze and cotton rolls) that drip blood or saliva when compressed or that flake dried blood when shaken. Pathology waste includes human body parts, with the exception of teeth, removed at surgery and surgery specimens or tissues removed at surgery or autopsy that are suspected by the health care professional of being contaminated with infectious agents known to be contagious to humans or that have been fixed in formaldehyde or another fixative.
Biohazardous waste must be placed in a red biohazardous bag and pathology waste placed in a white biohazardous bag. The biohazardous bags should be placed in rigid, leakproof containers of any color that are closeable and have a tight-fitting lid. A container with biohazardous waste must be labeled “Biohazardous Waste” or “Biohazard” on the lid and sides. A container with pathology waste must be labeled “Pathology Waste,” “PATH” or other label approved by the CDPH on the lid and sides. Before disposal, bags must be tied to prevent leakage or expulsion of contents during storage, handling or transport.
Biohazardous and pathology waste, stored at room temperature, must be disposed of within 30 days of the date waste accumulation starts if the dental practice generates less than 20 pounds of such waste per month or within seven days if more than 20 pounds of waste is generated per month. Dental practices that generate less than 20 pounds of biohazardous waste per month may store the waste at 32 F or below for up to 90 days before disposal. Mail-back programs are available.
What Is Not Medical Waste
Medical waste does not include disposal items, such as gauze or cotton, soiled with nonfluid blood or saliva; teeth not meeting the definition of biohazardous waste; or urine, feces, saliva, sputum, nasal secretions, sweat, tears or vomitus unless it contains visible or recognizable fluid blood. These items are not considered “regulated medical waste” and may be disposed of as regular solid waste.
With respect to extracted teeth, neither Cal/OSHA nor the MWMA prohibit dentists from giving patients back their own extracted, nonbiohazardous teeth. Teeth containing amalgam or other heavy metal should be managed either as universal waste or hazardous waste and should never be discarded as regulated medical waste or as solid waste.
Regulatory Compliance appears monthly and features resources about laws that impact dental practices. Visit cda.org/ practicesupport for more than 600 practice support resources, including practice management, employment practices, dental benefit plans and regulatory compliance.
