The Western Lake Superior Sanitary District

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2 The Western Lake Superior Sanitary District has developed this manual to assist you in the proper management of wastes created in your dental practice. Reduction of toxic substances at the source is a mandate of the United States Environmental Protection Agency; it is often the most cost-effective manner of reducing the toxicity of a discharge. The goal of the Bi National Agreement between Canada and the United States is the virtual elimination of toxics from point sources. Mercury discharged to the sewer system when dealing with old or new amalgam is of vital concern within the relatively pristine Lake Superior Basin. In addition to recommendations for reducing mercury discharge, suggestions are also given here for managing other wastes that may be generated in your practice. Amalgam Waste... Page 2 X-ray Fixer and Developer... Page 2 Lead Foil... Page 2 Cleaners for X-ray Developer Systems... Page 3 Disinfectants and Chemiclave Waste... Page 3 Other Wastes... Page 3 Hazardous Waste Compliance. Page 4 Dental Waste Disposal Checklist. Page 5

3 In order to meet the Western Lake Superior Sanitary District's pollution prevention goals, it is necessary to reduce the amount of mercury from amalgam particles entering the sewage system or the garbage. Amalgam particles are a potential source of mercury in the sewer. Amalgam particles are created when old fillings are removed and new fillings are mixed. It is a violation of the Minnesota Hazardous Waste Regulations to dispose of amalgam particles in the garbage or down the sewage system. It is recommended that any amalgam particle that is captured on screens or in traps be recycled. For your reference, a list of recyclers is given in the appendix. These companies will take clean unused amalgam and old amalgam that may be mixed with other contaminants caught in traps or on screens. To minimize the amount of mercury vapor emitted to the office from waste amalgam, the American Dental Association recommends that it be stored under a small amount of photographic fixer in a closed container labeled Waste Amalgam. However, most recyclers of amalgam want the material as dry as possible. Before sending waste amalgam to a recycler, you must decant off the fixer and blot the amalgam dry with paper towel. Most iecyclers pay for clean scrap amalgam, but may not pay for amalgam that is mixed with other wastes from traps. The recyclers request that clean and mixed amalgam be kept separate to aid in ease of recycling. You can send waste amalgam to the recycler via common carrier (Le. UPS) in a strong suitable container. The American Dental Association recommends that small amounts of elemental mercury can be made into amalgam by reacting it with alloy. This results in an amalgam scrap which can be added to the scrap jar and recycled. Contaminated elemental mercury from spills, and absorbents from cleaning up spills of mercury, are accepted by some recyclers of amalgam. This material should be managed as a hazardous waste, with proper labeling, storage, manifesting, and shipping. Used empty amalgam capsules have been determined to be nonhazardous, based on toxicity test results. Empty amalgam capsules may be placed in the garbage. X-ray fixer is considered a hazardous waste because of it high silver content. However, fixer is easily recyclable. Recycling is the management method recommended by regulatory agencies. There are two suitable methods of managing fixer waste: 1.) You may use a silver recovery unit for your developing system; or 2.) you may give, sell, or pay someone that operates a silver recovery unit to take your fixer. For you reference, a list of silver recyclers is included in the appendix. If you dispose of your fixer off-site, collect and store it in a closed plastic container labeled: Hazardous Waste-Used Fixer. The liquid that has run through a recovery unit can be sewered. Hazardous waste rules still require you to report the fixer waste on your Hazardous Waste Notification/License Application and the Notification of Hazardous Waste Activity as described in Section B in this booklet. If shipped as a hazardous waste, it must be properly manifested. If you do not use a hazardous waste manifest, ask for a receipt from the person who accepts your fixer for recycling in order to verify that you are managing your waste in a proper manner. Developer solutions should not be mixed with fixer solutions. Waste developer can be sewered if it is not mixed with fixer. Flush the drain thoroughly as you discharge developer down the drain. Some units mix the fixer and developer after they are spent. The resulting solution is hazardous. However, you may purchase an adapter kit to keep the fixer and developer separate. The fixer can be recycled and the developer can be sewered. Lead foil that shields X-ray film or protective lead shields should not be disposed of in the garbage. These materials are hazardous waste unless they are recycled for their scrap metal content. A recent survey by the Western Lake Superior Sanitary District, with cooperation of the Northeast District Dental Society, indicated that a high percentage of dentists are presently recycling lead foil. Companies which recycle amalgam or fixer may also accept lead waste. A list of metal reclaimers is given in the appendix. Systems are available to treat rinse waters contaminated with old amalgam that is too fine to be caught in traps or on screens. These systems are used in Europe and are being evaluated by several U.S. organizations at the present time. Until use of such systems is feasible, recycling of amalgam that can be captured is the major objective of regulatory agencies. NOTE: If amalgam or other metals are recycled for their metal content, they are not subject to hazardous waste regulations.

4 Many cleaners for X-ray developer systems contain chromium. You can check the Material Safety Data Sheet (MSDS) to see if the cleaner you use contains chromium. If your cleaner does contain this metal, the wastes from cleaning should be managed as a hazardous waste and require a hazardous waste disposal service. It is easier and cheaper to use a system cleaner that does not contain chromium. According to photo industry representatives, the environmentally safe cleaners are as effective as the chromium-based cleaners. 1 Disinfectants Used disinfectants may be discharged directly to the sewage system. Residue left in containers may be rinsed down the drain; the container may be disposed of in the garbage or recycled through your local recycling program. Flush the drain well when disposing of any disinfectant. Straight alcohols, ethers, and peroxides are considered flammable and should not be sewered because of the possibility of explosion. I Chemiclave Waste chemical sterilizer waste may be discharged to the Western Lake Superior Sanitary District sewer system. Flush the drain well when disposing of this waste. Any unused chemical is a hazardous was& if it has a flash point below 140 degrees Fahrenheit, or if it contains high concentrations of formaldehyde. Buy only the amount of chemical sterilizer that you need; this will eliminate the need to dispose of the excess material. Blood: Flowable quantities of blood may be sewered. Swabs or dressings that are bloody and dripping need to be treated as infectious medical waste. If they contain only a small amount of blood that will not drip out of the material, they can be placed in the garbage. Sharps: Needles, scalpels, reamers, broaches, and other sharp objects that could cause a puncture wound should not be placed in the garbage even if they are sterilized. This type of waste should be placed in a puncture-proof container. Disposal should be through an infectious medical waste service. A list of medical waste transporters is provided in the appendix. Office waste: Although office waste is usually not hazardous, we wish to remind you that aluminum, glass, newspaper, corrugated paper, and office paper can easily be recycled through your garbage hauler or recycling center. It is mandatory to do so. Please call the Western Lake Superior Sanitary District Garbage Hotline for information about recycling office waste.

5 This section discusses your responsibilities as a Very Small Quantity Generator of hazardous waste in Minnesota. If you generate more than 22 gallons of hazardous waste per month, you must comply with additional regulations. Below is a list of the waste codes you may need to fill out the proper forms: Amalgam waste... D009, DO1 1 If you generate any of the following wastes, you must Photographic Fixer... DO1 1 obtain an Environmental Protection Agency Identification Number and State Hazardous Waste License: Ignitable Waste... DO01 Photographic Fixer (even if it is recycled) Chromium containing cleaners Chromium containing cleaners... DO07 Lead containing materials... DO08 Flammable chemicals Waste mercury... DO09 Waste elemental mercury Lead containing materials that are not recycled Amalgam that is not recycled If you have not already obtained an EPA ID Number, you should fill out the EPA form titled Notification of Hazardous Waste Activity and send it to the address in the instructions. To obtain this form, request fact sheet 7.09 from: Minnesota Pollution Control Agency Hazardous Waste Division 520 Lafayette Rd. St. Paul, MN Phone: Si The container in which you store your hazardous waste must be labeled with the words "Hazardous Waste" with a description of the waste. Example: Hazardous Waste-Used Fixer The date you started filling the container should be written on the bottle or on a label. Standard labels are commercially available. 3 Store all hazardous waste in closed containers. Make sure the containers are appropriate for the waste being stored (plastic container for fixer waste). Containers should be inspected once a week. A written log of these inspections should be kept and should include date, person inspecting the storage area, and comments. Liquid hazardous waste should be stored on an impermeable surface in an area without floor drains. If you have not already obtained a Hazardous Waste License, you should fill out the Minnesota Pollution Control Agency form titled Hazardous Waste Notification/License '%@ication. This form may also be obtained fmn the bhnesota Pollution Control Agency. Request fact sheet Each Year You will be sent a kense for It must be filled Out with infot"ion On how your Waste Was managed. Businesses generating less than 22 gallons of waste per month are allowed to transport silver containing waste (fixer) destined for recovery without manifesting the waste or using the services of a licensed transporter. If you are recycling amalgam and lead foils for their metal content, they are not subject to hazardous waste regulations. However, if you generate other waste such as chromium-based cleaners or large quantities of flammable liquid, you must use a licensed hazardous waste transporter, and you must manifest the waste for shipment.

6 POST THIS APPENDIX FOR YOUR REFERENCE Amalgam Recyclers W.E. Mowry & Company 1435 University Avenue St. Paul, MN (61 2) Mercury Refining Co. 709 Watervliet-Shaker Road Latham, NY (also accepts contaminated raw mercury) D.F. Goldsmith 909 Pitner Avenue Evanston, IL (708) Strickland Refining Company st Avenue Northeast Minneapolis, MN (612) Premier Dental 478 South Robert Street St. Paul, MN (61 2) EnviroC hem Industrial Boulevard Rodgers, MN (61 2) Si Ive r Recyclers James Alexander 5534 Maple Grove Road Hermantown, MN (218) W.E. Mowry & Company 1435 University Avenue St. Paul, MN (612) EnviroChem Industrial Boulevard Rodgers, MN (61 2) Silver Recovery Systems Northern Recovery Systems Dennis Oswell 5260 Samuelson Road Duluth, MN (218) American Precious Metals 151 A Highway 35 North River Falls, WI (71 5) Scrap Metal Reclaimers Premier Dental 478 South Robert Street St. Paul, MN (61 2) Mississippi StreePMetals 800 Mississippi Street St. Paul, MN (61 2) West End Iron & Metal Inc South 39th Avenue West Duluth, MN (218) TLK Industries Inc. 902 Ogden Avenue Superior, WI (71 5) Medical Waste TransporterslDisposers BFI Medical Daniel Gregg Medical Safety Systems JOG Franklin DuluthCloquet area (218) Strickland Refining Company st Avenue Northeast Minneapolis, MN (61 2)

7 Traps, screens, excess mix 1) Sell, give away, or pay to have silver reclaimed 2) Buy silver recovery system I Combined fixer and developer X-ray processing 1) Purchase kit to separate and use methods listed for fixer and developer Chromium containing x-ray system cleaners X-ray system cleaning 1) Switch to non-chrome cleaners 2) Dispose of as a hazardous waste Disinfectants Used 1) Discharge to sewer Chemiclave chemicals Used 1) Discharge to sewer New 1) Call Western Lake Superior Sanitary District Lead foils and shield X-ray processing protective shields 1) Send to metal reclaimer 2) Dispose of as a hazardous waste I Blood Liquid 1) Discharge to the sewer Dripping swabs, etc. 1) Dispose of as infectious waste Non-dripping swabs, etc. 1) Dispose of in garbage Infectious waste service

8 u- A cooperative environmental assistance project of the MPCA and the WLSSD Western Lake Superior Sanitary District 2626 Courtland Street Duluth, Minnesota WLSSD Hotline (218) , Printed on recycled paper 100/15 3/931M PP WLW &