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Compliance Bulletin

Hazardous Waste Photographic, X-ray, and Dental Wastes

Dental clinics and photography or radiology laboratories generate relatively small quantities of several types of hazardous and nonhazardous wastes. There are only two categories of hazardous waste: listed and characteristic. The Colorado Hazardous Waste Regulations (6 CCR 1007-3) list more than 400 hazardous wastes on four lists. Even if a waste does not appear on the lists, it may be a characteristic hazardous waste if:

• it is easily combustible or flammable (ignitable);
• it dissolves metals or other materials or burns the skin (corrosive);
• it is unstable or undergoes rapid or violent chemical reaction or produces toxic gases when mixed with water or other materials (reactive);
• it is a metal, pesticide, herbicide, or organic chemical at high enough concentrations that could be harmful or toxic if released into ground water (toxic).

(6 CCR 1007-3 Part 261)

Many small dental clinics and photography or radiology laboratories are classified as Conditionally Exempt Small Quantity Generators (CESQG) of hazardous waste, meaning that they generate less than 100 kilograms (kg) (about 220 pounds or 25 gallons) of hazardous waste per calendar month (6 CCR 1007-3 Part 261.5). CESQGs are responsible for identifying all hazardous wastes that they generate (6 CCR 1007-3 Part 262.11), can accumulate up to 1000 kg of hazardous waste on site at any one time, and may either treat their own hazardous wastes or ensure delivery to a facility that is authorized to accept that hazardous waste (6 CCR 1007-3 Part 261.5). Although not required, it is recommended that CESQGs utilize the hazardous waste manifest system and hazardous waste transporters when disposing of their hazardous wastes.

There are additional requirements for generators of 100 kg or more of hazardous wastes per month. Refer to the Colorado Hazardous Waste Regulations 6 CCR 1007-3 Part 262 and the "Guide to Generator Requirements of the Colorado Hazardous Waste Regulations," available from the Colorado Department of Public Health and Environment for more information.

HAZARDOUS WASTES

The most common sources of hazardous wastes generated by dental clinics and radiology laboratories include:

• Fixer - contains silver, D011
• Undiluted developer - corrosive, D002
• Lead foil, dental bite wings, discarded lead shields - contain lead, D008
• Amalgam - contains silver & mercury, D011, D009
• Dental trap filter wastes - contain lead, silver, mercury, D008, D009, D011
• Some cleaners for developer systems - contain chromium, D007
• Old X-ray equipment - may contain PCBs, regulated under the Toxic Substances Control Act (TSCA)

(6 CCR 1007-3 Part 261.24)

Recycling

Silver
Silver from used film, fixer, and paper is a valuable resource that should be recycled. These wastes may be classified as hazardous wastes depending on the concentration of silver (6 CCR 1007-3 Part 261.24). There are essentially two ways to recover the silver, either recycling onsite or collecting it for an offsite recycling service to pick up. Onsite recycling is generally limited to used fixer, rather than film or paper. The generator can install a silver recovery unit (electrolytic units, recirculating electrolytic units, and cartridges) at the end of the x-ray or film processing unit. The recovered silver can then be sold to a metal reclaimer and the treated fixer disposed of down the drain with prior permission of public wastewater treatment authority (6 CCR 1007-3 Part 100.21). Facilities that have individual septic disposal systems should not dispose of this material down the drain, as it can harm the septic system. They should contract with an industrial wastewater disposal company to dispose of these wastes.

For offsite recycling, the generator should collect and store used fixer in a closed plastic container. Although not required for CESQGs, it is good management practice to label this container with the words "Hazardous Waste-Used Fixer" and the date that the fixer was first added to the container. When enough used fixer has been accumulated, the generator can arrange pick-up by the recycling service. The recycling service will reclaim the silver from the used fixer at the recycler’s site. Many will offer this service for used film and paper as well.

Lead
Lead from lead foil, bite wings, and discarded lead shields may be recycled as scrap metal through scrap metal recyclers, through some silver recyclers, or contact your dental supply company for recycling assistance (6 CCR 1007-3 Part 261.6(a)(3)).

Amalgam and dental trap wastes
Amalgam containing silver and mercury may be sent offsite for recycling along with dental trap wastes that collect amalgam particles and some lead scraps (6 CCR 1007-3 Part 261.6(a)(3)). Check with your recycler to make sure they are willing to take both amalgam and lead wastes. These particulates should be collected in a closed container compatible with the waste. It is good management practice for the CESQG to label the container as "Hazardous Waste-Amalgam and Dental Trap Wastes" and mark it with the accumulation start date. When a sufficient amount has been collected, the offsite recycler should be contacted for pick-up. Used and empty amalgam capsules may be disposed of as solid waste with the regular trash.

Disposal
Hazardous wastes that cannot be recycled or are disposed of rather than recycled have to be disposed of as hazardous wastes. This includes chromium-based cleaners for developer systems and unused developer. Some wastes, such as unused developer (corrosive), may be treated by the generator and disposed of down the drain with prior approval of the wastewater treatment authority (6 CCR 1007-3 Part 100.21). The generator should contact a hazardous waste disposal company for assistance. Oils containing PCBs and PCB-containing equipment with greater than 50 ppm PCBs are regulated under the Toxic Substances Control Act by the Environmental Protection Agency (EPA) (40 CFR Part 761). Contact the EPA Region VIII offices for assistance on PCB management.

NON-HAZARDOUS WASTES

Developer
Used or diluted developer is a non-hazardous waste and can often be flushed down the drain with the permission of the public wastewater treatment authority. Facilities that are on individual septic disposal systems should not pour this material down the drain because it can harm the septic system. They should contract with an industrial wastewater disposal company for disposal of these wastes.

Infectious Wastes
Blood on swabs or dressings and used sharps (needles, probes, etc.) are considered non-hazardous infectious wastes (25-15-401 CRS). Infectious wastes are a special (solid) waste in Colorado that require special handling prior to disposal (6 CCR 1007-2 Section 1.2). Properly labeled and packaged infectious wastes can be disposed of without treatment if it is acceptable to the waste hauler and disposal site (6 CCR 1007-2 Section 13.8). Infectious wastes that have been rendered non-infectious may be mixed with the regular trash. The use of a treatment method recommended by EPA guidance for infectious waste management is usually accepted as appropriate treatment (25-15-404 CRS, 6 CCR 1007-2 Section 13.8.3). Contaminated sharps must be placed in a puncture-resistant rigid container and treated prior to disposal; untreated containers of sharps cannot be compacted (6 CCR 1007-2 Section 13.8.4).

For more information please contact:

Colorado Department of  Public Health & Environment
Hazardous Materials and
Waste Management Division
4300 Cherry Creek Drive South
Denver, Colorado 80222-1530
Customer Technical Assistance (303) 692-3320
E-mail comments.hmwmd@state.co.us
www.cdphe.state.co.us/hm/ 

This Compliance Bulletin is intended to provide guidance on the appropriate management of wastes based on Colorado solid and hazardous waste statutes and regulations only. The wastes described in this guidance may also be regulated under other statutes and regulations. 7/97 CHW-012