Dental Offices Solid Wastes - Hazardous Waste

Hazardous wastes are regulated under the federal Resource Conservation and Recovery Act or similar state regulations. These rules require all businesses, including dental offices, to determine if the wastes they generate are hazardous or not, and if they are hazardous, to follow specific procedures for managing and disposing of the wastes.

In order to regulate the over 800,000 hazardous waste generators in the U.S., EPA established three categories of generators:

  • Conditionally-Exempt Small Quantity Generators (CESQG) who generate less than 100 kg of non-acute hazardous waste a month, less than 1 kg of acute hazardous waste a month (e.g. p-listed wastes such as epinephrine) and less than 100 kg of residues or contaminated soil, waste, and other debris from the spill cleanup of acute hazardous waste;
  • Small Quantity Generators (SQG) who generate between 100 kg and 1,000 kg of non-acute hazardous waste a month, less than 1 kg of acute hazardous waste a month, and less than 100 kg of spill residue from acute hazardous waste; and
  • Large Quantity Generators (LQG) who generate 1,000 kg or more of non-acute hazardous waste a month, 1 kg or more of acute hazardous waste a month, and 100 kg or more of spill residue from acute hazardous waste.

[It should be noted that some states do not recognize the CESQG category (e.g., California, Minnesota, and Rhode Island). As a result, in those states, dental offices would be regulated as a small quantity generator (SQG). An SQG must meet additional requirements related to tracking of and accountability for the waste. Further, some states have a CESQG category, but they require CESQGs to follow some of the SQG requirements, such as obtaining an EPA identification number, or complying with storage standards (e.g., Illinois, Louisiana, Maine, West Virginia, Vermont). You can investigate your state requirements using the HERC Hazardous Waste State Locator. This locator will provide an overview of your state rules, specific information for CESQGs, links to guidance documents and a point of contact at your state environmental agency.]

As you may expect, the rules for the three categories vary with increasingly more stringent requirements for the larger generators. Nearly all dental offices meet the definition of conditionally exempt small quantity generators (an exception might be a dental office that is associated with a larger facility, such as a university).

CESQGs often mistakenly assume that because they are conditionally exempt their hazardous wastes are not subject to regulation. This is not entirely correct. The hazardous wastes generated by a CESQG are still considered hazardous wastes. They are not excluded from regulation, but are subject to the reduced (exempted) management requirements applicable to CESQGs. The following summary should assist CESQGs in maintaining compliance with RCRA hazardous waste rules and maintaining their status as CESQGs.

1. Identify hazardous waste generated by your business. Any solid waste (which may be a solid, sludge, liquid, or contained gas; and is any spent, used, discarded, abandoned, or no longer useable material) generated by your business must be evaluated to determine if it is a hazardous waste, either listed or by a hazardous waste characteristic. For more information, see: HERC's Hazardous Waste Determination.

2. Accumulate hazardous waste in containers or tanks. For CESQGs the accumulation tanks or containers are not specifically required to be marked with the words "Hazardous Waste" or dated like they must be for other Generator categories, but identifying the contents by marking the containers is strongly recommended as a good management practice. If the containers are not marked, the inspectors are more likely to ask you many questions about the contents, and identification may require costly analysis. You should NOT place incompatible wastes in the same container. However, similar materials can be collected in the same container if they will not cause a reaction, fire, evolution of a gas, etc. If wastes are mixed, all listed and characteristic hazardous waste codes must be included in the waste description. The container must be kept closed except when adding or removing wastes. The waste must be maintained in such a manner that it prevents a release of hazardous waste to the environment or endangers human health. A CESQG may not accumulate hazardous waste in units other than tanks or containers.

3. Ship or deliver your hazardous wastes to an approved facility. CESQGs may either:

  • deliver their own waste in their own vehicles to an approved facility, or
  • have a permitted hazardous waste transporter deliver it to:
  • a permitted hazardous waste management facility; or
  • a permitted, registered, or licensed municipal or industrial solid waste facility that is authorized to accept hazardous waste; or
  • a facility which beneficially uses or reuses, or legitimately recycles or reclaims the waste; or
  • a facility which treats the waste prior to beneficial use or reuse, or legitimate recycling or reclamation.

Most state regulations require CESQGs to have written permission for disposal of a hazardous waste in a landfill from the landfill operator and from the state environmental agency before such disposal is allowable. In many states there are no municipal solid waste landfills accepting CESQG waste for disposal.

4. Registration, manifests and recordkeeping. CESQGs are not required to have an EPA ID number or use the Uniform Hazardous Waste Manifest when shipping waste offsite. There is no time limit on how long CESQGs may accumulate hazardous waste. However, they may never exceed the 1,000 kg maximum quantity limit, and the waste must be maintained in such a manner that it does not endanger human health nor release hazardous constituents to the environment. It is recommended that CESQGs maintain records demonstrating that they have properly disposed of their wastes, which may include manifests, billing records, certificates of disposal, or other documentation from their hazardous waste disposal contractor.

More Information

Specific dental office wastes, which are potentially hazardous, and are covered in HERC's dental section include:

For a more detailed discussion of hazardous waste regulations, see HERC’s Hazardous Waste section.

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