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TABLE OF CONTENTS Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Managing wastes to prevent pollution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Amalgam management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Fixer management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Off-site disposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . On-site treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Choosing a waste hauler or recycler . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . City of Boulder wastewater discharge limits . . . . . . . . . . . . . . . . . . . . . . . . . . List of contacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Inserts Dental waste recyclers Colorado Department of Public Health and Environment hazardous waste compliance bulletin for photographic, x-ray and dental wastes. 1 2 3 4 4 4 5 5 6

treats waste water from households, industries, institutions and commercial businesses. The plants treatment processes remove solids and organic materials from the incoming wastewater. Treated wastewater is discharged to Boulder Creek. The solids that settle out of the wastewater, called biosolids, are treated and used for improving farmland soil. To protect Boulder Creeks sensitive ecosystem and maintain biosolids quality, wastewater must meet stringent water quality standards for numerous pollutants, many of which cannot be completely removed by the Citys treatment plant. Metals are of specific concern because they are n degraded but instead settle out into either the biosolids or pass through the plants processes int Boulder Creek.

INTRODUCTION The City of Boulders Industrial Pretreatment program has prepared this brochure to provide the dental community with guidelines on choosing environmentally friendly products, recycling metal-bearing wastes, and correctly disposing of waste materials. Through pollution prevention, dental practices can reduce the regulatory requirements associated with wastes such as used x-ray fixer, amalgam, and chromium x-ray cleaners.






Pollution prevention measures include employee training, product substitution, improved housekeeping practices, chemical inventory control and the recycling of metal wastes. When implementing a pollution prevention strategy, you should consider the potential for inadvertently transferring pollutants from one waste stream to another. For example, mercury is very persistent in the environment. Chair side traps are beneficial in preventing amalgam from going down the drain which could otherwise contribute to wastewater pollution. However, if the recovered amalgam is disposed of in the trash or as biohazardous waste, the mercury disposal problem is not resolved, it is just being transferred to another waste stream. The good news is that both mercury from amalgam and silver from used x-ray fixer can be recycled. Recycling these resources is not only the environmentally correct thing to do, but may also alleviate some of the requirements associated with disposing of these wastes. The City of Boulder, like many municipalities, has limitations on concentrations of pollutants such as metals, discharged to the wastewater system. These limits are designed to protect the quality of treated wastewater discharged to Boulder Creek and maintain biosolids quality. Refer to page 5 for a list of the City of Boulders wastewater discharge limits. The State of Colorado oversees hazardous waste generators, ensuring environmentally correct management and disposal of hazardous waste. For more information on Colorados hazardous waste requirements refer to Insert 2. Other pollution prevention measures you might want to consider to improve both the quality of your workplace and the environment include: l Using precapsulated dental amalgam; l Using disinfectants containing less-hazardous materials such as quaternary amines; l Discontinuing the use of x-ray developer cleaning products that contain chrome; l Researching and purchasing new technologies such as filmless radiography and; l Advocating pollution prevention among the employees. Below is a chart that lists several types of waste generated by dental clinics along with environmentally correct disposal options. WASTE TYPE Amalgam particles Waste or bulk mercury Empty amalgam capsules Fixer SOURCE Traps, screens, excess mix Spills, spill cleanup Precapsulated amalgam use X-ray process OPTION 1) Send to a recycler. 2) Dispose of as a hazardous waste. 1) Send to a recycler. 2) Dispose of as a hazardous waste. 1) Dispose in trash. 1) Take off-site for recycling. 2) Treat before discharge to sewer. 3) Dispose of as hazardous waste. 1) Discharge to sewer. I) Switch to nonchrome containing cleaner which can be discharged to sanitary sewer. 2) Dispose of as hazardous waste. 3) Use mechanical methods (brush and elbow grease) instead of chemicals. 1) Discharge to sewer. 2) Use disinfectants containing lesshazardous materials such as quaternary amines. 1) Send to metal reclaimer. 2) Dispose of as hazardous waste. Check the Material Safety Data Sheet to see if the x-ray cleaner you use contains chrome. If it does call your supplier and ask for an alternative that does not contain chrome.

Store all hazardous waste in closed containers. Make sure the containers are appropriate for the waste being stored (plastic containers for fixer and amalgam waste). Liquid hazardous wastes should be stored on an impermeable surface in a secure area without floor drains.

Developer X-ray system cleaners that contain chrome

X-ray process X-ray process

Disinfectants with less than 4% glutaraldehyde Disinfectants with low concentrations of formaldehyde Lead foils and shields

Equipment cleaning

X-ray processing protective shields



Amalgam waste should never be discarded in the red bag or infectious waste collection. Biohazardous waste can be incinerated. When amalgam waste is incinerated, the mercury is released into the environment in the incinerators air emissions. Mercury, though bound in the amalgam, can be recovered. Amalgams are made up of about 50 percent mercury and some portion of silver, tin, copper and, in some cases, other metals, such as zinc, palladium or indium. The inserted list identifies businesses providing amalgam waste management services and off-site recycling services. Some recyclers may give you a refund or credit for the recovered mercury. Amalgam waste should never be put in with the infectious (red bag) waste. Best Management Practices for Amalgam Management 1. Never flush amalgam down the drain. 2. Make sure your office has a mercury spill kit. 3. Use precapsulated alloys. Avoid using elemental mercury. 4. Collect empty capsules in a covered container and dispose with solid waste. 5. Retrieve excess amalgam during placement with gauze. Larger particles should be recycled and gauzes placed in solid waste (which is not incinerated). Recover amalgam from instruments prior to washing. The material used to wipe the instruments should also be disposed of as solid waste. 6. Change amalgam traps at least once a week or more frequently if your practice warrants it. Flush the lines at the end of the day and change the traps first thing the following morning. Only traps on chairs used for amalgam placement or removal need special handling. Place traps from chairs dedicated to hygiene in the regular solid waste. 7. Use disposable traps instead of reusable traps because of the difficulty in effectively removing amalgam particles from the trap without discharging the amalgam into the drains or garbage. 8. Secondary filters in vacuum systems should be changed once a month or more frequently, if needed, according to the manufacturers specifications. 9. Amalgam, traps and filters should be either shipped to a recycler or collected by a hazardous waste hauler. You might consider separating contact amalgam (amalgam that has been in the patients mouth) from noncontact amalgam. Recyclers may offer a refund or credit for noncontact amalgam. Keep the recycling and disposal documentation for at least three years. 10. Store waste amalgam in a designated airtight container. Label the container Mercury Amalgam: Recyclable Scrap Metal or equivalent. Include the name, address and phone number of your office and the date that accumulation started. Recyclers will be able to provide their own shipping and disinfection guidelines. In the past, dental amalgam scrap may have been kept under photographic fixer, water or other liquid. If you have been using this method, do not pour the liquid down the drain. Contact your mercury recycler or a hazardous waste hauler for more information on how to dispose of this solution. 11. Explore the latest wastewater treatment technologies. Certain manufacturers sell an amalgam separator which recovers very fine particles that may wash through the standard trap.

Never rinse amalgam traps over drains or discard in garbage.

FIXER MANAGEMENT Silver recovered from used fixer is a valuable resource. Your office can practice silver recovery by containing used fixer for off-site recycling or treating the fixer on-site with a silver recovery unit. The Dental Waste Recycler insert identifies businesses providing both on- and off-site recovery services. Some recyclers may give you a refund or credit for the recovered silver. If your practice generates only small quantities of fixer, it may be more cost-effective and efficient to have the fixer transported off-site for silver removal. By opting for off-site disposal, you are guaranteed 100% recovery of silver in x-ray fixer. By using radiovisography imaging technology, you may be able to reduce or eliminate fixer use altogether. OFF-SITE DISPOSAL Several local vendors offer fixer pick-up services. Some x-ray chemical vendors will transport used fixer to their facility, remove the silver and blend the spent fixer with new fixer for reuse. Other companies will transport used fixer to a centralized recovery facility for silver reclamation. When storing fixer for off-site treatment or disposal, remember to: 1. Collect and store the fixer in a closed plastic container. 2. Label the container Hazardous waste - used fixer along with the date when fixer was first added to the container. 3. Keep records of the volume and frequency of off-site fixer disposal for a minimum of three years. Treated fixer ON-SITE TREATMENT You can purchase or lease a silver recovery unit to remove silver from spent fixer. Canister units are usually sufficient for removing silver from small volumes of fixer and can be used alone or in series. Electrolytic units also are available and can be followed by a canister to ensure as much silver as possible is recovered. Talk with a silver recovery service about what will work best for your practice. After a specified interval, the canister or the plated silver is shipped to a metal reclaimer where the captured silver is recovered. As a general guideline, the Silver Council, an industry trade group, recommends that a business producing less than 10 gallons of used fixer per week should have a recovery unit capable of removing at least 90 percent of silver from the fixer. The treated fixer can be discharged to the drain with permission from the City of Boulder Industrial Pretreatment program. If your office uses a silver recovery unit, remember to: 1. Check the unit daily for leaks, spills and overflows. 2. 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. 3. 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 users guide for specific guidance. 4. 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. 5. Record test results in a silver recovery log. can be discharged to the drain with permission from the City of Boulder Industrial Pretreatment program, 413-7350.

Floor drains in photoprocessing rooms should be isolated using stand pipes, plugs or covers.

CHOOSING A WASTE HAULER OR RECYCLER Here are some issues to consider when choosing a waste hauler or recycler. l Will the hauler recover the silver from fixer solutions and mercury from amalgam? To receive your EPA identification number, which is recorded on hazardous waste manifests, call the state at (303) 692-3300. However, Conditionally Exempt Small Quantity Generators (CESQGs) are not required to obtain EPA identification numbers. CESQGs can instead write CESQG in the space on the manifest designated for the EPA identification number. In fact, having a separate identification number may hinder dentists who share clinic space from commingling their like wastes. CITY OF BOULDER SPECIFIC POLLUTANT LIMITATIONS METALS Arsenic Cadmium Chromium VI (grab sample only) Chromium Total Copper Lead Mercury Molybdenum Nickel Selenium Silver Zinc DAILY MAXIMUM (Milligrams/Liter) 0.10 0.10 0.42 5.25 1.2 0.7 0.007 0.09 0.65 0.16 0.10 5.4 l What is the basis of frequency for waste pickup? l Will you receive a credit or refund for the recovered silver and mercury? l What is the fate of spent fixer, amalgam or silver recovery units taken or shipped from your office?

l Will the hauler provide certification that waste generated by your office is transported, disposed of, or recycled in accordance with all applicable laws and regulations? l Will the hauler provide containers for holding the waste solution?

PARAMETER LIMITS (STANDARD UNITS) Minimum = 5.5, Maximum = 10.5 pH

LIST OF CONTACTS Wastewater Discharge City of Boulder Industrial Pretreatment Program 4049 N. 75th Street Boulder, CO 80301 (303) 413-7350 Hazardous Waste Management Boulder County Health Department 3450 Broadway Boulder, CO 80304 Environmental Health: Air Quality, Solid & Hazardous Waste (303) 441-1180 State of Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, CO 80222-1530 (303) 692-2000 Hazardous Materials and Waste Division, Customer Technical Assistance Line (303) 692-3320 U.S. Environmental Protection Agency, Region VIII 999 18th Street, Suite 500 Denver, CO 80202-2466 l-800-227-8917 Pollution Prevention The Silver Council 5454 Wisconsin Ave. Chevy Chase, MD 20815 (301) 664-5150 Partners for a Clean Environment (PACE) P.0. Box 791 Boulder, CO 80306 (303) 786-PACE A program of the City of Boulder, Boulder County, Boulder Chamber of Commerce and Boulder Energy Conservation Center. PACE assists local businesses in saving money through environmental efficiency programs. Hazardous Waste Haulers USPCI/ Laidlaw (303) 938-5500 Waste Management of Colorado (303) 797-1600 Hazrad Services, Inc. (303) 456-9224 Drinking Water Cross Connection/Backflow Information City of Boulder Drinking Water Program 5605 N. 63rd Street Boulder CO 80301 (303) 413-7401

Dental Waste Recyclers Silver Recyclers Business Name/Address Contact Name/Phone Off-Site Silver Recovery In-Site Silver Recovery Scrap Film Recycling Comments

Environmental Services Inc. 4026 S. Parker Road Suite 132 Aurora, CO 80014 Merry X-Ray Chemical 1441 W. Bayaud St. Suite 2-A Denver, CO 80223

Sandy Fitzgerald (303)690-1414 Phillip Glass (303)698-1701 X

Contact vendor for details.

Purchase of materials is required to get scrap film picked up and be in the silver recovery program. Contact vendor for details.

Picker International 3250 Quentin Street Suite 120 Aurora, CO 80014 Rocky Mountain Radiographics 9505 N. Tomahawk Road Parker, CO 80134 Safety-Kleen 2801 S. Tejon St. Englewood, CO 80110 S&H Silver Recovery 3060 West 58th Ave. Denver, CO 80221 Silver Recovery Inc. 604 2nd Street Berthoud, CO 80513 Southwest Radiographics 1001 E. 64th Ave. Denver, CO 80229

Debbie Brookham l-800-866-8507 x8307 James Blackbum (303)841-3561 Bryce Powell (303)761-8614

Contact vendor for details. Generator receive credit for high silver solutions.

Verne Neuscheler (303)455-2873 Jerry Olson (970)532-3456 Leisa Bruner X X

T. G. X-Ray Ltd. 5 South Kalamath Street Denver. CO 80223

Amalgam and Mercury Recyclers Business Name/Address Phone Elemental Mercury Advanced Environmental Recycling Corporation 2591 Mitchell Avenue Allentown, PA 18103 Amalgaway 1002 W. Troy Avenue Indianapolis, IN 46225 Bethlehem Apparatus Company PO Box Y Hellertown, PA 18055 Dental Recycling-North America PO Box 1069 Hackensack, NJ 07601 DFG Mercury 909 Pitner Avenue Evanston, IL 60202 Environmental Transloading Services 654 S Myers Street Los Angeles, CA 90023 Mercury Refining Company 1218 Central Avenue Albany, NY 12205 Recyclights 401 West 86th Street Minneapolis, MN 55420 Lead Recyclers* Business Name/Address Phone/Fax Materials Accepted Lead Shields Eastman Kodak Company (8001933-8031 Yes (800) 554-2372 X X X X Materials Accepted Loose Amalgam Amalgam in Traps and Filters Spill Cleanup Materials

(800) 267- 1467 X (610) 838-7034 X (800) 525-3793 X (847) 869-7800 X (800) 777-3363 X (800) 833-3505 X (800) 83l-2852 X X X X X X X X X X X X X X X X X

*Check with local metal recyclers to see if they will accept lead shields. This list in no way implies the City of Boulders endorsement of any particular firm or business. If you know a firm who would like to be added to this list, please have them contact the City of Boulders Industrial Pretreatment program at (303) 413-7350.

Compliance Colorado Department of Public Health and Environment

Bulletin 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) . . . HAZARDOUS WASTES The most common sources of hazardous wastes generated by dental clinics and radiology laboratories include:

. . .

Fixer - contains silver, DO 11 Undiluted developer - corrosive, D002 Lead foil, dental bite wings, discarded lead shields - contain lead, D008 Amalgam - contains silver & mercury, DO 11, D009 Dental trap filter wastes - contain lead, silver, mercury, D008, D009, DO 11 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 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 2.5 gallons) of hazardous waste per calender 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 oh 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. 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 -over-

not required for CESQGs, it is good management practice to label this container with the words Hazardous WasteUsed 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 recyclers 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 100.2 1). 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 arc 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 6 CCR 1007appropriate treatment (25- 15-404 CRS, 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 comment.hmwmd @

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 7/97 CHW-012 regulations. Printed on recycled paper