| FAQ - Waste - Archived Through 2012
What is the updated protocol for handling hazard waste spills on floors in the office such as mercury and amalgam? We have a spill kit but want to make sure we are following procedures.
OSAP does not maintain individual state/local regulations/laws and can only provide you with general information.
OSHA's Hazardous Communication Standard 29 CFR 1910.1200 involves hazardous chemicals in the workplace and applies to dentistry. The Standard requires each facility to have a written chemical hygiene plan. The written chemical hygiene plan must be communicated to each employee and provide procedures for evacuation, medical care, incident reporting, and clean up of spills. Thus, dental offices utilizing amalgam are required to have a mercury spill kit available.
Chemical spills should be handled and cleaned-up according to the product's Material Safety Data Sheet (MSDS) and disposed of according to all federal, state, and local laws. As a general rule, a minimum of two types of spill kits should be available to handle chemical spills in a dental setting: 1) general all purpose chemsorb kit and 2) mercury spill kit.
You should contact your state and local EPA agency, State Dental Society/Association, and State Board of Dental Examiners/Licensing Board to inquire about applicable laws in your area. Because elemental mercury may not be poured down the drain or disposed of in waste receptacles, these agencies often maintain a list of qualified waste haulers/recyclers in your area.
With regard to scrap amalgam, again all federal, sate, and local regulations/laws apply with regard to disposal of amalgam waste including empty amalgam capsules.
The American Dental Association (ADA) has revised their recommendations concerning amalgam waste. The ADA's Best Management Practices For Amalgam Waste (March 2004) recommends that disposable amalgam capsules be recycled and not disposed of in biohazard containers, infectious waste containers (red bags) or regular garbage. The ADA offers suggestions that include several steps that can be taken with regard to disposable amalgam capsules. The suggestions may be viewed in the Best Management Practices For Amalgam Waste. (1) (2)
Again, these are only ADA recommendations and all federal, state, and local regulations/laws must be adhered to.
Salvage and store all contact and non-contact scrap amalgam in separate, appropriately labeled, tightly closed containers. (3)
Recycle scrap amalgam through an amalgam recycler. (3)
Follow the requirements of your amalgam recycler for the storage, disinfection and shipping of scrap amalgam. (3)
It is also important to keep in mind that the specific type and number of spill kits that the facility must make available is based on the information provide on the chemical's MSDS. Typically, section VII of the MSDS should include precautions for safe handling and use, including spill and/or leak procedures. This section gives details concerning the use of protective clothing, equipment, and ventilations to be used for cleaning up a spill and safe disposal of the chemical.
Additionally, if you are unable to locate the instructions for the spill kit you should contact the product's manufacturer and obtain replacement instructions.
OSHA provides materials to assist facilities in establishing and writing the required hazardous communication program. The following resources should be useful to you.
1) The Hazardous Communication Standard may be viewed at:
2) OSHA provides model Hazardous Communication Programs and Examples that may be viewed at:http://www.osha.gov/SLTC/hazardcommunications/solutions.html
3) OSHA also provides a great deal of information that explains the hazard communication requirements that may be viewed at:
4) OSHA provides specific information concerning mercury that may be viewed at:
5) OSHA Publications may be obtained and viewed at:
(Publication numbers 3084, 3114, 174, 3187, and 3186 should be most useful).
6) OSHA provides information for dentistry that may be viewed at:
Additional resources that may be useful include the following:
1) The American Dental Association has a great deal of information on management of amalgam waste, including mercury hygiene recommendations that may be viewed at;
The ADA also provides a directory of dental waste recyclers that is available at:
2) OSAP has links to State Agencies at:
3) OSAP's April 2006 issue of Infection Control In Practice: Where Are Your MSDSs?: Vol. 5, No. 3, may also be beneficial to you (available on-line to OSAP members).
4) Cornell University Office of Environmental Health and Safety:
5) Seton Compliance Resource Center:
6) With regard to mercury, silver, and other dental waste disposal, The Environmentally Responsible Dental Office: A Guide to Proper Waste Management in Dental Offices. Northeast Natural Resource Center of the National Wildlife Federation and the Vermont State Dental Society. June 1999, may be viewed at (ADA makes reference to this material):
1) ADA's Best Management Practices For Amalgam Waste:
2) The ADA statement concerning amalgam:
3) The Environmentally Responsible Dental Office: A Guide to Proper Waste Management in Dental Offices. Northeast Natural Resource Center of the National Wildlife Federation and the Vermont State Dental Society. June 1999.