Environmental Regulation of Dental Office Waste Disposal

Regulatory Agencies with Jurisdiction

• DEA – Controlled Substances
• EPA – Hazardous Waste
• MPCA – Hazardous Waste/Waste Water
• County – Controlled Substances/Waste Water

First Steps

• Get an EPA/MPCA Generator ID Number
• A Hazardous Waste ID number can be obtained by filling out a Notification of Regulated Waste Activity Form. This form is available from the MPCA or a metropolitan county hazardous waste office The form is also available on the MPCA Web site at  www.pca.state.mn.us/publications/w-hw7-09.pdf

Type of Generator ID

Most Dental Offices require what is referred to:

• Very Small Quantity Generator License (VSQG) - 220 pounds or less per month of hazardous waste (about 1/2 drum of liquid or less)
• Or A Minimal Generator License

Minimal Generator

• A Minimal Generator ONLY generates:
• Ten gallons or less per year of hazardous waste such as solvent or paint thinner.
• Lead acid batteries.
• Special hazardous wastes including electronics and photographic negatives.
• Universal wastes including lamps, batteries, pesticides and mercury-containing equipment such as thermostats, switches, or thermometers.
• Photographic fixer solution (less than 220 pounds/month) and x-ray film that is shipped off site for recycling.

Inexpensive Disposal Options

• Very Small Quantity Generators (VSQGs) are allowed to deliver their own waste in their own vehicle to a licensed VSQG Collection Program.
• Only transport waste from your own business and in your business vehicle.
• Follow the Department of Transportation requirements for transporting hazardous materials. For example, you must use the correct container, appropriately mark and label containers, use a shipping paper and secure the waste in your vehicle.

Potential Collection Options Include:

Each program determines the waste(s) it will accept, its hours of operation and associated charges.

• Xcel Energy, Mark Anderson, (612) 630-4516
• Special Waste Disposal, Inc, Jim Ciolkosz, (612) 285-9865
• Dakota County Business Hazardous Waste Collection Program (952) 891-7557

Metro Dental Offices

Dental clinics in the Twin Cities metropolitan area may discharge their wastewater to the sanitary sewer under a program developed by the Minnesota Dental Association (MDA) and the Metropolitan Council Environmental Services (MCES) if an approved amalgam separator is appropriately used prior to discharge..

Amalgam Separators

Appropriate use means the separator is maintained according to the manufacturer’s specifications and the flow rate does not exceed the MCES approved rate. A list of approved amalgam separators and their approved flow rates is available.

On-Site Waste Water Disposal
(Septic Systems)

• Regulated by County
• Must be inspected and approved for disposal of materials.
• If not, can be subjected to hazardous waste enforcement by MPCA

What to Do During an Inspection

• Cooperate
• Get Inspectors Name and Make Note of Date of Inspection.  
• You are allowed to go with the Inspector
• Take Pictures as you Go.
• Try to Cooperate but don’t volunteer information.

Enforcement Scenario

• Inspection
• Issue Report of Inspection (Must Request under Data Practices Act)
• Notice of Potential Violation and Penalties
• Negotiations
• Reduction in Penalties and Corrective Measures.