Managing Dental Mercury

6NYCRR Subpart 374-4 , Standards for the Management of Elemental Mercury and Dental Amalgam Wastes at Dental Facilities(effective May 12, 2006), requires dental facilities to install dental amalgam separators; recycle dental amalgam waste and elemental mercury; and maintain records on the installed separator and recycled dental amalgam wastes.  

Recycle scrap amalgam through an amalgam recycler. Follow the requirements of your amalgam recycler for the storage, disinfection and shipping of scrap amalgam. Generally, it is recommended to collect and store all contact and non-contact scrap amalgam, capsule waste and extracted teeth with amalgam restorations in separate, appropriately labeled, tightly sealed containers without liquid. 

• Never put scrap amalgam in the sharps container.
• Never put scrap amalgam in the red biohazard bag.
• Never discard scrap amalgam in the trash.
• Never rinse scrap amalgam down the drain.
• Never remove excess amalgam from the amalgam well with the high-speed suction vacuum line.
• Never clean up a mercury spill using a vacuum cleaner.
• Never place extracted teeth with amalgam restorations in the red biohazard bag. They should be placed in a container that is acceptable to your recycler. Precautions, such as glasses, gloves, and mask, should be used when handling extracted teeth.
• Do not use heat. If contact amalgam must be disinfected before shipment to your recycler, do not use any method that utilizes heat. The heat will cause the mercury to volatilize and be released into the environment.
• Do not decant liquid. If you store scrap amalgam under used radiographic fixer, water, or other liquid, do not, under any circumstances, decant the liquid down the drain. Contact your dental amalgam recycler or hazardous waste hauler for more information on how to dispose of this material properly.
• A container cannot be stored by the dental facility for more than one year from the date the waste was initially placed in the container. 

Steps to clean this type of trap are: 

• Open the chair-side dental unit to expose the amalgam trap.
• Remove non-amalgam fragments such as cement from the trap with cotton forceps and discard in the garbage.
• Remove all visible amalgam by tapping the contents into a properly labeled container. Close the cover tightly.
• If the trap is visually clean, it can be reused. A heavily contaminated trap should always be recycled. Store contaminated traps in the properly labeled container. 

• Remove the amalgam trap and place it in a properly labeled container.
• Do not clean disposable traps under running water or discharge the trapped amalgam into the wastewater system. 

• Replace vacuum pump filters regularly as recommended by the equipment manufacturer.
• Remove the filter. While holding it over a tray or other container that can catch spills, decant as much liquid as possible without losing visible amalgam. The decanted, amalgam-free liquid can be rinsed down the drain.
• Put the lid on the filter and place it in the box in which it was originally shipped. When the box is full, the filters must be recycled. Be sure to check with your amalgam recycler to ensure that they will take these filters. 

• The system must be effective. The manufacturer must be able to prove that the system can remove the amalgam from the wastewater regardless of particle size. An amalgam separator placed into service after May 12, 2006 must achieve 99 percent removal efficiency.
• The separator must be properly sized for the volume and flow of the dental facility amalgam wastewater in accordance with the manufacturer's specifications and recommendations. The maximum allowable flow rate through the amalgam separator may not exceed the maximum flow rate capacity that the separator was tested at and passed in meeting International Standards Organization (ISO-11143). Separators should be tested and certified by accredited testing laboratories and certification bodies. For dental facilities with 50 or more chairs, please see 6NYCRR Subpart 374-4.
• Available space for the installation and subsequent access to that space for equipment replacement and maintenance should be considered.
• There should be no compromise in suction power.
• You may want to consider a unit that is hands-off. The dentist or staff should not have to perform a series of manual operations or be required to handle and change filters.
• The captured amalgam must be recycled. Consider a company that both sells the system and arranges for the recycling of the captured amalgam. You should, at minimum, request information from the company that sold you the unit about how to assure that the captured amalgam is recycled.
• Simplicity of design is a plus. There will be fewer chances for something to go wrong.
• The unit should operate quietly.
• The unit should come with a fail-safe mechanism that protects you from a spill or back-up in the event that a blockage occurs.
• The unit should install centrally so that the appropriate wastewater streams pass through it before discharging into the sewer system.
• The unit should be reasonably priced. Obtain information from the companies on both short and long term costs (including maintenance and parts replacement) over a five to ten year period before making a decision. 

In the event that elemental mercury is present in your dental office: 

• Recycle all elemental mercury and dispose of all contaminated materials through a hazardous waste hauler. Many hazardous waste haulers and dental amalgam recyclers will accept elemental mercury for recycling.
• If only a small amount of elemental mercury is to be recycled, it may be possible to initiate a reaction with an amalgam alloy to form scrap amalgam, which must then be recycled through your amalgam recycler. 

Guidelines for managing elemental mercury, mercury waste, or other contaminated items: 

• Never dispose of mercury contaminated waste in the sharps container, as medical waste, or in the trash.
• Never dispose of elemental mercury down the drain, in the sharps container, as medical waste, or in the trash.
• The one year storage provision also applies to dental amalgam waste, such as but not limited to, extracted teeth with dental amalgam restorations, carving scrap, vacuum pump filters and chair-side traps taken out of service, excess dental amalgam mix, and used dental amalgam capsules. 

If cleaning up a mercury spill or a broken mercury-containing product: 

• Put on nitrile gloves. Do not use latex gloves as mercury can penetrate latex.
• Clean up all visible elemental mercury using a mercury spill kit. Mercury spill kits are available from a number of sources including: companies that specialize in Occupational Safety and Health Administration (OSHA) compliance supplies and equipment; amalgam recyclers; and dental product suppliers. Before purchasing a kit, make sure it comes with complete instructions on how to perform a spill clean up. Train several staff members in proper spill clean up procedures.
• Place all contaminated items (materials used during the clean up procedure and broken pieces of glass) in a sealable plastic bag or container. Label the bag or container as “Mercury Waste”.  

Some solid waste planning units (such as in Erie, Monroe, Otsego, Rockland, Oneida-Herkimer and Cayuga Counties) offer elemental mercury recycling programs, which allow dentists to safely manage their elemental mercury. Some will charge a fee for this service. Call your local solid waste district to inquire about such programs. A list of New York State recycling coordinators. 

If you are concerned about the possible uncontained presence of mercury in your dental office due to historical or recent mercury spills, equipment is available for the detection of mercury vapor and mercury spill locations in the workplace environment. This equipment can be rented from rental test equipment companies. 

Mercury from prior dental procedures often settles at low points in the plumbing such as sink traps and sumps. The slow dissolution of the mercury in a sink trap or sump can release mercury into the wastewater for years after past disposal practices have been corrected. When there is a possibility that plumbing repairs or demolition may disturb adhered amalgam waste, dental offices should follow common sense approaches and guidelines to protect the environment and those working in the dental facility. For instance, you should advise your plumber that whenever plumbing parts are removed or cleaned, caution should be taken to avoid spilling the contents in case amalgam or mercury are present. The sludge from the pipes should be poured or brushed out and handled as contact amalgam. The plumbing parts can then be put back in place or recycled. 

Alert renovators to the possibility of historical mercury spills that may have resulted in the presence of mercury in carpets, floor cracks, behind mouldings and other areas where elemental mercury may have been used or where amalgam capsules may have been spilled. 

When a separator is installed at a dental facility, the dental facility provides written notification to the appropriate sewage treatment works or sewer authority where the wastewater is discharged. For dental facilities that begin operations after May 12, 2006, notification must be submitted within 30 days from the date the separator is placed into service. Dental facilities that are on septic systems should complete a form and keep it in their records. 

The notification must include the dental facility name, address, telephone number, type of amalgam separator installed, manufacturer's model number, unit specifications (e.g. ISO 11143 tested flow rate, efficiency), date the unit was placed into service, and the number of chairs serviced by the separator. A copy of Notice of Dental Mercury Separator Installation form (PDF, 35 KB) may be obtained from the Department's website. 

Additionally, dental facilities should be aware of Federal Regulations related to self-certification for dental facilities that do not place amalgam. More information about this may be found at 40 CFR 441.10(f).  

All dental facilities, including specialties that are exempt from installing a separator, must maintain the following written documentation, on an annual basis, from the collection service or recycler for a minimum of three years:  

• the name and address of the collection service; 
• the amount, by weight, of dental amalgam waste and elemental mercury sent for recycling of mercury, and date(s) it was collected; 
• the name and address of the facility where the dental amalgam waste and elemental mercury will ultimately be recycled; and 
• certification that the mercury contained in the waste was destined for recycling. 

A dental facility must keep the following information on file for as long as the separator is in use at the dental facility:  

• type of amalgam separator installed,  
• manufacturer's model number,  
• unit specifications,  
• date the unit was placed in service, and  
• the number of chairs serviced by the separator.  

For a minimum of three years, the dental facility keeps a description and a date of all maintenance performed on a separator.