The alphabet soup of regulatory compliance

Dentists often refer to infection control information as “OSHA” information. OSHA was, in fact, responsible for some of the earliest standards for the dental workplace. OSHA’s mission is the protection of the employee and its standards reflect that emphasis. Although OSHA now plays a vital role in infection control in dentistry, it is not the only agency with an interest in infection control.

The Centers for Disease Control and Prevention (CDC), for example, have a broader mandate: the CDC is concerned with safeguarding the public’s health. Obviously, this mandate is not confined to employees of dentists, but includes dentists, staff members, patients, and the public-at-large. Within the CDC is the National Institute for Occupational Safety and Health (NIOSH). Both NIOSH and OSHA were created by the Occupational Safety and Health Act of 1970. OSHA is charged with the development and enforcement of workplace safety and health regulations; NIOSH is responsible for improving workplace safety through research, education, and training in occupational safety and health.

Other agencies have some regulatory oversight of or interest in the dental health care industry, including the Environmental Protection Agency (EPA), which has an interest in hazardous waste and drinking water standards (which have been applied to dental unit waterline effluent lately). State and local public health authorities often have regulations that are more stringent than the federal standards. The more stringent standards take precedence over federal standards in that case. For that reason, the practitioner should always consult with local and state authorities to determine the applicable regulations for their jurisdiction.

All of the above-mentioned federal agencies have Web sites that are well-organized and informative. (Web sites include: www.osha.gov ; www.cdc.gov ; and www.epa.gov .) These Web sites have search features; most of the Web sites have publications or position papers on various topics that can be downloaded at no charge. These Web sites should be consulted as one of the first strategies when seeking information regarding regulatory compliance issues.

The American Dental Association (ADA) is also a good source of reliable information, as are many state and local dental societies. The ADA publishes a Regulatory Compliance Manual which is updated frequently . The manual is a good, comprehensive reference and it is highly recommended.

Amalgam waste

The presence of mercury in amalgam has made it a source of concern for those charged with reducing mercury in the environment. Amalgam waste can be separated into contact and noncontact waste . Contact waste is that amalgam waste that has been in contact with a patient’s blood or body fluids. This would include amalgam that is in extracted teeth, plus that which is removed during restorative procedures. Noncontact waste has not been in a patient’s mouth or exposed to blood or OPIM. Amalgam recyclers may treat these types of waste separately (and some may refuse to accept contact waste). It is prudent, therefore, to keep these wastes separated in the office.

The mercury found in amalgam is in a bound form. The environmental threat posed by such material is not entirely clear because the mercury is in a more inert form than some other sources of mercury. Nevertheless, there is legitimate concern that the improper disposal of amalgam may add to the overall mercury burden of the environment. Environmental mercury may eventually accumulate in fish that are then consumed by animals or humans.

Some of the environmental mercury burden is due to the release of mercury vapor. This will happen when amalgam is heated. For this reason, amalgam scrap and amalgam-containing extracted teeth should never be placed in sharps containers or in biohazard bags that are to be incinerated. Instead, all amalgam (including that found in extracted teeth) should be recycled. This includes amalgam scrap from evacuator traps and empty amalgam capsules. Although bulk mercury dispensers were formerly used by dentists, the ADA strongly recommends that bulk mercury dispensers be avoided in favor of precapsulated amalgam alloys.

A special concern may exist when plumbing work is needed in the dental office. Amalgam may be found in drainpipes and traps. Although this is considered to be largely inert and immobile, particles may dislodged by demolition or plumbing work. The ADA has published guidelines to aid in dealing with this potential problem .

A number of companies provide amalgam recycling services. It is important to pick a stable company with a good reputation. There are many laws governing the disposal of hazardous substances. It is incumbent upon the recycler to comply with these statutes and to indemnify the customer for the recycler’s errors or omissions. The regulation of hazardous wastes involves “cradle-to-grave” responsibility that was established by the extensive and complex provisions of the Resource Conservation and Recovery Act (RCRA). The regulations are focused primarily on the prevention of pollution and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). They emphasize corrective, retrospective action such as cleanup of contaminated sites .

Silver waste

Silver waste is found in spent processing solutions in the form of silver thiosulfate complexes. Silver waste is regulated at the state and local level. Many municipalities and state governments have enacted regulations governing the disposal of this material because it often ends up in wastewater effluent. As in most other areas of regulatory compliance, the practitioner must determine the applicable local regulations and act accordingly. There are a number of options for recycling of spent solution, including the use of a commercial recycling service to pick up the used fixer.

Lead foil

Lead foil is used in many types of dental radiographic film. Lead is considered a hazardous material and should be recycled, rather than disposed of in regular waste . With the increasing use of digital radiography, the significance of lead and silver waste in dentistry will diminish.

Volatile organic solvents and other materials

Biopsy containers must be kept tightly sealed, as they usually contain formalin or some other toxic tissue preservative. The containers must be clearly marked with the universal biohazard symbol, but they should also be labeled as to chemical content. If such containers are kept in the office, it will be necessary to have Material Safety Data Sheets (MSDSs) for the fixative used. Other potentially hazardous organic chemicals include methyl methacrylate monomer. This, and similar, materials will require special handling and disposal.

Amalgam waste

The presence of mercury in amalgam has made it a source of concern for those charged with reducing mercury in the environment. Amalgam waste can be separated into contact and noncontact waste . Contact waste is that amalgam waste that has been in contact with a patient’s blood or body fluids. This would include amalgam that is in extracted teeth, plus that which is removed during restorative procedures. Noncontact waste has not been in a patient’s mouth or exposed to blood or OPIM. Amalgam recyclers may treat these types of waste separately (and some may refuse to accept contact waste). It is prudent, therefore, to keep these wastes separated in the office.

The mercury found in amalgam is in a bound form. The environmental threat posed by such material is not entirely clear because the mercury is in a more inert form than some other sources of mercury. Nevertheless, there is legitimate concern that the improper disposal of amalgam may add to the overall mercury burden of the environment. Environmental mercury may eventually accumulate in fish that are then consumed by animals or humans.

Some of the environmental mercury burden is due to the release of mercury vapor. This will happen when amalgam is heated. For this reason, amalgam scrap and amalgam-containing extracted teeth should never be placed in sharps containers or in biohazard bags that are to be incinerated. Instead, all amalgam (including that found in extracted teeth) should be recycled. This includes amalgam scrap from evacuator traps and empty amalgam capsules. Although bulk mercury dispensers were formerly used by dentists, the ADA strongly recommends that bulk mercury dispensers be avoided in favor of precapsulated amalgam alloys.

A special concern may exist when plumbing work is needed in the dental office. Amalgam may be found in drainpipes and traps. Although this is considered to be largely inert and immobile, particles may dislodged by demolition or plumbing work. The ADA has published guidelines to aid in dealing with this potential problem .

A number of companies provide amalgam recycling services. It is important to pick a stable company with a good reputation. There are many laws governing the disposal of hazardous substances. It is incumbent upon the recycler to comply with these statutes and to indemnify the customer for the recycler’s errors or omissions. The regulation of hazardous wastes involves “cradle-to-grave” responsibility that was established by the extensive and complex provisions of the Resource Conservation and Recovery Act (RCRA). The regulations are focused primarily on the prevention of pollution and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). They emphasize corrective, retrospective action such as cleanup of contaminated sites .

Silver waste

Silver waste is found in spent processing solutions in the form of silver thiosulfate complexes. Silver waste is regulated at the state and local level. Many municipalities and state governments have enacted regulations governing the disposal of this material because it often ends up in wastewater effluent. As in most other areas of regulatory compliance, the practitioner must determine the applicable local regulations and act accordingly. There are a number of options for recycling of spent solution, including the use of a commercial recycling service to pick up the used fixer.

Lead foil

Lead foil is used in many types of dental radiographic film. Lead is considered a hazardous material and should be recycled, rather than disposed of in regular waste . With the increasing use of digital radiography, the significance of lead and silver waste in dentistry will diminish.

Volatile organic solvents and other materials

Biopsy containers must be kept tightly sealed, as they usually contain formalin or some other toxic tissue preservative. The containers must be clearly marked with the universal biohazard symbol, but they should also be labeled as to chemical content. If such containers are kept in the office, it will be necessary to have Material Safety Data Sheets (MSDSs) for the fixative used. Other potentially hazardous organic chemicals include methyl methacrylate monomer. This, and similar, materials will require special handling and disposal.