VERMONT DEPARTMENT OF ENVIRONMENTAL CONSERVATION
BEST MANAGEMENT PRACTICES FOR DENTAL AMALGAM AND OTHER WASTES
Under Vermont law, dental offices are required to follow environmental “best management practices”
developed by the Vermont Department of Environmental Conservation for amalgam, elemental mercury, and other common hazardous wastes. In addition, all dental practices except for orthodontists, periodontists, endodontists, oral and maxillofacial surgeons, and any other dental practice that does not place or remove amalgam, are required to install amalgam separators no later than January 1, 2007.
This certification form, which provides the best management practices in a checklist format, must be completed by Vermont dental practices and filed with the Department of Environmental Conservation by January 31, 2007, and every other year thereafter (i.e., January 31, 2009, 2011, 2013, etc).
Resource materials are available on-line at www.mercvt.org (under the Dental section) to assist in
complying with these best management practices. In particular, dental practices are encouraged to reference The Environmentally Responsible Dental Office: A Guide to Proper Waste Management in Dental Offices, which can be accessed through this web site.
Note: Note: New dental practices or relocated practices must file this certification form
Withi within 30 days of startup.
HOW TO USE THIS FORM
To complete this form, each dental practice, by location, should respond to each question and provide the additional information requested. If you can answer “Yes” to all of the questions, then your
practice is following best management practices. A “No” response generally indicates that a best
management practice is not being followed. If you answer “No” or “NA” (not applicable) to any
question, please provide a brief written explanation below each question that describes why the management practice was not met, and any corrective action that will be taken, or why the management practice is not applicable.
We suggest that you save the certification form on your computer. You can complete the form on your computer screen, then print and sign. Alternatively, you can print out the blank form and complete by hand.
COMPLIANCE WITH BEST MANAGEMENT PRACTICES
The Department will review self-certification forms that are submitted and will follow up with any incomplete forms submitted or non-filers. Periodic field visits will be conducted to verify compliance with BMPs and amalgam separator installation and operation. A high priority for field visits will be practices that have not filed self-certification forms.
If you need assistance in completing the form or complying with these best management practices, please contact the Environmental Assistance Office at 800-974-9559.
After completing the questions and signing the certification statement return the form by mail to:
Environmental Assistance Office (Dental)
103 South Main Street – The Cannery
Waterbury, VT 05671-4911
DENTAL BEST MANAGEMENT PRACTICES
PART 1: AMALGAM WASTES
General Instructions: Place a check or “X” in the box for each question that indicates whether the best management is being followed (Yes), not being followed (No), or is not applicable to the practice (NA). If you answer “No” or “NA” to any best management practice, please explain in the space provided below each numbered item. If there are multiple sites for a dental practice, please complete one form per location.
Terms Related to Amalgam Wastes:
; Non-contact amalgam (scrap) is excess amalgam mix remaining at the end of a dental
procedure. Many recyclers will buy this clean scrap.
; Contact amalgam is amalgam that has been in contact with a patient. Examples are extracted
teeth with amalgam restorations, carving scrap collected at chairside, and amalgam captured by
chairside traps, filters, or screens.
; Chairside traps capture amalgam waste during amalgam placement or removal procedures
(traps from hygiene chairs generally do not contain amalgam).
; Vacuum pump filters or traps on wet seal vacuum systems (those using water) contain
amalgam. Some recyclers will accept whole filters, while others may require special handling
of this material.
; Amalgam capsules are the individually dosed containers of pre-capsulated dental amalgam.
After use, the capsules may contain residual amalgam.
Best Management Practices for Amalgam Wastes
1. Yes No NA All elemental mercury (free, bulk, or raw mercury) has
been removed from the premises and sent for recycling. Comments:
2. Yes No NA This practice recycles and intends to continue recycling
all amalgam waste from this location, including amalgam
from the separator(s), any amalgam scrap from screens,
traps, or filters, and any scrap amalgam not fully used in
Note: Use of dental amalgam by Vermont dental practices has been decreasing.
When appropriate, use of alternative restorative materials to dental amalgam
will reduce amalgam wastes and potential impact on the environment.
3. Provide the names and addresses of the recycling facility (ies) used by your practice to
recycle its amalgam wastes.
4. Yes No NA The instructions provided by the amalgam recycler are
followed for the packaging, labeling, storage, disinfection
(if required), and pickup or shipping of amalgam waste. Comments:
5. Yes No NA If any elemental mercury is present in the dental office,
including mercury from historical use and mercury in any
medical instruments, such as thermometers, a mercury
spill kit is maintained on site and all appropriate staff
trained in its use.
6. Yes No NA These practices are followed:
; Amalgam is not placed in a sharps container
; Amalgam is not placed in a red biohazard bag
; Amalgam is not discarded in the regular trash
; Amalgam is not disposed down the drain
; Excess amalgam is not removed from an amalgam well using a high-speed suction
; Extracted teeth with amalgam restorations are not placed in a red biohazard bag, but are
recycled with other amalgam wastes in a disinfectant solution (such as glutaraldehyde
or formalin), or as directed by the recycler.
; Used amalgam capsules are not placed in the regular trash but are recycled with other
Disposable Chairside Traps (check NA and proceed to next question if only reusable traps are used)
7. Yes No NA Disposable chairside traps are placed into a container for
recycling as directed by the recycler.
Notes: Traps that are visibly clean can be put in the regular trash or reused.
Reusable Chairside Traps (check NA if only disposable traps are used)
8. Yes No NA All visible amalgam is removed from reusable traps by
tapping the contents into a container for recycling as
directed by the recycler.
Notes: Non-amalgam fragments such as cement may be removed from the trap with
forceps and discarded in the regular trash.
9. Yes No NA Reusable traps are not rinsed under running water (as this
could result in amalgam being discharged down the
Vacuum Pump Filters
Vacuum pump filters are only present on wet seal pumps that use water. Check “NA” on the
following question if you have a dry seal pump.
10. Yes No NA Filters are changed according to the vacuum pump
manufacturer’s recommended schedule and recycled as
directed by the recycler.
11. Yes No NA Only pH neutral, non-bleach, non-chlorine-containing
suction line cleaners are used.
12. Yes No NA Lines are cleaned daily on chairs where restorative
dentistry is performed and as necessary or according to
the vacuum pump manufacturer’s recommendations on
Note: Regular line cleaning will help ensure that amalgam separators function
Sink Traps and Plumbing
13. Yes No NA All under-sink drains that may have received amalgam or
mercury in the past have been cleaned since the
implementation of best management practices, and any
amalgam or elemental mercury discovered in those traps
was removed and sent for recycling.
14. Yes No NA When changing or cleaning pipes or performing any
plumbing maintenance, the dental practice will inspect for
the presence of residual mercury and amalgam. If
mercury or amalgam is present, it will be removed and
PART 2: AMALGAM SEPARATORS
Best Management Practices for Amalgam Separators
By January 1, 2007, amalgam separators must be installed in all Vermont dental practices except for orthodontists, periodontists, endodontists, oral and maxillofacial surgeons, and any other dental practice that does not place or remove amalgam.
Newly installed amalgam separators must be certified to the ISO 11143 standard for amalgam separators (the Vermont Department of Environmental Conservation maintains a list of certified amalgam separators).
In the event that a dental practice installed an amalgam separator prior to January 1, 2006,
and that separator is not on the list of certified amalgam separators, the practice may continue to use that separator for compliance with these best management practices unless, in the opinion of the Department, the amalgam separator is not capable of achieving amalgam removal efficiencies equivalent to certified separators.
15. Yes No NA This practice has installed an amalgam separator to
service all of its dental chairs where amalgam is placed or
This practice discharges wastewater to: a municipal sewer system a septic system
Provide the name of the manufacturer and model of the amalgam separator(s) installed.
(If installed prior to January 1, 2006, an estimate of the installation date may be used)
Model: Provide the date of installation:
16. Yes No NA This practice maintains and operates its amalgam
separator(s) according to the manufacturer’s instructions
(i.e., necessary cleanings, cartridge changes, and other
required servicing are performed on schedule).
Who maintains your amalgam separator(s)?
This practice (proceed to next question) and/or A service provider (specify below)
Service Provider Name:
Service Provider Address:
17. Yes No NA Visual inspections of the separator(s) are conducted at
least weekly and an inspection log is maintained.
Note: An inspection log should identify the date of inspection, the initials of the
individual performing the inspection, any maintenance performed, and
observations/comments. (See sample log at the end of this document. You
can download an inspection log for you use at:
18. Yes No NA Records related to the amalgam separator(s) (e.g.,
installation information, inspection logs, and amalgam
shipping records) are maintained for at least three years. Comments:
PART 3: CONDITIONALLY EXEMPT HAZARDOUS WASTES
Best Management Practices for Conditionally Exempt Hazardous Wastes
Certain wastes generated by Vermont dental practices are regulated as hazardous wastes. The
wastes identified in this section are exempt from regulation as hazardous provided specific
conditions are met. For more information about the hazardous waste regulations that apply to
Vermont small businesses, refer to the Conditionally Exempt Generators’ Handbook which is
available on-line at:
19. Yes No NA This practice has evaluated all of the wastes that it
generates and determined which, if any, are regulated as
Note: Note: Typical hazardous wastes generated by dental practices include the following:
- amalgam (contain mercury and silver);
- lead foils and other lead-containing wastes; and
- photographic fixer and film (contain silver)
- universal waste: fluorescent lamps, mercury-containing devices, cathode ray
tubes (TVs, monitors)
20. Yes No NA Conditionally exempt and regulated hazardous wastes are
not disposed of in the trash or down the drain.
Used X-Ray Fixer Solution
21. Yes No NA Used x-ray fixer solution is:
; Sent to a silver recovery facility that is authorized to accept and recycle this waste in the
receiving state; or
; Sent off-site for recycling using a permitted hazardous waste transporter; or
; Reclaimed on-site using a silver recovery unit (see Note below); or
; Recycled through a municipal hazardous waste collection program.
Note: Wastewater treated by a silver recovery unit may be discharged into the
municipal wastewater treatment plant unless prohibited by the municipality. Dental
practices connected to an on-site septic system should not discharge treated wastewater
from silver recovery to that system. Consider bringing this waste to a municipal
hazardous waste collection program.
Used X-Ray Developer and Cleaners
Notes: Used x-ray developer, if not mixed with x-ray fixer, may be discharged to the
municipal wastewater treatment plant unless prohibited by the municipality.
Used developer should not be discharged to a septic system. Consider
bringing this waste to a municipal hazardous waste collection program.
22. Yes No NA Waste x-ray developer is not mixed with x-ray fixer
23. Yes No NA Non-chromium containing cleaners are used to maintain
the x-ray developer system.
Lead Foils, Shields, and Aprons
24. Yes No NA Lead foils, shields, and aprons are sent for recycling and
are not disposed of in the regular trash or red biohazard
UNIVERSAL HAZARDOUS WASTES
Universal wastes are common hazardous wastes (e.g., batteries, lamps, mercury-containing
devices, and cathode ray tubes) that can be managed according to streamlined management
requirements in lieu of the full hazardous waste regulations. Refer to the Universal Waste Fact
Sheet for more information about universal waste. (Available on the web at www.anr.state.vt.us/dec/wastediv/rcra/pubs.htm)
Note Note: Universal wastes should be recycled. One option is to recycle these wastes
through a municipal hazardous waste collection program.
Fluorescent Bulbs and Lamps
25. Yes No NA Spent fluorescents are recycled, and not disposed in the
regular trash, nor are they intentionally broken or crushed. Comments:
26. Yes No NA Spent fluorescents lamps are stored in a closed,
structurally sound container labeled with the words
“Universal Waste – Lamps.”