The United States passed many of the current environmental protection laws in the 1970s. In 1976, the US passed the Resource Conservation and Recovery Act, or RCRA. RCRA is one of a handful of environmental statutes that deal with specific types of waste.
Most dentists are aware of laws that require them to properly dispose of biological waste. But did you know that dentists are also subject to RCRA?
Not sure what RCRA is or what it covers? Read on to learn everything you need to know about it and to learn how it comes into play at your dental practice.
The Resource Conservation and Recovery Act is a statute that covers the disposal of hazardous and solid wastes. The Environmental Protection Agency (EPA) is in charge of creating and enforcing the rules for waste control.
RCRA does not cover every single type of waste. It has specific categories for waste covered under this law. These categories include non-hazardous solid waste and hazardous waste.
The ultimate goal of RCRA is to regulate waste disposal in order to prevent contamination of the earth, air, and water.
Non-hazardous solid waste is kind of a misnomer because the waste doesn't actually have to be solid to fall under this category. Solid waste is all garbage or refuse that isn't considered hazardous or that doesn't under an exception.
Common exceptions for solid waste include domestic sewage, irrigation return flow, and radioactive waste. Don't be concerned if something concerning is listed as an exception -- it is likely covered under a different law.
The EPA created two ways to determine whether a certain waste is hazardous. The first is a defined list of hazardous waste. The second is dependent on whether the waste has a characteristic that makes it hazardous.
There are four lists for listed hazardous waste -- F, K, P, and U. The F-list covers wastes from manufacturing and industrial processes. The K-list covers wastes from specific manufacturing entities such as veterinary pharmaceuticals manufacturing.
The P and U lists cover pharmaceutical and toxic chemicals. These include 100 percent pure chemicals, technical grade chemicals, and sole active ingredient chemicals. These lists cover many chemicals that are frequently used in dental offices such as amalgam which contains mercury.
Ignitability means that one characteristic of the waste is that it catches fire under certain conditions. This includes liquids with flash points below 60?C, non-liquids that cause fired under certain conditions, and ignitable compressed gases and oxidizers.
Materials that display corrosive characteristics are also covered under RCRA. These materials generally have a pH that is less than 2 or greater than 12.5. That means that they are likely able to corrode steel.
Reactive wastes are defined as wastes that are unstable under normal conditions. They may react with water or give off toxic gases. They also have the potential to detonate or explode under normal conditions when heated.
Toxic wastes are defined as wastes that are harmful when ingested or absorbed by the body. They are covered because they have the potential to pollute groundwater if not properly disposed of.
Any solid waste that does not fall under an exception must be properly disposed of in order for your dental practice to be in compliance with RCRA. Other specific wastes include dental amalgam, including any chair-side amalgam taps, amalgam filling materials, and extracted teeth that contain amalgam. It also covers lead foil, x-ray film, disinfectants, adhesives, and processing chemicals.
In addition to these items, dental offices must be careful to properly dispose of fluorescent lamps, batteries, and chemical sterilants and disinfectants.
Confused? That's understandable, RCRA is pretty complicated. The EPA website is a great resource for those who want to a better understanding of covered wastes. They even came up with a handy flow-chart to help you decide whether that particular waste is subject to RCRA.
There are three types of generators: large quantity, small quantity, and conditionally exempt small quantity generator.
Large quantity generators produce 2,200 or more pounds of hazardous waste per month. They are subject to very strict RCRA generator regulations. These include obtaining an EPA identification number and limitations on storing waste on site.
Small quantity generators produce between 220 and 2,200 pounds per month of hazardous waste. SQGs are subject to many of the same regulations as LQGs. They don't have to do things like complete a biennial report or complete as much employee training.
Unless you have a very large and busy dental office, you likely fall under the conditionally exempt small quantity generator category. Generators under this category produce no more than about 2 pounds per month of hazardous waste.
CESQG is the least restrictive category. They must identify all hazardous waste generated and make sure to deliver their hazardous waste to an authorized hazardous waste manager.
Hazardous waste must be transported to a permitted treatment, storage, and disposal facility. If cannot transport, then you must have a waste management company retrieve the waste for proper disposal.
You can store hazardous waste on site, but it must be less than 1,000 kg of waste at a time. Be careful not to mix hazardous waste with non-hazardous waste. Mixing causes non-hazardous waste to become hazardous. This can have an impact on your status as a conditionally exempt small quantity generator.
The Resource Conservation and Recovery Act is one of the United States' biggest laws that deals with waste disposal. Compliance with it is not something that should be taken lightly. With a little research and persistence, you'll be well on your way to compliance with RCRA.
Contact us today if you need assistance with the management of your dental waste.