Dental Office & Amalgam

Our current Pretreatment Ordinance 39 Section 2.7.1 contains specific requirements for Dental Facilities within the District with respect to amalgam waste. Key changes include:

Dental Offices should:

Note that best management practices for dental offices with respect to amalgam handling are required in Ordinance 39-10.

Proper disposal of dental amalgam, which contains up to 50 percent mercury and some silver, zinc, copper, and tin, is a particular concern for preventing the pollution of the San Francisco Bay. Amalgam-containing waste generated at dental offices includes dental amalgam chunks, mixtures containing dental amalgam fines, dental amalgam sludge, extracted teeth with amalgam restorations, and single-use traps and vacuum pump filters that contain dental amalgam.

All amalgam-containing waste can be recycled under the Universal Waste Rule. If not recycled, then it must be disposed of as hazardous waste. The waste should never be rinsed down the drain, thrown in the trash or in medical waste/red bags. Mercury may be released from amalgam if it is incinerated or may leach out if it ends up in wastewater.

What are the requirements for handling amalgam waste under the Universal Waste Rule?

  1. Place amalgam in airtight containers.
  2. Label or mark the airtight containers with one of the following phrases: “Universal Waste-Dental Amalgam”, “Waste Dental Amalgam” or “Scrap Dental Amalgam”.
  3. Maintain a record, in the form of a log, invoice, manifest, bill of lading or other shipping documents for at least 3 years, along with the following information:
    • Name and address of the universal waste handler, destination facility or foreign destination to whom the waste was sent.
    • The quantity of each type of universal waste sent.
    • The date the shipment of universal waste left your facility.
  4. Recycle through Amalgam Waste Disposal Service. For a list of services available in Alameda County, Contact the Alameda County Dental Society at (510) 547-7188.

What if I don’t handle my amalgam waste under the Universal Waste Rule?

If the amalgam waste is not handled under the Universal Waste Rule, then it must be disposed of as a hazardous waste. Some of the requirements for disposal of hazardous waste include:

  1. Obtaining an EPA generator ID number.
  2. Keeping accurate records of hazardous waste management.
  3. Proper labeling and handling instructions that clearly indicate “Hazardous Waste”.
  4. Manifesting, transporting and disposing for accurately tracking the entire process.
  5. Sending the waste to a permitted facility by a certified waste hauler. For information about services available in Alameda County, visit and specifically, the Small Business Hazardous Waste Disposal Services link.

Visit to find a list of hazardous waste disposal sites in our area.