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Re: Dental Amalgam

Hello Lin,

In regards to your request for information on the classification and management/regulation of dental amalgam, I have the following information.
Ohio EPA does not regulate dental amalgam wastes as a listed hazardous waste.   Ohio considers amalgam from a sink trap  or coarse and vacuum filters connected to a drain discharging into a POTW to be a sludge.   It is our understanding that up to 80% of the dental amalgam is collected in coarse and vacuum filters.  The remaining 20% that is not collected is in particulate or dissolved form and may discharge, via the drain, into a POTW. 

Under Ohio's hazardous waste rules, sludges exhibiting a hazardous waste characteristic that are reclaimed are not a waste.  Therefore, they are not a hazardous wastes.   Ohio EPA considers unused discarded dental amalgam to be a commercial chemical product.   Commercial chemical products exhibiting a hazardous waste characteristic that are reclaimed are not a hazardous waste.   Fragments of used amalgam that are separately collected in a container may meet the definition of scrap metal.   Scrap metal that is reclaimed is not a hazardous waste.

The following web site contains TCLP data on dental amalgam:

[USAF Dental Investigation Service]

Some states may co-regulate dental amalgam as hazardous waste and infectious wastes.

Here is another useful  web site that has information on the disposal of dental amalgam.


I hope this helps.

Art L. Coleman, Jr.
Technical Support Unit
Division of Hazardous Waste Management
Lazarus Government Center
122 South Front Street
Columbus, Ohio 43215


Dear P2 Tech:

NH is one of many states working on reducing mercury and toxics in
healthcare facilities.  One of the issues that we are dealing with is how to
classify and handle dental amalgam waste (for best results in getting the
stuff recycled).  
There seems to be little consistency among states in how waste amalgam is
regulated; some consider it hazardous waste, some solid waste, some
Universal waste, and some ignore the issue entirely. There is also a lack of
analytical data (i.e. will amalgam pass TCLP)? (I realize this may or may
not be a technically appropriate use of TCLP, as we are really worried about
the vaporization of the Hg, but that is what RCRA would use for
classification purposes.) 
Please let me know:
How does your state classify/ handle dental amalgam waste? 
Do you have any TCLP or analytical test results you can share?
Thanks for your time and Happy Holdiays!

Hoping for a white Christmas in NH:
Lin K Hill
603-271-2456 (fax)