Dental practices are required to dispose of their regulated waste is a responsible manner. These requirements are mandated by both OSHA and by the Texas Commission on Environmental Quality (TCEQ).

There are three different types of regulated waste generated by a dental practice and each has its own requirements. Two of these – disposal of amalgam and of hazardous chemicals – have well defined disposal programs. Dental practices understand the necessity for implementing these programs, as there are direct and harmful environmental impacts.

The third type generally gets less attention. That category is the disposal of regulated medical wastes or infectious wastes associated with patient procedures. These by-products can include blood-soaked gauzes, needles, small amounts of human tissue, or disposable instruments used in dental procedures.

The development of HIV many years ago gave attention to the necessity of protecting medical professionals and patients from inadvertent exposure to needles or other wastes containing Blood Borne Pathogens that had been used on someone else. A whole industry emerged around Sharps containers that capture used syringes and needles. But the expense of these containers, like the disposal of this category of medical waste, usually gets little review by the dental practitioner. It is considered to be a necessary evil – and it is – but it is an expense that can be controlled.

Regulated medical waste disposal has been a creeping type of regulation that has slowly become more defined. Until just recently dentists could take their needles and create their own disposal units by putting them in a bucket and covering them with concrete. But that is no longer the case.

Regulations have changed and dental practices are now required to dispose of this category of medical waste through state permitted disposal facilities that may utilize incineration, autoclaving or chemical treatment of all waste material. Since dentists do not have incinerators, autoclaves or chemicals to treat their own waste, this means that they must contract for this service from third party medical waste transporters.

A few years ago there were a number of these service providers in the market place offering competitive rates. However, recent consolidation of these companies, many of them regionally focused, has increased in recent years and so has the cost associated with medical waste disposal and transportation.

Most general dental practices, unless they perform surgeries, do not generate more than three-four boxes of waste per year. It is a low volume production activity. However, the large medical waste service providers have instituted a contract basis that may necessitate quarterly, monthly or weekly pick-ups – with a charge per container plus administrative fees. This aspect of service is not part of any state or federal regulation, but only as a binding term of a service contract. If your practice has a formal service contract, you are probably paying too much for your service – perhaps two, even three times too much.

Attributes

Whether or not you are a low volume producer or you generate six or more boxes of disposable medical waste medical waste per year, week, or month, what you really need is a service provider that will come when you call them – and this should be when the box is full, not half empty.

The following contract elements are what you should look for with a service provider:

· A fixed price per box
· A written manifest that provides chain-of-custody, cradle to grave disposal documentation
· Agreed schedule of pickup

The following contract “add-ons” are what you should avoid with a service provider:

· No monthly or annual service fees
· No administrative fees
· No environmental surcharge fees
· No box or bag fees
· No box setup fees
· No weight fees
· No missed pickup fees

And by all means do not enter into a long-term contract that has any of the above items as a service requirement. The best arrangement would be to identify a service provider who will service you on a per-call basis with no other charges.

Pay for what you need, not what you do not use.

If you would like to have UDA evaluate your medical waste disposal expense and recommend options, please contact us.