Under federal regulations nearly all oral healthcare facilities fall under the CESQG category. However, some states do not recognize the EPA’s CESQG category and in those states dental offices are regulated as SQGs.12 Other states have a CESQG category, but require that CESQGs follow SQG requirements related to the tracking of and accountability for the waste. The State-by-State Hazardous Waste Resource Locator provides information for specific jurisdictions.4
To be in compliance with RCRA hazardous waste rules under federal EPA regulations, CESQG oral healthcare facilities are not required to obtain an EPA ID number, comply with hazardous waste accumulation and storage requirements, follow the manifest system, or meet recordkeeping and reporting requirements, and there is no time limit on how long they may accumulate hazardous waste (as long as the 1,000 kg maximum quantity limit is not exceeded).
However, it is prudent practice (not specifically required by the EPA) to label hazardous waste containers with the words “Hazardous Waste” and the identity of their contents (Figure 4). It is also prudent (not specifically required by EPA) that oral healthcare facilities maintain records (e.g., manifests, billing records, certificates of disposal, or other documents from hazardous waste disposal contractors) demonstrating that they have properly disposed of their waste.