Dental Tribune USA

California as a model for regulated medical waste disposal

By Dr Burton J. Kunik, USA
November 12, 2009

California ranks first in the United States for the number of dental services provided. A survey released in 2009 by the UCLA Center for Health Policy Research showed that the state has more than 31,000 licensed dentists, or approximately 14 per cent of the nationwide total. In addition to its size, the dental community in California has another distinction — compliance requirements with some of the most comprehensive state laws in the country regulating medical waste disposal.

Regulatory policy in California is often a model for other states, and increasing nationwide concern over the environmental implications of medical waste disposal suggests that dental professionals should be familiar with California requirements and solutions.

California provisions

All dentists realize that their practices deal in materials and tools that must be properly managed for staff and patient safety, but too many do not understand the dental office specifics of regulated materials. Treatment byproducts such as used gloves, masks, gowns, patient bibs, lightly soiled gauze or cotton rolls and plastic barriers actually are not regulated medical waste. According to the Centers for Disease Control and Prevention, only one to two percent of dental office waste is actually regulated medical waste, with needles and other medical sharps composing the bulk of that material.

Regulated medical waste is defined by the California Division of Occupational Safety & Health (Cal/OSHA) as:

  • Liquid or semi-liquid blood or other potentially infectious materials (OPIM), such as bloody saliva.
  • Contaminated items that would release blood or OPIM in a liquid or semi-liquid state if handled or compressed.
  • Items that are caked with dried blood or OPIM and are capable of releasing these materials during handling.
  • Pathological and microbiological wastes containing blood or OPIM.
  • Contaminated sharps.
  • Waste regulated by the California Health and Safety Code which includes pharmaceuticals that are not hazardous.

Disposal issues

In California, as in other states, many dental offices pay for standard monthly or quarterly collection of regulated medical waste by medical waste pickup services. However, this is generally expensive since dental offices generate minimal medical waste, and it is also disruptive, as when pickups are missed or office workflow is interrupted by the collection process. For a small office, this is just not cost-effective.

Effective option

Disposal by mail is an alternative disposal option that can save the dentist money and free up staff for patient care.

Disposal by mail systems include a sharps container specially designed to be mailed through the U.S. Postal Service and a pre-paid return-by-mail package. All costs of the container, packaging, return postage, destruction and documentation are included in one purchase price. Systems are ordered on an as-needed basis without required contracts. Once filled, they are simply handed to the postal carrier. Proof of destruction is available through an online manifest tracking program.

A variety of sizes of disposal by mail systems are available. Included sharps containers can be placed on a counter or mounted and locked on the wall. There are even disposal by mail options allowing dentists to use their own current sharps containers. Besides the cost savings of the disposal by mail, there are no calls for pickups, no interruptions during patient care, no monthly fees, no contracts, no keeping up with waste manifests since they are maintained online, and no extra costs beyond the basic system components.

The requirements for adherence to the California Medical Waste Management Act waste segregation and storage limits are easily met with the disposal by mail systems, eliminating unnecessary pickups, often required by some medical waste disposal services. Disposal by mail also is extremely safe and can reduce liability and the risk of non-compliance often encountered by using other methods of medical waste management such as encapsulation (which must also disinfect the waste). It is important to note that disposal by mail companies, like all other forms of regulated medical waste disposal, must be approved by the state.

Disposal by mail is an effective solution in any state, no matter what the regulatory requirements.


Former dentist Dr Burton J. Kunik is chairman and CEO of Sharps Compliance Corp., a provider of cost-effective disposal solutions for medical and pharmaceutical waste generated outside the hospital setting. The company’s Web site is Dr Kunik can be reached at

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