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Silver and Lead Recovery Policy


The purpose of this policy is to establish standards and protocols that can be distributed throughout the School of Dentistry regarding the proper disposal of lead and silver containing wastes.


Silver reclamation and lead disposal both fall under EPA jurisdiction since both lead and silver are "hazardous wastes" when "discarded". The EPA regulation that deals with identification of hazardous waste of this type is 40 CFR 261. It is included in the EPA Hazardous Waste regulations in a group of 41 such materials referred to as TCLP (Toxic Characteristic Leachate Procedure) wastes. The threshold concentrations for solutions and solids containing silver or lead are 5mg/liter or .0005%. Therefore, very little solution is necessary to produce a hazardous waste. Both lead and silver have a hazardous waste exemption for reclamation. If the materials are reclaimed they are subject to a less stringent regulation by the EPA.

Silver Reclamation / Lead Recovery

In light of the above federal regulations, the following policy of silver and lead reclamation is in effect for the UNC School of Dentistry. Any area that generates lead or silver wastes must establish a means of securing these wastes and transporting them to the Division of Radiology for proper disposal and/or reclamation. The protocol for bringing fixer, lead foil, scrap film and amalgam is outlined below.

  1. Used fixer. Used fixer should be transported in gallon containers to Radiology. Bring fixer weekly since the main recyclable unit in Radiology only holds five gallons at a time. Do NOT bring developer.

  2. Lead Foil. Save lead foil from inside film packet and bring to Radiology where University Health and Safety will pick it up.

  3. Used or rejected radiographic film. Collect (do not throw in trashcan) any rejected or unwanted film and bring to radiology for recycling.

  4. Used amalgam. Save amalgam in plastic container and bring to Radiology where University Health and Safety will pick up.

If you have any questions contact Ms. Madge Webster at 537-3561 or Dr. Rick Platin at 537-3145.

The Radiology Dental Faculty Group is supporting a silver recovery unit that has the capacity of servicing the dental school. Health and Safety has provided Radiology with the proper containers for the disposal of lead foil and will pick up and transport these materials to comply with applicable EPA and DOT regulations.

Examples of materials to be sent to Radiology:

  1. Fixer solution, lead foil from film packets, old or unused radiographic film
  2. Photographic fixer solution
  3. Lead or silver containing solder
  4. Research material containing silver or lead with the potential for hazardous waste generation
  5. Used amalgam

Chemical Hazard Communications Committee

Last Modified: 11/19/2012