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Interpretation Response #00-0199 ([Florida Department of Environmental Protection] [Ms. Irene Gleason])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Florida Department of Environmental Protection

Individual Name: Ms. Irene Gleason

Location State: FL Country: US

View the Interpretation Document

Response text:

September 21, 2000


Ms. Irene Gleason                             Ref. No. 00-0199
Hazardous Waste Management Section
Florida Department of Environmental Protection
Two Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32399-2400

Dear Ms. Gleason:

This is in response to your letter dated  July 17, 2000, requesting clarification on shipping scrap dental amalgam under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether scrap amalgam is regulated under the HMR.

According to your letter and attached "Scrap Dental Amalgam Management Procedures," dental amalgam, usually a mix of 50% mercury with the remainder being silver and small amounts of tin, copper, and other metals, is used for filling cavities in teeth. The scrap amalgam is decontaminated with 1:100 bleach before being sent for reclamation to various facilities.

Under § 173.22, it is the shipper's responsibility to properly classify and describe a hazardous material.  This office does not normally perform that function.  However, based on the information provided in your letter, it is the opinion of this Office that since the waste amalgam is decontaminated before shipping for reclamation, it does not meet the defining criteria for a Division 6.2 infectious substance or regulated medical waste.  However, if the quantity of mercury in one package meets or exceeds the reportable quantity specified in the HMR, it would be regulated as a Class 9 environmentally hazardous substance when shipped to the reclamation facility.

I hope this answers your inquiry.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards



Regulation Sections

Section Subject
173.22 Shipper's responsibility