Best Management Practices For Hazardous Materials/Waste Handling 

Best Management Practices (BMPs) should be thought of as "good housekeeping" procedures. In medical facilities there are many waste streams that could be considered non-hazardous if properly recycled instead of thrown into the trash or dumped down the drain.

To the right of the waste heading you will find references to the respective federal and state law. Federal laws for waste management can be found in the Resource Conservation and Recovery Act (RCRA) - 40 Code of Federal Regulations (CFR) 260-266, 268, 270-273, 279, 280-282, and 148. State laws for waste management can be found in Florida Administrative Code (FAC) 62-730 and various Florida Statutes (F.S.). State laws on waste management are typical more stringent than federal laws. 
Silver Recovery: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 |  F.S. 403.721​ and 40 CFR 401 | FAC 62-660  | F.S. 403.051

Depending on the locations of facilities and the pre-treatment requirements, you may be allowed to dispose of the photo processing liquid waste stream into the sanitary sewer. Silver is the regulated element in this waste stream and can be removed and sold. Below are some guidance suggestions for your use in determining BMPs for the facility. Each facility's needs will depend on location and amounts processed each day.
 Generation Sources:
  • Silver is the element used as the light-sensitizing agent in most photographic materials and is present in photographic fixer solutions as silver thiosulfate complex. 
  • During the developing process, silver is released in the fixer and the bleach/fix.  In addition, silver is also present in the wash water as a result of "drag off" from the different processing tanks. 
  • The concentration and distribution of silver in the photo processing solutions depends on the type of photo processing system used, method of collection, type of wash and the amount of film processed per day.
 Disposal Options:

Eventually, the solutions must be replaced and used solutions disposed of. 
  • One method of disposal for the used solution is to store the used solutions in DOT approved containers and then have them hauled away by a licensed commercial hazardous waste hauler.
  • Another possible disposal method is to discharge the solutions to a POTW (Publicly Owned Treatment Works) also known as the sanitary sewer system. If the film processor elects to discharge the "waste" chemicals to a POTW, they must be treated to reduce the silver content prior to discharge.  It is required that you receive written permission from your POTW's "pretreatment officer" to discharge this type of waste stream. The pretreatment officer will approve or disapprove your request based on silver content of the waste, their operational permit requirements and the plant's capacity for this type of waste stream.
  • Discharges to a septic system will require approval from the Lee County Health Department and may not be attainable. This type of disposal is not recommended because of the potential to contaminate onsite property and because these chemicals may destroy the biological process necessary for septic tanks to continue effective operation. 
  • All records for disposal or recycling must be kept on site for three years. 

Processing Chemicals and Washes

Waste fixers, system cleaners, low flow washes and washless stabilizers may be hazardous due to heavy metals or organic chemicals they contain. For example, waste fixers and stabilizers may contain hazardous levels of silver.  Prior to disposal, determine whether waste fluids are hazardous. Please read the material safety data sheets (MSDS) to help in this determination.


Common solvents used for cleaning film, work surfaces and equipment may contain hazardous substances.  For example, film cleaners may contain trichloroethylene, a listed hazardous waste, or they may be hazardous due to flammability, having a flash point of less than 140 degree Fahrenheit.

 Photographic Film

Undeveloped photographic film contains high concentrations of silver. Before disposing of undeveloped film waste take the proper steps to remove the silver from the film.  Film ends and tabs can be soaked in waste fixer to remove the silver from the film before disposal.

Black and white film and x-rays do contain residual levels of silver after developing.  Before disposing of these negatives, contact a film recycling contractor for reclamation of the residual silver and the film.

 Silver Recovery Units

Two popular methods of silver recovery produce wastes and effluents that are hazardous.  Wastes sent to a contractor for reclamation or recycling are exempt from hazardous waste regulations.  It is important to properly maintain silver recovery units.

Electrolytic recovery units cause silver to collect in electrolytic cathodes. The silver can be recycled and the desilvered fixer can generally be discharged to a sewer or reused.  Obtain written notification from your sewer authority before discharging desilvered fixer.  Care must be taken to prevent the formation of sulfides.  Silver concentrations in the effluent may be high.

Metallic replacement or chemical replacement cartridges form a silver sludge that may be reclaimed.  Silver concentrations in the effluent is high unless two units are in series.


Waste processing chemicals and washes or wastewaters from metal recovery units should never be discharged to the ground or to a septic tank system.  Waste processing chemicals, wastewater, etc. should be discharged only to a sanitary sewer system with written permission from your local sewer authority.

Substances commonly used in photo processing and subject to wastewater regulations include:
  • Ammonia       
  • Silver  
  • Iron     
  • Sulfites/Sulfates         
  • Formaldehyde

Heavy metals: cadmium, chromium and zinc

Fixers, washless stabilizers and other silver-rich wastewater should undergo silver recovery before being discharged to a sanitary sewer system.  It may be necessary to contract with a licensed photographic waste disposal company to properly dispose of your silver-rich solutions.

Lead Foil Packaging: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 |  F.S. 403.721

The lead foil backing on x-ray film needs to be recycled, not thrown into the trash.  If the foil backings are not recycled, they are considered a hazardous waste.  Some of the film suppliers will provide a recycling service; you should contact your supplier to explore your options.  All records for disposal or recycling must be kept on site for three years.

Amalgam:   40 CFR 273.13 | FAC 62-737 | F.S. 403.7186 OR 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 |  F.S. 403.721 

Dental amalgams are the silver colored fillings used to fill cavities.  This substance is regulated because it contains the elements Mercury, Silver and Tin.  Amalgams comes in different forms: excess amalgam from new fillings, pulled teeth with amalgam fillings, and amalgam traps.  All of the types listed above may NOT go into the trash and MUST be recycled.  If you choose not to recycle your scrap dental amalgam, you must comply with all hazardous waste regulations.  All records for disposal or recycling must be kept on site for three years.

Additional Information on Amalgam Waste
Thermometers: 40 CFR 273.13 | FAC 62-737 | F.S. 403.7186​​

Thermometers containing mercury should not be thrown into the trash.  A typical thermometer can contain .5-3 grams of mercury.  The mercury MUST be recycled.  This can be done by finding a hauler or using the Business Collection Days.  Thermometers should not be broken.  If one happens to break, place all mercury and glass into a closed container for proper disposal.  Do not use bare hands or a regular vacuum to clean up mercury; this is hazardous to your health.  Less hazardous options for thermometers are alcohol filled or digital.  All records for disposal or recycling must be kept on site for three years.
Disinfectant waste: 40 CFR 261 & 40 CFR 262 | FAC 62-730.030 |  F.S. 403.721

Most of the solvent waste generated at medical facilities come from the disinfectant or cleaning of instruments.  Depending on the concentration of the solution you are using, the waste may be hazardous.  Reading the Material Safety Data Sheet for your disinfect will determine your disposal method.  If the waste is hazardous, it must be captured in a container that is sealed so no evaporation occurs and treated as hazardous waste.  All records for disposal or recycling must be kept on site for three years.
Fluorescent Bulbs: 40 CFR 273.13 | FAC 62-737 | F.S. 403.7186​​

Fluorescent bulbs/devices are considered hazardous waste because they contain the element Mercury.  However, if you recycle your Fluorescent bulbs/devices, they do not qualify as hazardous.  Caution: if a supplier tells you that their bulbs are environmentally safe remember that they are trying to sell you a product, and they may not be familiar with the State and Local regulations that pertain to the proper recycling or disposal of these mercury-containing bulbs. Lamps or devices with ANY mercury MUST be recycled.   All records for disposal or recycling must be kept on site for 3 years.

Additional Fluorescent Tube Information

Material Safety Data Sheet (MSDS)

*Material Safety Data Sheets are a good start to determine if your waste stream will be hazardous waste. They do have their limitations if they are too vague. MSDS's do not take into account what process or system the product may be used in or what your management practices are for preventing cross contamination. Before purchasing any product, request the MSDS to see what is in it and to help avoid costs associated with the purchase, use, and disposal of the product.

Do Not: 

  • Do not store any materials/waste near storm drains, ditches, creeks, rivers, canals or any bodies of water that would be contaminated if a spill occurs.
  • Do not throw away or send receipts that show proper disposal of waste materials to a bookkeeper.  They are required to remain on site for a minimum of three years.  This includes contracts with hazardous waste haulers.
  • Do not take the word of any sales person who will not supply MSDS for the product he/she is selling.  Some will say that the material is biodegradable or environmentally friendly, but the process that you use the material in may contaminate the product and cause it all to be regulated (i.e., equipment degreasing and rinsing).
  • Do not dispose of any material into your septic system, sanitary sewer, or storm sewer.  If you want to do this you must have written permission from the regulatory agency that permits that particular system. For Septic Systems it is the Department of Health and Rehabilitative Services; For Sanitary Sewers it is the local utility district that you are located within.
  • Do not store hazardous waste out of containment areas.  Make sure all containers are labeled properly (include dates where necessary).


If you have any questions, please call the Division of Natural Resources Management, Pollution Prevention (P2) Program at 239-533-8821. The P2 Program is here to serve your interest in the proper management of hazardous waste.

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