Dental practices in the UK generate various types of waste that must be managed safely and legally.
From amalgam fillings to sharps, hazardous waste to dry mixed recycling, dental waste legislation ensures that it is segregated, treated, and disposed of in ways that protect both public health and the environment.
This guide explores the primary UK regulations, their scope, and how they apply specifically to dental settings.
Legislative Framework Governing Dental Waste
Environmental Protection Act 1990 (EPA 1990)
The EPA 1990 provides the foundational framework regulating controlled waste across the UK.
It prohibits the disposal or treatment of waste in ways that may cause pollution or harm to health.
It also imposes a “duty of care” on producers, including dental practices, to ensure that waste is securely stored, handled responsibly, transferred only to authorised carriers, and accompanied by waste transfer documentation.
Hazardous Waste Regulations 2005 (England/Wales) and Special Waste Regulations (Scotland)
The Hazardous Waste Regulations for England & Wales and Special Waste Regulations for Scotland apply to hazardous materials, including amalgam, chemically contaminated waste, and sharps.
Practices generating hazardous waste must register (in England and Wales), segregate waste correctly, label it properly, and ensure it’s sent to a facility licensed to process that type of waste.
Environmental Permitting Regulations
The Environmental Permitting (England and Wales) Regulations regulate the facilities that treat or dispose of waste, requiring permits for activities such as incineration, autoclaving, or chemical treatment.
While dental practices do not need these permits to generate waste, they must ensure that any company collecting their waste is appropriately licensed.
Sharps Regulations 2013
This legislation requires healthcare providers to protect workers from sharps injuries.
Dental practices must provide suitable disposal containers, utilise safety-engineered devices where appropriate, and train staff in the safe handling and reporting of hazardous materials.
COSHH (Control of Substances Hazardous to Health)
COSHH requires dental employers to assess risks from hazardous substances, including those found in dental waste.
This involves implementing safe storage, using personal protective equipment (PPE), and training staff.
Environment Act 2021
This post-Brexit legislation sets new goals for resource efficiency and environmental protection.
Though broad in scope, it influences waste policy across sectors, including healthcare and dentistry, especially with its focus on recycling and extended producer responsibility.
Dental Waste Streams and Legislative Requirements
Dental Amalgam
Amalgam is regulated under retained EU Regulation 2017/852.
Dental practices must use encapsulated amalgam only, have amalgam separators that capture at least 95% of amalgam waste, and store this waste in separate, sealed containers for collection by licensed waste carriers.
Use is also restricted in children under 15 and pregnant or breastfeeding women unless necessary.
Sharps Waste
Sharps such as needles, scalpel blades, and orthodontic wires must be disposed of in UN-approved containers that are placed at the point of use.
These should be colour-coded, typically yellow or orange, depending on whether the sharps are medicinally contaminated.
Infectious or Clinical Waste
This includes contaminated gauze, gloves, tissues, and extracted teeth.
It must be segregated in yellow or orange bags, stored securely, and collected by a licensed waste contractor for incineration or alternative treatment.
Guidance from HTM 07-01 outlines specific storage and transportation requirements.
Chemical and Pharmaceutical Waste
Expired disinfectants, x-ray fixer, developer, and out-of-date dental materials are considered hazardous and must be segregated into clearly marked containers for appropriate disposal.
These substances are typically managed under hazardous waste rules, requiring consignment notes and tracking.
Non-Hazardous/Recyclable Waste
As of 31 March 2025, under the Separation of Waste (England) Regulations 2025 (also known as Simpler Recycling), dental practices with more than 10 full-time equivalent staff must now segregate recyclables such as dry mixed recycling, food waste and glass waste.
Micro-businesses with less than 10 employees will follow in 2027.
This legislation supports broader environmental goals under the Environment Act.
Duty of Care and Documentation
Dental practices must retain waste transfer and consignment notes for at least two years (non-hazardous) and three years (hazardous).
These documents must include details like European Waste Catalogue (EWC) codes, descriptions, and signatures from both parties.
Practices must also confirm that the waste contractor is registered with the Environment Agency.
Training, Compliance, and Enforcement
Staff must be trained in the correct use of colour-coded bins, safe sharps disposal, PPE, spill management, and emergency procedures.
Failure to comply with legislation can result in enforcement action from the Environment Agency or local authority, and poor waste handling can also result in negative CQC inspection outcomes or professional misconduct findings by the General Dental Council.
Regional Variations and Post-Brexit Changes
While England and Wales use the Hazardous Waste Regulations 2005, Scotland continues to use the Special Waste Regulations.
Additionally, although the UK is no longer in the EU, many environmental laws have been retained under the EU Withdrawal Act, including those governing amalgam disposal and mercury recovery.
A Shift Toward Sustainability
With the NHS aiming for net-zero emissions by 2045, there is increasing pressure for all healthcare providers to reduce their environmental impact.
This includes reducing unnecessary waste, improving segregation, and adopting eco-friendly alternatives to single-use plastics.
Conclusion
Managing dental waste in the UK is a complex but vital responsibility.
It’s about protecting patients, staff, and the environment.
From amalgam regulations to sharps disposal, every dental practice must be up to date on current laws, maintain clear documentation, and ensure proper staff training.
With upcoming recycling regulations and sustainability targets, the need for responsible dental waste management is greater than ever.
If your dental clinic is looking for simple, straightforward waste management, then look no further!
