Medical Waste Management

By Dr. Katherine Schrubbe, RDH, BS, MEd, PhD, Compliance and OSHA Consultant

Image result for medical waste dental

Rules, regulations and standards of care abound in the dental profession. In order for the dental team to comply, all team members must have a clear understanding of the requirements and mandates. In short, it can be overwhelming.

While the primary goal of the dental practice is to provide the highest quality patient care and the best patient experience – all while ensuring patient and staff safety – team members must be efficient, well-organized and competent in the completion of the tasks and duties related to the requirements and mandates. This creates a culture of standardization and calibration. The instrument processing protocols, how to prepare and turn over operatories, and hand hygiene are all examples of tasks that should happen like clockwork.  What to dispose of – the where and how of waste management – is also one of those tasks.  Dental team members who are unsure of the appropriate steps to take may be making costly errors that hurt the dental practice.

Managing medical waste in the dental setting
Let’s review the types of medical waste produced in the dental setting and the protocols for management and disposal. It should be noted that the Centers for Disease Control and Prevention (CDC) states that dental healthcare facilities should dispose of medical waste regularly to avoid accumulation, and any facility generating regulated medical waste should have a plan for its management that complies with federal, state and local regulations to ensure health and environmental safety. Also, dental team members handling waste should be trained in appropriate methods and informed of the potential hazards.1

Having a clear plan, as well as understanding the risks involved, will streamline processes and productivity related to medical waste disposal. Many times, team members are confused with the terms defining the various types of waste. There are basically two types of waste generated in dental practices: regulated and nonregulated medical waste. General medical waste is defined as any solid waste that is generated in the diagnosis, treatment or immunization of human beings or animals in research pertaining thereto, or the production or testing of biologicals. (The term excludes hazardous and household waste.). Only a small percentage of medical waste is infectious and needs to be regulated.2,3,4 Infectious waste, which is regulated, is a very small subset of medical waste (about 3 percent) that has proven to be capable of transmitting an infectious disease.3

The Bloodborne Pathogens standard uses the term regulated waste to refer to the following categories of waste, which require special handling:

  • Liquid or semi-liquid blood or other potentially infectious material (OPIM).
  • Items contaminated with blood or OPIM, which would release these substances in a liquid or semi-liquid state if compressed.
  • Items that are caked with dried blood or OPIM and are capable of releasing these materials during handling.
  • Contaminated sharps.
  • Pathological and microbiological wastes containing blood or OPIM.5

Most of the regulated waste in dental offices consists of contaminated sharps and extracted teeth. However, other examples of regulated medical waste categories in dentistry, such as those listed above, include liquid blood or saliva; two-by-twos or cotton rolls saturated/caked with blood or saliva; used needles, scalpel blades, ortho wires, broken sharps instruments, burs, biopsy specimens and excised tissue.3

The practice management team must be certain that dental team members are trained and have a clear understanding of how to separate regulated waste from nonregulated waste to ensure a purposeful segregation. The practice incurs a cost from regulated waste because it must be picked up and transported off-site by qualified waste hauler vendors; therefore, only items that are considered infectious should be placed in regulated waste receptacles (commonly known as the red biohazard bags or red biohazard sharps containers).

Non-sharp regulated waste items, such as those listed above, must be disposed of in red biohazard bags. Contaminated sharps, however, must be disposed of in red biohazard sharps containers. OSHA points out that contaminated sharps shall be discarded immediately or as soon as feasible in containers that are closable, puncture resistant, leakproof on the sides and bottom and labeled or color-coded. OSHA also states that, during use, containers for contaminated sharps shall be easily accessible to personnel and located as close as is feasible to the immediate area where sharps are used or can be reasonably anticipated to be found, maintained upright throughout use, replaced routinely and not allowed to overfill. Lastly, when moving containers of contaminated sharps from the area of use, OSHA states that containers shall be closed immediately prior to removal or replacement to prevent spillage or protrusion of contents during handling, storage, transport or shipping, and placed in a secondary container if leakage is possible. The second container shall be closable; constructed to contain all contents and prevent leakage during handling, storage, transport or shipping; and labeled or color-coded according to this standard. Reusable containers shall not be opened, emptied or cleaned manually or in any other manner that would expose employees to the risk of percutaneous injury.6   

The CDC recommends that sharps containers be located as close as possible to the work area.1Accordingly, every operatory should have a red biohazard sharps container, which should be stored in a place inaccessible to small children who could mistake a red container for a toy or surprise box.

Once procedures are complete, staff members should dispose of any disposable sharps in the operatory sharps containers. All other used items from patient care that have not been disposed of in red biohazard bags or sharps containers may be safely thrown out in the regular trash. Items such as barriers, gloves, masks, bibs, lightly soiled gauze and cotton rolls are not considered infectious or dangerous to the environment.3

Medical waste is primarily regulated by state environmental and health departments. The Environmental Protection Agency (EPA) has not had the authority to oversee the handling of medical waste since the Medical Waste Tracking Act (MWTA) of 1988 expired in 1991. It is important for the dental team to contact their state environmental program before they dispose of medical waste. They should contact their state environmental protection agency at, as well as their state health agency, for more information regarding their state’s regulations on medical waste.2

It should be noted that the dental practice remains responsible for the regulated waste it generates until it is destroyed or rendered non-hazardous. This concept, which is called cradle-to-grave liability, means that even after waste leaves the practice, any cleanup for any damage it may cause is the responsibility of the generator (the practice); so, the practice should carefully select a licensed waste hauler.3,4

Recordkeeping for the disposal of waste must meet state regulations. The most critical record is the waste manifest – a tracking document that comprises the name of the generator (dental practice), transporter, disposer and the waste itself. It also may include the description and quantity of waste, date, type of container and the type of final disposal.4   All manifest records must be kept for three years.4

The management of medical waste in a dental practice is a critical component of compliance to federal, state and local agency standards. Regardless of the practice size, all dental team members must be aware of what to dispose of, and how and where to dispose of it. Otherwise they risk taking a haphazard approach to the disposal of hazardous materials, causing potential risk to patients and staff, as well as the environment.


  1. Centers for Disease Control and Prevention. Guidelines for Infection Control in Dental Health-Care Settings — 2003. MMWR 2003;52(No. RR-17). Available at: Accessed November 18, 2018.
  2. U.S. Environmental Protection Agency. Medical Waste. Available at Accessed November 18, 2018.
  3. Miller CH, Palenik CJ. Infection Control and Management of Hazardous Materials for the Dental Team. 5th ed. St. Louis: Mosby Elsevier; 2013;192-196.
  4. OSAP Interact Training System Workbook. OSHA and CDC Guidelines; Combining Safety with Infection Control and Prevention. 5th Edition; 2017.
  5. U.S. Department of Labor. Occupational Safety and Health Administration. Bloodborne Pathogens Standard; 1910:1030. Most frequently asked questions concerning the bloodborne pathogens standard. Available at Accessed November 18, 2018.
  6. U.S. Department of Labor. Occupational Safety and Health Administration. Bloodborne Pathogens Standard; 1910:1030. Available at Accessed November 18, 2018.

Practice Rescue: 3 tips to hiring the right candidate

By Corinne Jameson-Kuehl, Owner

Image result for maroon flag

The unemployment rate is at an all-time low, and the war for amazing talent is at an all-time high. What can employers do to find the best fit for the position they seek?

A client dentist recently told me that she was so desperate to fill the open dental assistant position in her practice that she hired the first candidate that applied, despite the “maroon flags” she sensed when she was interviewing and then processing through the employee’s 90-day trial time period.

What are maroon flags?

Maroon flags are when we justify a hire that does not meet all our requirements on a skill or personality level. The applicant does not quite give us the obvious red flag, rather adds in a mix of the cautious yellow flags or warning signs. Often, we feel in our gut something just isn’t right but we hire anyway, dismissing those feelings for fear of the unknown or that we might be overthinking the candidate’s potential.

Three examples of maroon flags could include the following:

  1. Workplace timelines do not add up on the candidate’s resume.
  2. The candidate is very eager or aggressive about securing employment with your practice.
  3. The candidate offers openly negative discussions regarding a previous employer and environment.

3 Tips

How do we avoid getting sucked into a maroon-flag employee?“We feel in our gut something just isn’t right but we hire anyway.”

  1. Use words in your job posting to describe your practice and the position that would attract what you are looking for, such as “growth-minded” or “fast-paced.” You want to sell the position. Great candidates are not just looking for a job, they are looking for a great fit too.
  2. Ask yourself if the candidates applying for the position are hungry for more? Are they teachable and passionate for growth in your business? Initiative cannot be taught.
  3. Ensure you have a system in place for true references, background checks, and interview processes prior to making an offer.

Maroon flags are not to be confused with the red flag of a criminal or drug history, or simply an incapacity to do the job, it is something we can’t sometimes put our finger on.

Teledentistry: Creating the ideal referral relationship

By Jill Shue, Administrative Solutions Coach

With the hustle and bustle in a dental practice, there is a continuing struggle around the referring process. It is easy for tunnel vision to set in once a referral need is determined. The doctor states a referral is needed, and the patient is dismissed to another team member. The focus is no longer just on the patient in the chair but also on the next patient waiting to be seen, running on time, and managing operations.

In the rush, communication is lost and patients fall between the cracks. Both the referring doctor and specialist, along with their teams, have their responsibilities to each other as well as to the mutual patient.

The reality

Your patients have chosen you as their provider. Your patients trust you. However, many general dentists do not offer specialty services within their practices. This means that when you make a referral to an outside specialist, patients have to leave their comfort zone for treatment.

Look at it from your patient’s perspective: She is ushered out of the treatment room, handed a slip of paper and told to call a new, unfamiliar office — often without follow-up instructions. The patient leaves your office knowing she needs to do something to further her care. Often patients either fail to follow through with the recommendations, or they call to schedule and are confused with their specific need.

If patients overcome those obstacles and have the treatment completed by the specialist, they often experience a lack of follow-up. Patients assume the general dentist’s team will be in touch to take the next steps, but usually, in our experience, there is no communication back to the general practice.

When there is no communication, the patient then does not complete the necessary treatment and the likelihood of success drops. Patients are not aware that the two providers do not share records. When treatment is completed, we do not have a magic wand to wave to alert us to the patient’s treatment progress. Treatment falls between the cracks. The patient falls between the cracks.

Provider’s perspective

Often adequate information is not shared between the offices. If the referring practice’s team fails to send the referral, notes, and images to the specialist team promptly, then the specialist’s team must hunt down records. Seemingly endless calling and emailing between the offices asking for information becomes routine, and inefficiencies set in.

Once the specialist team has the necessary information to treat the patient, the team is then able to appoint and treat the patient appropriately. The specialist team then fails to communicate to the general team that the treatment has been completed and to instruct on the necessary healing times and follow-up needs.

The patient does not receive the best care, steps are missed, and care is delayed. In our experience, both offices vent their frustration and blame the other. When neither team takes responsibility for its part in the mutual patient’s care, then the doctor-patient relationship is broken. The relationship between the two offices is also broken. No one wins.


We talk with our clients about taking a concierge team approach enhanced through teledentistry technology. This approach can offer your patients a warm introduction to the specialist and team and also continue the exceptional communication your team and you already offer throughout their treatment.

Your patient needs to visit a specialist. Your team communicates with the specialist’s team members, informing them of the patient’s diagnosis. Your office then sends the patient’s images and provides the referring team a teledentistry appointment for the patient.

Your patient and the specialist virtually meet via a teledentistry platform in your office. A live video consultation puts the patient at ease and creates a rapport between all parties. The patient leaves the referring office with the specialist appointment scheduled. Now both care teams are aware of the patient’s needs, enabling them to create a treatment plan together that best fits the patient’s needs.

Once the patient receives the treatment, the specialist then communicates back to the referring team to inform of the next step and the general team continues the patient’s care as determined. The key is communication. Both doctors and their teams must be in continual communication with one another.


By creating systems to improve communication between the referring doctor and specialist, you close the gap. Your case acceptance may rise while your patient retention and satisfaction also increase. Your team benefits from a streamlined, secure exchange of clinical data. The patient receives the best experience and care that both the referring and specialty teams have to offer.

Don’t just be a good specialist or a good referring doctor. When you close the gaps, you’ll be successful for your team, your colleagues, and your patients.

Upset the Apple Cart! Create a Superior Patient Experience

By Laura Barnes, Transitions Management Coach

Does it ever feel like you are trying your best, but are in a continuous loop of the same results? The competition always seems to be more innovative or have more financial resources?  If so, it’s time to upset the apple cart!

Most dental offices strive to provide exceptional care for their patients as part of their philosophy but operate on auto-pilot once the practice is well-established.  One common thread of discussion among all practices revolve around how to find new patients and attract them. However, the real question is how to keep them engaged, but even better, be a spokesperson for your practice.  Consider this…a friend asks about a recommendation to see a newly released movie…you don’t recommend a movie that you like, you recommend a movie that you LOVE! Be the dentist your patients LOVE!

The solution is to design their experience with your office for emotion, not experience.  As dentists and teams, we usually focus on the systems and procedures to provide excellent care.  While these are important and the cornerstone for success, sometimes we forget that the patient is a person-  a person that wants to connect with us on a personal level. It should be our goal to help them feel comfortable and connected with us….to pleasantly surprise them by hosting a (mini) surprise birthday celebration for them, mailing a handwritten note, or remembering to inquire about a new grandchild.  These efforts do not need to be expensive…the goal is to out-think the competition, not out-spend. The most memorable moments center around how you make your patients feel!

What do YOU do to create a “WOW” experience for your patients that gets them talking about you and your team to their friends, family and colleagues? How do you challenge the status quo and upset the apple cart??

Business Connection or Pyramid Recruit?

By Corinne Jameson-Kuehl, RDH, Owner

It’s that time of year where everyone is making goals and excited about achieving them. Statistics show within 6 months of the new year, only 9% of those who make resolutions actually stick to the goals they make.

Many of us start the year off strong with goals to make new and better business connections. We look to align ourselves with businesses that share similar philosophies and modes of action. It makes sense to be attracted to growth-minded people that will drive business and assist potential mutual clients to success. What doesn’t make sense is when individuals want to connect for the purpose of pushing their home-based business product, or for the self-serving goal of gaining your hard earned network list.

It is wise to approach any new business connection invitation with the following cautions:

           1. What is the mutual purpose of making this connection?

           2. Will this new connection take away time and energy from my vision and values of what  

               goals I am looking to accomplish?

If there is any doubt on the intention of the new connection, simply ask them why they would like to connect with you. This question will help you make an efficient and advantageous decision immediately.

Jill Shue of Custom Dental Solutions Awarded Fellowship in the American Association of Dental Office Management

Milwaukee, WI: October 1, 2018

Custom Dental Solutions is pleased to announce that our Lead Administrative/Insurance Trainer has achieved the distinction of Fellow in the American Association of Dental Office Management (AADOM).  The Fellowship achievement recognizes outstanding professional and educational achievements in dental practice administration and is awarded only to those who have completed rigorous requirements set forth by AADOM.

Our team will benefit from Jill’s extensive knowledge in leadership, dental insurance management and patient relations.

The convocation and induction ceremony was held in San Antonio, TX on July 20th at the 14th Annual AADOM Conference.


About AADOM:

The American Association of Dental Office Management (AADOM) is an organization of professional office managers, practice administrators, patient coordinators, insurance and financial coordinators, and treatment coordinators of general and specialized dental practices.  AADOM is the nation’s largest education and networking association dedicated to serving dental practice management professionals. For more information please call 732-842-9977 or visit

Reprocessing Dental Handpieces

By Dr. Katherine Schrubbe, RDH, BS, MEd, PhD.

Compliance with CDC guidelines for reprocessing is vital to the safety of the dental staff and patients.

There seems to be a lot of buzz about dental handpieces these days. For whatever reason, the question of reprocessing these devices for patient use is once again a popular conversation in dental practices. Dental handpieces are medical devices accompanied by instructions for use (IFU). As discussed in a previous article, IFU are provided for medical devices and products in accordance with federal Food and Drug Administration (FDA) standards and provide information on cleaning, disinfection and 1 In any dental setting, IFUs must be strictly followed to ensure patient safety, as well as peak performance of the devices. Whether the organization is a DSO, a large group practice or a solo practice, there must be a sufficient number of instruments to serve the patient schedules in order to avoid shortcuts in reprocessing.

sterilization of patient care items.

Categories of patient care items

The Centers for Disease Control and Prevention sorts patient care items into three categories (referred to as the Spaulding classification), based on the potential risk for infection associated with their intended use: critical, semicritical or noncritical.2,3

Centers for Disease Control and Prevention. Guidelines for Infection Control in Dental Health-Care Settings – 2003. MMWR 2003;52(No. RR-17); 20.

At the ends of the spectrum are the critical and noncritical patient care items. According to the CDC, all critical items should be heat sterilized between patient use, as they have the greatest risk of transmitting infection. Noncritical items, which pose the least risk of disease transmission, should be cleaned and disinfected with an EPA-registered hospital disinfectant.2,4

In the middle of the spectrum are semicritical items. These items come in contact with mucous – or non-intact – membranes, but they do not penetrate soft tissue, contact bone, the bloodstream or other normally sterile tissues.2

Dental handpieces are considered semicritical items. The CDC states, “dental handpieces and associated attachments, including low-speed motors and reusable prophylaxis angles, should always be heat sterilized between patients and not high-level or surface disinfected.  Although these devices are considered semicritical, studies have shown that their internal surfaces can become contaminated with patient materials during use. If these devices are not properly cleaned and heat sterilized, the next patient may be exposed to potentially infectious materials.”4,5,6

In other words, there are no shortcuts to patient safety around handpieces, including low-speed motors use primarily for hygiene appointments. Eleven states require heat sterilization of dental handpieces: California, Florida, Indiana, Kansas, Missouri, New Mexico, Ohio, Oregon, South Carolina, Virginia, and Washington.7 And, the CDC guidelines fully apply in the remaining 39 states. Additional guidance from the CDC states, “handpieces and other intraoral devices that can be removed from the air and waterlines of dental units should be cleaned and heat-sterilized between patients. Follow the manufacturer’s instructions for cleaning, lubricating, and sterilizing these devices. These devices include high-speed, low-speed, electric, endodontic, and surgical handpieces, as well as all handpiece motors and attachments, such as reusable prophylaxis angles, nose cones, and  contra-angles.”8

The updated guidance from the CDC provides a 3-point summary:

  1. Clean and heat sterilize handpieces and other intraoral instruments that can be removed from the air lines and waterlines of dental units.
  2. For handpieces that do not attach to air lines and waterlines, use FDA-cleared devices and follow the validated manufacturer’s instructions for reprocessing these devices.
  3. If a dental handpiece cannot be heat sterilized and does not have FDA clearance with validated instructions for reprocessing, do not use that device.9
Dr. Katherine Schrubbe, RDH, BS, M.Ed, PhD


  1. Schrubbe K. Instructions for use. Efficiency in Group Practice. Available at Accessed April 24, 2018.
  1. Centers for Disease Control and Prevention. Guidelines for Infection Control in Dental Health-Care Settings — 2003. MMWR 2003;52(No. RR-17); 20.
  1. Miller CH, Palenik CJ. Infection Control and Management of Hazardous Materials for the Dental Team. 5th ed. St. Louis: Mosby Elsevier; 2013; 122.
  1. Centers for Disease Control and Prevention. Summary of Infection Prevention Practices in Dental Settings: Basic Expectations for Safe Care. Atlanta, GA: US Department of Health and Human Services, Centers for Disease Control and Prevention, National Center for Chronic Disease Prevention and Health Promotion, Division of Oral Health, March 2016.
  1. Chin J.R., Miller C.H., Palenik, C.J. (2006). Internal contamination of air-driven low-speed handpieces and attached prophy angles. J Am Dent Assoc. 137(9):1275-80. Available at Accessed May 10, 2018.
  1. American Dental Association. Oral health topics; infection control. Available at Accessed May 10, 2018.
  1. The Dental Student Network list of state licensing agencies. Available at Accessed April 24, 2018.
  1. Centers for Disease Control and Prevention. Dental Handpieces and Other Devices Attached to Air and Waterlines. Available at Accessed May 10, 2018.
  1. Centers for Disease Control and Prevention. Statement on Reprocessing Dental Handpieces, April 11, 2018. Available at Accessed May 10, 2018.
  1. US Department of Health and Human Services. Public Health Service Food and Drug
    Administration. Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling Guidance for Industry and Food and Drug Administration Staff. March 17, 2015.  Accessed May 10, 2018.
  1. Vavrosky K. 5 infection control mistakes you may be making and not even realize. Dental Products Report, July 11, 2016. Available at,1.  Accessed May 10, 2018.

Are you busy or productive?

There is an old song that goes like this, “sitting on the dock of the bay wasting time…” Although sitting on the dock of the bay relaxing and enjoying the quiet is truly needed in our lives; “wasting time” is a great way to get to stuck in your personal and professional life.

There are a multitude of people who talk about moving forward, desiring to act upon their goals, but never get “there” because they are stuck sitting on the dock, and wasting a lot of time.

1. Consider your schedule: Are you busy reacting to busy-work, or are you productive with goal accomplishment?

2. Evaluate your need for “dock-time” are you using too much of it to avoid feeling overwhelmed, and therefore creating laziness and a feelings of imposter syndrome?

3. Create active daily and weekly goals and be accountable for them. Write them down to ensure better successful outcomes.

Organize your schedule into time periods of accomplishments, allowing for achievement and relaxation. There are several great resources out there to help you begin a life of productive habits. A couple of my personal favorites: “The Miracle Morning” by Hal Elrod and “Train your Brain for Success” by Roger Seip (particularly the 2-hour solution section).
Now go! Get off the dock!

What is preventing your Success?

Are you finding yourself asking why you are not as successful as you want to be?  The difference between successful people and unsuccessful people is the reaction to what happens around them.  Successful people are always moving forward, prepared for any action.  Unsuccessful people have no plan and simply react to the circumstances around them.

  • Take full personal responsibly-no more excuses
  • Identify what you want to accomplish and write down the steps it would take to get “there.”
  • Surround yourself with successful people in successful environments and eliminate distractions.
  • Become accountable to a trusted adviser to ensure you finish what you start.


What is your plan?  Be excited as you enjoy the journey of success!


By:  Corey Jameson-Kuehl