BEST

MANAGEMENT

PRACTICES

FOR

DENTAL

WASTE

T A B L E O F C O N T E N T S

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Managing wastes to prevent pollution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Amalgam management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Fixer management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Off-site disposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

On-site treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Choosing a waste hauler or recycler . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

City of Boulder wastewater discharge limits . . . . . . . . . . . . . . . . . . . . . . . . . . 5

List of contacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

I n s e r t s

Dental waste recyclers

Colorado Department of Public Health and Environment hazardous

waste compliance bulletin for photographic, x-ray and dental wastes.

treats waste water from households, indus-tries, institutions and commercial businesses. The plant’s treatment processes remove solids andorganic materials from the incoming wastewater. Treated wastewater is discharged to Boulder Creek.The solids that settle out of the wastewater, called biosolids, are treated and used for improving farm-land soil. To protect Boulder Creek’s sensitive ecosystem and maintain biosolids quality, wastewatermust meet stringent water quality standards for numerous pollutants, many of which cannot be com-pletely removed by the City’s treatment plant. Metals are of specific concern because they are notdegraded but instead settle out into either the biosolids or pass through the plant’s processes intoBoulder Creek.

I N T R O D U C T I O N

The City of Boulder’s Industrial Pretreatment program has prepared this brochure to providethe dental community with guidelines on choosing environmentally friendly products, recyclingmetal-bearing wastes, and correctly disposing of waste materials. Through pollution prevention,dental practices can reduce the regulatory requirements associated with wastes such as usedx-ray fixer, amalgam, and chromium x-ray cleaners.

1

M A N A G I N G W A S T E S T O P R E V E N T P O L L U T I O N

Pollution prevention measures include employee training, product substitution, improved housekeepingpractices, chemical inventory control and the recycling of metal wastes. When implementing a pollution pre-vention strategy, you should consider the potential for inadvertently transferring pollutants from one wastestream to another.

For example, mercury is very persistent in the environment. Chair side traps are beneficial in preventingamalgam from going down the drain which could otherwise contribute to wastewater pollution. However, ifthe recovered amalgam is disposed of in the trash or as biohazardous waste, the mercury disposal problem isnot resolved, it is just being transferred to another waste stream. The good news is that both mercury fromamalgam and silver from used x-ray fixer can be recycled. Recycling these resources is not only the environ-mentally correct thing to do, but may also alleviate some of the requirements associated with disposing ofthese wastes.

The City of Boulder, like many municipalities, has limitations on concentrations of pollutants such as metals,discharged to the wastewater system. These limits are designed to protect the quality of treated wastewaterdischarged to Boulder Creek and maintain biosolids quality. Refer to page 5 for a list of the City of Boulder’swastewater discharge limits.

The State of Colorado oversees hazardous waste generators, ensuring environmentally correct managementand disposal of hazardous waste. For more information on Colorado’s hazardous waste requirements refer toInsert 2.

Other pollution prevention measures you might want to consider to improve both the quality of your work-place and the environment include:

l Using precapsulated dental amalgam;l Using disinfectants containing less-hazardous materials such as quaternary amines;l Discontinuing the use of x-ray developer cleaning products that contain chrome;l Researching and purchasing new technologies such as filmless radiography and;l Advocating pollution prevention among the employees.

Below is a chart that lists several types of waste generated by dental clinics along withenvironmentally correct disposal options.

WASTE TYPE SOURCE O P T I O N

Amalgam particles Traps, screens, excess mix 1) Send to a recycler.2) Dispose of as a hazardous waste.

Waste or bulk mercury Spills, spill cleanup 1) Send to a recycler.2) Dispose of as a hazardous waste.

Empty amalgam capsules

Fixer

Precapsulated amalgam use

X-ray process

1) Dispose in trash.

1) Take off-site for recycling.2) Treat before discharge to sewer.3) Dispose of as hazardous waste.

Developer

X-ray system cleaners thatcontain chrome

X-ray process

X-ray process

1) Discharge to sewer.

I) Switch to nonchrome containing cleanerwhich can be discharged to sanitary sewer.

2) Dispose of as hazardous waste.3) Use mechanical methods (brush and

elbow grease) instead of chemicals.

Disinfectants with less than 4%glutaraldehydeDisinfectants with low concentrationsof formaldehyde

Lead foils and shields

Equipment cleaning

X-ray processing protective shields

1) Discharge to sewer.2) Use disinfectants containing less-hazardous materials such asquaternary amines.

1) Send to metal reclaimer.2) Dispose of as hazardous waste.

Check the Material

Safety Data Sheet to see

if the x-ray cleaner you

use contains chrome.

If it does call your

supplier and ask for an

alternative that does not

contain chrome.

Store all hazardous waste

in closed containers. Make

sure the containers are

appropriate for the waste

being stored (plastic con-

tainers for fixer and

amalgam waste). Liquid

hazardous wastes should

be stored on an imperme-

able surface in a secure

area without floor drains.

2

A M A L G A M M A N A G E M E N T

Amalgam waste should never be discarded in the ‘red’ bag or infectious waste collection.Biohazardous waste can be incinerated. When amalgam waste is incinerated, the mercury is released into theenvironment in the incinerator’s air emissions.

Mercury, though bound in the amalgam, can be recovered. Amalgams are made up of about 50 percent mercuryand some portion of silver, tin, copper and, in some cases, other metals, such as zinc, palladium or indium. Theinserted list identifies businesses providing amalgam waste management services and off-site recycling services.Some recyclers may give you a refund or credit for the recovered mercury.

Amalgam waste

should never be put

in with the infectious

(red bag) waste.

Best Management Practices for Amalgam Management

1. Never flush amalgam down the drain.2. Make sure your office has a mercury spill kit.3. Use precapsulated alloys. Avoid using elemental mercury.4. Collect empty capsules in a covered container and dispose with solid waste.5. Retrieve excess amalgam during placement with gauze. Larger particles should be recycled and

gauzes placed in solid waste (which is not incinerated). Recover amalgam from instruments prior to wash-ing. The material used to wipe the instruments should also be disposed of as solid waste.

6. Change amalgam traps at least once a week or more frequently if your practice warrants it. Flush the lines at the end of the day and change the traps first thing the following morning. Only traps on chairs used foramalgam placement or removal need special handling. Place traps from chairs dedicated to hygiene in theregular solid waste.

Never rinse amalgam

traps over drains or

discard in garbage.

7. Use disposable traps instead of reusable traps because of the difficulty in effectively removing amalgam parti-cles from the trap without discharging the amalgam into the drains or garbage.

8. Secondary filters in vacuum systems should be changed once a month or more frequently, if needed, accordingto the manufacturer’s specifications.

9. Amalgam, traps and filters should be either shipped to a recycler or collected by a hazardous waste hauler. Youmight consider separating contact amalgam (amalgam that has been in the patient’s mouth) from noncontactamalgam. Recyclers may offer a refund or credit for noncontact amalgam. Keep the recycling and disposaldocumentation for at least three years.

10. Store waste amalgam in a designatedairtight container. Label the con-tainer “Mercury Amalgam:Recyclable Scrap Metal” or equiva-lent. Include the name, addressand phone number of your officeand the date that accumulationstarted. Recyclers will be able toprovide their own shipping anddisinfection guidelines. In the past, dental amalgam scrapmay have been kept under photo-graphic fixer, water or other liquid.If you have been using thismethod, do not pour the liquiddown the drain. Contact your mercury recycler or a hazardouswaste hauler for more informationon how to dispose of this solution.

11. Explore the latest wastewater treat-ment technologies. Certainmanufacturers sell an amalgamseparator which recovers very fineparticles that may wash throughthe standard trap.

3

F I X E R M A N A G E M E N T

Silver recovered from used fixer is a valuable resource. Your office can practice silver recovery by containing usedfixer for off-site recycling or treating the fixer on-site with a silver recovery unit. The Dental Waste Recycler insertidentifies businesses providing both on- and off-site recovery services. Some recyclers may give you a refund orcredit for the recovered silver. If your practice generates only small quantities of fixer, it may be more cost-effectiveand efficient to have the fixer transported off-site for silver removal. By opting for off-site disposal, you are guaran-teed 100% recovery of silver in x-ray fixer. By using radiovisography imaging technology, you may be able to reduceor eliminate fixer use altogether.

OFF-SITE DISPOSALSeveral local vendors offer fixer pick-up services. Some x-ray chemical vendors will transport used fixer to theirfacility, remove the silver and blend the spent fixer with new fixer for reuse. Other companies will transport usedfixer to a centralized recovery facility for silver reclamation.

When storing fixer for off-site treatment or disposal, remember to:1. Collect and store the fixer in a closed plastic container.2. Label the container “Hazardous waste - used fixer” along with the date when fixer was first added

to the container.3. Keep records of the volume and frequency of off-site fixer disposal for a minimum of three years.

ON-SITE TREATMENTYou can purchase or lease a silver recovery unit to remove silver from spent fixer. Canister units are usually suffi-cient for removing silver from small volumes of fixer and can be used alone or in series. Electrolytic units also areavailable and can be followed by a canister to ensure as much silver as possible is recovered. Talk with a silverrecovery service about what will work best for your practice.

After a specified interval, the canister or the plated silver is shipped to a metal reclaimer where the captured silveris recovered.

As a general guideline, the Silver Council, an industry tradegroup, recommends that a business producing less than 10gallons of used fixer per week should have a recovery unitcapable of removing at least 90 percent of silver from the fixer.The treated fixer can be discharged to the drain with permis-sion from the City of Boulder Industrial Pretreatment program.

If your office uses a silver recovery unit, remember to:

1. Check the unit daily for leaks, spills and overflows.2. Periodically check the flow rate of solution to the recovery

system. Typically a lower flow rate and a longer retentiontime will maximize silver recovery.

3. If using an electrolytic unit, check the appearance of the silverplate. The plate should be tan to brown and grainy.If it is black, mushy and smells like sulfur, the amperagemay be too high. If the silver plate is hard and white, the amperage is probably too low. Consult your user’s guidefor specific guidance.

4. Test the silver concentration of the treated fixer monthly.The test can be performed with an analytical test kit or alab analysis. Periodic testing will tell you how effectiveyour unit is at capturing silver and will alert you torecovery unit problems.

Floor drains in

photoprocessing

rooms should be

isolated using stand

pipes, plugs or covers.

Treated fixer

can be discharged

to the drain with

permission from the

City of Boulder

Industrial

Pretreatment

program, 413-7350.

5. Record test results in a silver recovery log.

4

C H O O S I N G A W A S T E H A U L E R O R R E C Y C L E R

Here are some issues to consider when choosing a waste hauler or recycler.

l Will the hauler recover the silver from fixer solutions and mercury from amalgam?

To receive your EPA

identification number,

which is recorded on

hazardous waste manifests,

call the state at (303) 692-3300.

However, Conditionally

Exempt Small Quantity

Generators (CESQGs) are

not required to obtain EPA

identification numbers.

CESQGs can instead write

“CESQG” in the space on the

manifest designated for the

EPA identification number.

In fact, having a separate

identification number may

hinder dentists who share

clinic space from commingling

their like wastes.

l Will you receive a credit or refund for the recovered silver and mercury?

l What is the fate of spent fixer, amalgam or silver recovery units taken or shipped fromyour office?

l Will the hauler provide certification that waste generated by your office is transported,disposed of, or recycled in accordance with all applicable laws and regulations?

l Will the hauler provide containers for holding the waste solution?

l What is the basis of frequency for waste pickup?

CITY OF BOULDER SPECIFIC POLLUTANT LIMITATIONS

METALS

Arsenic

Cadmium

Chromium VI (grab sample only)

Chromium Total

Copper

Lead

Mercury

Molybdenum

Nickel

Selenium

Silver

Zinc

DAILY MAXIMUM (Milligrams/Liter)

0.10

0.10

0.42

5.25

1.2

0.7

0.007

0.09

0.65

0.16

0.10

5.4

PARAMETER LIMITS (STANDARD UNITS)

pH Minimum = 5.5, Maximum = 10.5

5

L I S T O F C O N T A C T S

W a s t e w a t e r D i s c h a r g e

City of BoulderIndustrial Pretreatment Program4049 N. 75th StreetBoulder, CO 80301(303) 413-7350

H a z a r d o u s W a s t e M a n a g e m e n t

Boulder County Health Department3450 BroadwayBoulder, CO 80304Environmental Health: Air Quality, Solid & Hazardous Waste (303) 441-1180

State of Colorado Department of Public Health and Environment4300 Cherry Creek Drive SouthDenver, CO 80222-1530(303) 692-2000Hazardous Materials and Waste Division, Customer Technical Assistance Line (303) 692-3320

U.S. Environmental Protection Agency, Region VIII999 18th Street, Suite 500Denver, CO 80202-2466l-800-227-8917

P o l l u t i o n P r e v e n t i o n

The Silver Council5454 Wisconsin Ave.Chevy Chase, MD 20815(301) 664-5150

Partners for a Clean Environment (PACE)P.0. Box 791Boulder, CO 80306(303) 786-PACE

A program of the City of Boulder, Boulder County, Boulder Chamber of Commerce andBoulder Energy Conservation Center. PACE assists local businesses in saving money throughenvironmental efficiency programs.

H a z a r d o u s W a s t e H a u l e r s

USPCI/ Laidlaw (303) 938-5500Waste Management of Colorado (303) 797-1600Hazrad Services, Inc. (303) 456-9224

D r i n k i n g W a t e r C r o s s C o n n e c t i o n / B a c k f l o w I n f o r m a t i o n

City of Boulder Drinking Water Program5605 N. 63rd StreetBoulder CO 80301 (303) 413-7401

6

D e n t a l W a s t e R e c y c l e r s

Silver Recyclers

Business Name/Address

Environmental Services Inc.4026 S. Parker RoadSuite 132Aurora, CO 80014

Merry X-Ray Chemical1441 W. Bayaud St.Suite 2-ADenver, CO 80223

Picker International3250 Quentin StreetSuite 120Aurora, CO 80014

Rocky Mountain Radiographics9505 N. Tomahawk RoadParker, CO 80134

Safety-Kleen2801 S. Tejon St.Englewood, CO 80110

Bryce Powell(303)761-8614

X

S&H Silver Recovery Verne3060 West 58th Ave. NeuschelerDenver, CO 80221 (303)455-2873

Silver Recovery Inc.604 2nd StreetBerthoud, CO 80513

Jerry Olson(970)532-3456 X

Southwest Radiographics1001 E. 64th Ave.Denver, CO 80229

Leisa Bruner

T. G. X-Ray Ltd.5 South Kalamath StreetDenver. CO 80223

ContactName/Phone

Off-SiteSilverRecovery

SandyFitzgerald(303)690-1414

Phillip Glass(303)698-1701

X

DebbieBrookhaml-800-866-8507x8307

JamesBlackbum(303)841-3561

X

X

In-SiteSilverRecovery

X

X

X

X

X

X

X

Scrap Film Recycling

Comments

X

X

Contact vendor fordetails.

Purchase of materials isrequired to getscrap film pickedup and be in the silver recoveryprogram.

Contact vendor fordetails.

XContact vendor fordetails.

X

X

X

X

X

Generator receivecredit for “highsilver”solutions.

Amalgam and Mercury Recyclers

Business Name/Address

Advanced Environmental RecyclingCorporation2591 Mitchell AvenueAllentown, PA 18103

Phone Materials Accepted

Elemental Loose Amalgam SpillMercury Amalgam in Traps Cleanup

and Filters Materials

(800) 554-2372

X X X X

Amalgaway1002 W. Troy Avenue Indianapolis, IN 46225

(800) 267- 1467

X X X

Bethlehem Apparatus CompanyPO Box YHellertown, PA 18055

(610) 838-7034X X X X

Dental Recycling-North AmericaPO Box 1069Hackensack, NJ 07601

(800) 525-3793X X X

DFG Mercury909 Pitner AvenueEvanston, IL 60202

(847) 869-7800X

Environmental Transloading Services (800) 777-3363654 S Myers Street X X X XLos Angeles, CA 90023

Mercury Refining Company1218 Central AvenueAlbany, NY 12205

(800) 833-3505

X X X X

Recyclights401 West 86th Street Minneapolis, MN 55420

(800) 83l-2852

X X X X

Lead Recyclers*

Business Name/Address

Eastman Kodak Company

Phone/Fax

(8001933-8031

Materials Accepted

Lead Shields

Yes

*Check with local metal recyclers to see if they will accept lead shields.

This list in no way implies the City of Boulder’s endorsement of any particular firm or business. If you know a firm who would like to beadded to this list, please have them contact the City of Boulder’s Industrial Pretreatment program at (303) 413-7350.

C o m p l i a n c e B u l l e t i nColorado Department

of Public Health H a z a r d o u s W a s t eand Environment

P h o t o g r a p h i c , X - r a y a n d D e n t a l W a s t e s

Dental clinics and photography or radiology laboratoriesgenerate relatively small quantities of several types ofhazardous and nonhazardous wastes. There are only twocategories of hazardous waste: listed and characteristic.The Colorado Hazardous Waste Regulations (6 CCR1007-3) list more than 400 hazardous wastes on fourlists. Even if a waste does not appear on the lists, it maybe a characteristic hazardous waste if:

. it is easily combustible or flammable (ignitable);

. it dissolves metals or other materials or burns theskin (corrosive);

. it is unstable or undergoes rapid or violentchemical reaction or produces toxic gases whenmixed with water or other materials (reactive);

. it is a metal, pesticide, herbicide, or organicchemical at high enough concentrations thatcould be harmful or toxic if released into groundwater (toxic).

(6 CCR 1007-3 Part 261)

Many small dental clinics and photography or radiologylaboratories are classified as Conditionally Exempt SmallQuantity Generators (CESQG) of hazardous waste,meaning that they generate less than 100 kilograms (kg)(about 220 pounds or 2.5 gallons) of hazardous waste percalender month (6 CCR 1007-3 Part 261.5). CESQGsare responsible for identifying all hazardous wastes thatthey generate (6 CCR 1007-3 Part 262.11), canaccumulate up to 1000 kg of hazardous waste oh site atany one time, and may either treat their own hazardouswastes or ensure delivery to a facility that is authorized toaccept that hazardous waste (6 CCR 1007-3 Part 261.5 ).Although not required, it is recommended that CESQGsutilize the hazardous waste manifest system andhazardous waste transporters when disposing of theirhazardous wastes.

There are additional requirements for generators of 100kg or more of hazardous wastes per month. Refer to theColorado Hazardous Waste Regulations 6 CCR 1007-3Part 262 and the “Guide to Generator Requirements ofthe Colorado Hazardous Waste Regulations,” availablefrom the Colorado Department of Public Health andEnvironment for more information.

HAZARDOUS WASTES

The most common sources of hazardous wastes generatedby dental clinics and radiology laboratories include:

. Fixer - contains silver, DO 11

. Undiluted developer - corrosive, D002

. Lead foil, dental bite wings, discarded leadshields - contain lead, D008

. Amalgam - contains silver & mercury, DO 11,D009

. Dental trap filter wastes - contain lead, silver,mercury, D008, D009, DO 11

. Some cleaners for developer systems - containchromium, D007

. Old X-ray equipment - may contain PCBs,regulated under the Toxic Substances ControlAct (TSCA)

(6 CCR 1007-3 Part 261.24)

Recycling

SilverSilver from used film, fixer, and paper is a valuableresource that should be recycled. These wastes may beclassified as hazardous wastes depending on theconcentration of silver (6 CCR 1007-3 Part 261.24).There are essentially two ways to recover the silver, eitherrecycling onsite or collecting it for an offsite recyclingservice to pick up. Onsite recycling is generally limited toused fixer, rather than film or paper. The generator caninstall a silver recovery unit (electrolytic units,recirculating electrolytic units, and cartridges) at the endof the x-ray or film processing unit. The recovered silvercan then be sold to a metal reclaimer and the treated fixerdisposed of down the drain with prior permission ofpublic wastewater treatment authority (6 CCR 1007-3Part 100.21). Facilities that have individual septicdisposal systems should not dispose of this material downthe drain, as it can harm the septic system. They shouldcontract with an industrial wastewater disposal companyto dispose of these wastes.

For offsite recycling, the generator should collect andstore used fixer in a closed plastic container. Although

-over-

not required for CESQGs, it is good management practiceto label this container with the words “Hazardous Waste-Used Fixer” and the date that the fixer was first added tothe container. When enough used fixer has beenaccumulated, the ‘generator can arrange pick-up by therecycling service. The recycling service will reclaim thesilver from the used fixer at the recycler’s site. Many willoffer this service for used film and paper as well.

LeadLead from lead foil, bite wings, and discarded lead shieldsmay be recycled as scrap metal through scrap metalrecyclers, through some silver recyclers, or contact yourdental supply company for recycling assistance (6 CCR1007-3 Part 261.6(a)(3)).

Amalgam and dental trap wastesAmalgam containing silver and mercury may be sentoffsite for recycling along with dental trap wastes thatcollect amalgam particles and some lead scraps (6 CCR1007-3 Part 261.6(a)(3)). Check with your recycler tomake sure they are willing to take both amalgam and leadwastes. These particulates should be collected in a closedcontainer compatible with the waste. It is goodmanagement practice for the CESQG to label thecontainer as “Hazardous Waste-Amalgam and DentalTrap Wastes” and mark it with the accumulation startdate. When a sufficient amount has been collected, theoffsite recycler should be contacted for pick-up. Used andempty amalgam capsules may be disposed of as solidwaste with the regular trash.

Disposal

Hazardous wastes that cannot be recycled or are disposedof rather than recycled have to be disposed of ashazardous wastes. This includes chromium-basedcleaners for developer systems and unused developer.Some wastes, such as unused developer (corrosive), maybe treated by the generator and disposed of down thedrain with prior approval of the wastewater treatmentauthority (6 CCR 1007-3 Part 100.2 1). The generatorshould contact a hazardous waste disposal company forassistance. Oils containing PCBs and PCB-containingequipment with greater than 50 ppm PCBs are regulatedunder the Toxic Substances Control Act by theEnvironmental Protection Agency (EPA) (40 CFR Part761). Contact the EPA Region VIII offices for assistanceon PCB management.

NON-HAZARDOUS WASTES

DeveloperUsed or diluted developer is a non-hazardous waste andcan often be flushed down the drain with the permission

of the public wastewater treatment authority. Facilitiesthat are on individual septic disposal systems should notpour this material down the drain because it can harm theseptic system. They should contract with an industrialwastewater disposal company for disposal of thesewastes.

Infectious WastesBlood on swabs or dressings and used sharps (needles,probes, etc.) are considered non-hazardous infectiouswastes (25- 15-401 CRS). Infectious wastes arc a special(solid) waste in Colorado that require special handlingprior to disposal (6 CCR 1007-2 Section 1.2). Properlylabeled and packaged infectious wastes can be disposed ofwithout treatment if it is acceptable to the waste haulerand disposal site (6 CCR 1007-2 Section 13 .8).Infectious wastes that have been rendered non-infectiousmay be mixed with the regular trash. The use of atreatment method recommended by EPA guidance forinfectious waste management is usually accepted asappropriate treatment (25- 15-404 CRS, 6 CCR 1007-2 Section 13.8.3). Contaminated sharps must be placedin a puncture-resistant rigid container and treated prior todisposal; untreated containers of sharps cannot becompacted (6 CCR 1007-2 Section 13.8.4).

For more information please contact:

Colorado Department ofPublic Health & Environment

Hazardous Materials andWaste Management Division

4300 Cherry Creek Drive SouthDenver, Colorado 80222-1530

Customer Technical Assistance (303) 692-3320

E-mail comment.hmwmd @ state.co.ushttp://www.cdphe.state.co.us/hmi/

This Compliance Bulletin is intended to provide guidance on theappropriate management of wastes based on Colorado solid andhazardous waste statutes and regulations only. The wastes described inthis guidance may also be regulated under other statutes andregulations. 7/97 CHW-012

Printed on recycled paper