Effective July 17, 2017, all dental offices that place or remove amalgam are required to have an amalgam collection, separation, and recycling program in place, as stipulated in the EPA’s “Effluent Limitations Guidelines and Standards for the Dental Category” Rule.
Do You Need a New Amalgam Separator?
Existing offices without an Amalgam Separator: According to the EPA's Dental Effluent Guidelines, if your dental office does not yet have an amalgam separator, you will need to purchase and install one by July 14, 2020.
Existing offices with an Amalgam Separator: If your existing amalgam separator does not meet the EPA Rule’s standard (ISO 11143) or doesn’t capture 95% of the mercury and other metals present in the amalgam used for fillings, you have 10 years before you need to replace it—sooner if your current separator is retired before then.
New dental offices: New dental offices must have a compliant amalgam separator installed when they open for business.
How to Comply with the EPA Dental Amalgam Rule
In addition to installing an effective amalgam separator in your office, you must follow these two best management practices for amalgam waste:
Do not discharge scrap amalgam waste to publicly owned treatment works (POTWs).
Do not use line cleaners with a pH level higher than 8 or lower than 6.
How to Demonstrate Compliance with the EPA Dental Amalgam Rule
To prove compliance with the EPA’s Rule, you will need to complete a one-time compliance report (similar to this sample dental office compliance report, download as a .docx file) including information on your facility and a certification that your dental discharger meets requirements. Dental offices that don’t place or remove amalgam must also complete a compliance report stating as much. These reports must be submitted to a control authority—a local wastewater utility, a state environmental agency, or a U.S. EPA regional office, depending on where your office is located.
Dental offices in Alabama, Connecticut, Mississippi, Nebraska, and Vermont should submit their reports to their corresponding state EPA contact. Dental offices in all other states will need to find out who their control authority is from the appropriate EPA pretreatment program contact.
Amalgam separator maintenance: Amalgam separator cartridges must be replaced periodically based on the manufacturer's guidelines and the size of your practice. Amalgam cartridges and amalgam containers must be returned to a safe recycling and disposal company that will provide a compliance certificate with each shipment. Certificates must be retained to prove compliance.
DuraPro Health recommends medentex as the best value for amalgam compliance. Practices with 1-4 treatment chairs will only need to replace the cartridge once per year. Containers with pre-paid labels are included, making this solution easy and much less expensive than most other solutions.
Who is Exempt from the EPA Dental Amalgam Rule?
Several kinds of dental practices are exempt from the EPA rule, including mobile dental units and practices that primarily perform these procedures:
Oral and Maxillofacial Radiology
Oral and Maxillofacial Surgery