Dental Amalgam Program


In compliance with the Clean Water Act, the US Environmental Protection Agency has adopted Dental Effluent Guidelines to reduce discharges of mercury and other metals from dental offices into publicly owned treatment works. The rule will only regulate dental offices that place or remove amalgam. The Dental Office Category regulation can be found in 40 CFR Part 441. The compliance date for most offices will be October 2020.

What is dental amalgam?

Dental amalgam is the mixture of mercury, silver, tin and copper which is used to fill cavities caused by tooth decay.

Who is exempt?

Dental dischargers that do not place dental amalgam, and do not remove amalgam except in limited emergency or unplanned, unanticipated circumstances, are exempt. The following offices are also exempt: oral pathology, oral and maxillofacial radiology, oral and maxillofacial surgery, orthodontics, peridontics and prosthodontics.

Best Management Practices

Waste amalgam, including but not limited to dental amalgam from chair-side traps, screens, vacuum pump filters, dental tools, cuspidors or collection devices must not be discharged to SD1.

Dental unit water lines, chair-side traps and vacuum lines that discharge amalgam-process wastewater to SD1 must not be cleaned with oxidizing or acidic cleaners, including but not limited to bleach, chlorine, iodine or peroxide that has a pH lower than 6 or greater than 8 (i.e. cleaners that may increase the dissolution of mercury).

Reporting Requirements

All dental dischargers, even those that do not place or remove amalgam, must submit a One-Time Compliance Report to SD1. New sources must submit the completed form within 90 days of the introduction of wastewater to the publicly owned treatment works. For existing sources, the One-Time Compliance Report must be submitted no later than October 12, 2020, or 90 days after a transfer of ownership.

Dental dischargers must maintain and make available for inspection in either physical or electronic form, for a minimum of three years:
  • Documentation of the date, person(s) conducting the inspection and results of each inspection of the amalgam separator(s) or equivalent device(s), and a summary of follow-up actions, if needed.
  • Documentation of amalgam-retaining container or equivalent container replacement (including the date, as applicable).
  • Documentation of all dates that collected dental amalgam is picked up or shipped for proper disposal in accordance with 40 CFR 261.5(g)(3), and the name of the permitted or licensed treatment, storage or disposal facility receiving the amalgam retaining containers.
  • Documentation of any repair or replacement of an amalgam separator or equivalent device, including the date, person(s) making the repair or replacement and a description of the repair or replacement (including make and model).
  • Dental dischargers, or an agent or representative of the dental discharger, must maintain and make available for inspection in either physical or electronic form the manufacturer's operating manual for the current device.

Recap: Steps to Compliance

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