Dental Amalgam Rule - Deadline is October 12, 2020
In compliance with the Clean Water Act, the United States Environmental Protection Agency has adopted Dental Effluent Guidelines to reduce the amount of toxic metals entering the sanitary sewer system. The Dental Office Category regulation can be found in 40 Code of Federal Regulations (CFR) Part 441.
The compliance report deadline is October 12, 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.
EXEMPT DISCHARGERS
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 and maxillofacial radiology
- Oral and maxillofacial surgery
- Oral pathology
- Orthodontics
- Periodontics
- Prosthodontics
BEST MANAGEMENT PRACTICES
The following best management practices must also be implemented.
- 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 a POTW.
- Dental unit water lines, chair-side traps and vacuum lines that discharge amalgam process wastewater to a POTW must not be cleaned with oxidizing or acidic cleaners, including but not limited to bleach, chlorine, iodine and peroxide that have a pH lower than six (6) or greater than eight (8). Such line cleaners are prohibited because they may lead to the dissolution of solid mercury when cleaning chair-side traps and vacuum lines.
REPORTING REQUIREMENTS
Dental offices that place or remove amalgam must operate and maintain an amalgam separator and must not discharge scrap amalgam or use certain kinds of line cleaners. All dental dischargers, even those that do not place or remove amalgam, must submit a One-Time Compliance Report to SD1. The
One-Time Compliance Report must be submitted no later than October 12, 2020.
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).
RECAP: STEPS TO COMPLIANCE
- Submit One-Time Compliance Report by October 12, 2020
- Follow best management practices
- Retain disposal and equipment service records
- Notify SD1 of any change in ownership
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