Dental amalgam rule

This page is under construction, pending information will be updated in March.

Effective July 14, 2017 the U.S. EPA adopted Effluent Limitations Guidelines and Standards for the Dental Category Final Rule to reduce the discharge of mercury-containing amalgam from dental practices into publicly owned treatment works (POTWs). (40 CFR Part 441).

What dental facilities are impacted by the rule?

Dental offices, schools and clinics where dentistry is practiced that discharge to a publicly owned treatment work (POTW) (e.g., municipal sewage system) are subject to this rule. It does not apply to mobile units or to offices where the practice of dentistry consists only of the following dental specialties: oral pathology, oral and maxillofacial radiology, oral and maxillofacial surgery, orthodontics, periodontics, or prosthodontics.

What do affected dental facilities need to do?

In order to comply with the regulation, dental offices must-- 

  • operate and maintain an amalgam separator compliant with ISO11143 (2008)
  • avoid discharging scrap amalgam or oxidizing or acidic cleaners with a pH less than 6 or greater than 8, such as bleach, chlorine or peroxide; and
  • certify their practice's compliance with the regulation by submitting a one-time compliance form

Existing Sources (those discharging prior to July 14, 2017) must be in compliance with the standards by July 14, 2020 and submit a one-time compliance report certifying such by October 12, 2020.

New Sources (those starting discharging to the sewer after July 14, 2017) must be in compliance with the standards immediately and submit a one-time compliance report certifying such within 90 days after the first discharge to a POTW. If your facility is a new source that has been operating for more than 90 days and has not yet submitted a one-time compliance form, please submit as soon as possible.

 

Submit the one-time compliance form online

or mail to

Kansas Environmental Assistance Program

2323 Anderson Ave., Suite 300

Manhattan, KS 66502

 

Questions? Check the frequently asked questions or contact us at amalgamrule@ksu.edu or (800) 578-8898

Summary of Dental Amalgam Rule

Best Management Practices

Dental Effluent Guidelines

Fact Sheet: Effluent Limitations Guidelines and Standards for Dental Offices.

Effluent Limitations Guidelines and Standards for the Dental Category.

American Dental Association-- Amalgam Separators and Waste Best Management.

 

Summary of dental amalgam rule

What is the dental rule?1

  • the rule requires dental offices discharging wastewater that contains dental amalgam to publicly owned treatment works (POTWs) to install, inspect, and maintain a dental amalgam separator.
  • the rule requires implementation of two best management practices (BMPs).
  • the rule was published in the Federal Register by the EPA on June 14, 2017.
  • EPA estimates costs incurred by dental offices will be an average of $800 annually.

Why are  standards  needed?1

  • Mercury from waste amalgam can end up in the environment from the POTW through incineration, landfilling, or land application.
  • Mercury, a component of waste amalgam, is a potent neurotoxin that causes wide range of health issues.

 

Who is  affected  by  the  dental  rule?1

 Applies to:

  • dental offices
  • dental schools
  • dental clinics
  • government operated dental facilities

 Does NOT apply to:

  • mobile units
  • practices consisting ONLY of these specialties: oral pathology, oral and maxillofacial radiology/surgery, orthodontics, periodontics or prosthodontics.

What kind of  amalgam  separator is  required?2

  • An amalgam separator must be compliant with ISO11143 (2008).
  • The ISO Standard is incorporated into the current American National Standards Institute’s (ANSI)/American Dental Association’s (ADA) Standard 108-2009 for Amalgam Separators.
  • Amalgam separator must achieve 95 percent removal efficiency and meet the standards by June14 2027.

When will this  rule affect  dental offices?2

 The effective date of this rule is July 14, 2017.

 NEW dental offices--

  • MUST return one-time compliance Report within 90 days following introduction of wastewater to the sanitary sewer.

 TRANSFER OF OWNERSHIP:

  • MUST return one-time compliance report within 90 days of a transfer of ownership.

 

What steps  need to be  taken to come  into  compliance?

  • Install a new amalgam separator in offices that do not currently have one.
  • Inspect existing amalgam separators to make sure they are up to standard.
  • Establish internal documentation tracking procedures related to the inspection and maintenance of your amalgam separator.
  • Follow the ADA’s best management practices for handling dental amalgam.
  • Complete the one-time compliance report for dental discharges. It MUST be returned to your control authority (city or KDHE via SEAP). Retain a copy of this report on site for the duration of your practice/ownership.

*Taken and adapted with permission from Water Utilities Department, Arlington, Texas

1. U.S. Environmental Protection Agency. Fact Sheet: Effluent Limitations Guidelines and Standards for Dental Offices.

2. U.S. Environmental Protection Agency. Effluent Limitations Guidelines and Standards for the Dental Category.

 

Best management practices         

 Do:

  • Use pre-capsulated alloys and stock capsule-size variety.
  • Recycle used disposable amalgam capsules.
  • Salvage, store, and recycle non-contact amalgam.
  • Salvage contact amalgam pieces from restorations after removal and then recycle contents.
  • Recycle teeth containing dental amalgam restorations and verify whether or not teeth need disinfection.
  • Manage amalgam waste through recycling as much as possible.
  • Use line cleaners that minimize dissolution of amalgam.

 Don’t:

  • Use bulk mercury.
  • Put used disposable amalgam capsules into biohazard containers.
  • Put non-contact amalgam waste in biohazard containers, infectious waste containers or regular garbage.
  • Rinse devices containing amalgam over drains or sinks.
  • Dispose of extracted teeth that contain amalgam restorations in biohazard containers, infectious waste containers, sharps containers, or regular garbage.
  • Flush amalgam down the drain/toilet.
  • Use bleach or chlorine-containing cleaners to flush wastewater lines.

*Based on the American Dental Association’s Amalgam Waste Best Management Practices

 

 

K-State Pollution Prevention Institute
(800) 578-8898 | sbeap@ksu.edu
2323 Anderson Ave., Suite 300, Manhattan, KS 66506