On June 14, 2017 the United States Environmental Protection Agency (EPA) released a new rule related to dental offices, 40 CFR Part 441 Dental Effluent Guidelines.
Summary of Dental Rule
What is the Dental Rule?
- Requires dental offices that discharge wastewater containing amalgam to POTWs to install, inspect, and maintain a dental amalgam separator.
- Requires the implementation of two BMPs.
- 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 6 or greater than 8.
- Published in Federal Register on June 14, 2017.
- EPA estimates annual cost incurred by dental office: avg. of $800 annually
Who is affected by the Dental Rule?
- Applies to: Dental offices, Dental schools, Dental Clinics, and Government operated dental facilities
- Does not apply to one or more of the following practices exclusively: Oral pathology, oral & maxillofacial radiology/surgery, orthodontics, periodontics, or prosthodontics and mobile units.
- All Dental Offices must submit compliance information regardless of excluded practices or not
What kind of amalgam separator is required?
- Amalgam separator(s) compliant with ISO11143 (2008); or, ANSI /ADA 108-2009: TA 2011
- Amalgam separator(s) must achieve at least 95% removal efficiency.
When will this rule affect dental offices?
- The effective date of this rule is July 14, 2017.
- New dental offices must return a Compliance Report within 90 days following the introduction of wastewater to the sanitary sewer.
- Transfer of ownership must return a Compliance Report within 90 days after a transfer of ownership.
- Existing dental offices must return a Compliance Report no later than October 12, 2020.
- Existing separator(s) or devices must be replaced by July 14, 2027 or the end of service life (whichever is sooner) with a compliant amalgam separator.
What steps are needed to be taken to come into compliance?
- Install new amalgam separator(s) in offices that do not currently have one.
- Inspect existing models to make sure they are up to the standard.
- Establish internal documentation tracking procedure related to the inspection and maintenance of your amalgam separator(s).
- Malfunctioning amalgam separator(s) must be repaired or replaced no later than 10 business days after the malfunction is discovered by dental discharger or an agent or representative of the dental discharger.
- All dental offices must complete a Compliance Report for Dental Discharges.
- Dental dischargers must retain a copy of the compliance report, maintenance log, and records.
EPA FAQs on the Dental Office Category Rule
Mercury BMP Compliance Report
Additional Separator Form
Amalgam Separator Inspection Log
Mercury BMP Form Instructions
Dental Amalgam Disposal Flyer
For additional information, please email firstname.lastname@example.org.