Are you amalgam separator compliant yet?
By July 2020, nearly every dental office in the U.S. needs to be compliant with updated amalgam waste handling regulations.

Key Points
* Dentists are encouraged to follow dental best management practices for amalgam waste handling and disposal.
* The EPA requires amalgam separators to achieve at least a 95% removal efficiency.
* The EPA final rule on amalgam separators is effective as of July 14, 2017, and the date for compliance is July 14, 2020.

Background
In 2017, the Environmental Protection Agency (EPA) issued a final rule, Effluent Limitations Guidelines and Standards for the Dental Category (40 CFR 441; see Federal Register document link), to reduce discharges of mercury and other metals from dental offices into POTW facilities. The rule requires dental offices to comply with requirements that are based on the ADA's best management practices, including the use of amalgam separators.  ADA directs dental practices to manage waste in a manner consistent with the association's Best Management Practices for Amalgam Waste, which were developed to reduce the amount of mercury entering the environment. 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.

You don’t have separator installed yet?

Existing office - If you don’t have a separator today, you must be in compliance (i.e., install a separator) by July 14, 2020, unless your office is in one of the states where it is already mandatory.

Newly opened dental office (on or after July 14, 2017) - You MUST become compliant immediately.  You must install a separator immediately.

What about Reporting Requirements?

Existing and new sources must submit a one-time compliance report to their pretreatment Control Authority.

* If your dental office is in Alabama, Connecticut, Mississippi, Nebraska or Vermont, then your Control Authority is your state agency.
Dental offices in all other states should contact your EPA regional office, your local wastewater utility, or your state agency Pretreatment Coordinator to find out who your Control Authority is.  Pretreatment Program Contacts

Already have a separator installed?
If you already have a separator today, you should regularly monitor the unit and replace it and dispose of it properly when it’s full.  If the unit isn’t full, you theoretically have 10 years before you should replace it, although most offices replace it much sooner.

Think you are EXEMPT from this regulation? You are EXEMPT if:
You a dentist exclusively practicing in one of these specialties: 

1. Oral pathology
2. Oral + maxillofacial radiology
3. Oral + maxillofacial surgery
4. Orthodontics
5. Periodontics
6. Prosthodontics
7. You operate a mobile dental unit OR you discharge your wastewater into a private septic system.
8. You do not place and/or do not remove amalgam except in limited emergency or unplanned, unanticipated circumstances and can attest as such.