G ove r n men t Re lat ions
The EPA final rule on amalgam separators became effective July
14, 2017. The rule mandates that most dental offices that
discharge wastewater into a publicly owned treatment work
(POTW) must install, maintain and monitor an amalgam
separator that complies with one of the following:
1) American National Standards Institute (ANSI) American
National Standard/American Dental Association (ADA)
Specification 108 for Amalgam Separators (2009) with
Technical Addendum (2011)
2) International Organization for Standardization (ISO) 11143
Standard (2008)
3) Subsequent versions - as long as the separator achieves
at least 95% removal efficiency
The compliance date for existing sources (existing practices)
subject to the rule is July 14, 2020. New sources (newly
purchased or constructed practices) are subject to the rule
immediately, and must comply within 90 days of taking
ownership.
Offices that already have a separator installed may continue to
operate their existing separator for its lifetime or 10 years (July
14, 2027), whichever comes first, as long as the office complies
with the other rule requirements.
Dental practices will be required to submit a one-time
compliance report and retain a copy of the filed report for the
lifetime of practice ownership. Dental practices that are
exempt from the rule due to specialty, or because they do not
discharge waste into a POTW (mobile units or offices with
private septic systems) do not need to file these reports.
One-time compliance reports must be submitted to your
Control Authority. In Pennsylvania, the Control Authority will
either be the local POTW or the EPA regional office, depending
on whether the local POTW has an EPA approved pretreatment
program. Contact your local POTW or EPA regional office to find
out who your Control Authority is.
Your Control Authority will also determine the form used to
submit your report.
Offices with installed amalgam separators are also required to
comply with the following in office procedures:
1) Monitor the separator according to manufacturer’s
guidelines.
2) Inspect installed separators at least once a month to ensure
proper operation and maintenance of the separator.
3) Replace/Repair any malfunctioning separators according to
manufacturer instructions within 10 business days of
discovering the defect.
4) Maintain separators by replacing amalgam retaining
cartridges, separator canisters or units as directed by the
manufacturer, or annually, whichever comes first.
5) Do not discharge waste amalgam from chair-side traps,
screens, vacuum pump filters, dental tools, cuspidors, or
collection devices to a POTW. In other words, no flushing
waste down the drain.
6) Do not use oxidizing, acidic cleaners when flushing dental
unit water lines, chair-side traps and vacuum lines.
Therefore, do not use bleach, chlorine, iodine or peroxide
cleaning agents that have a pH of lower than 6 or higher
than 8.
7) Install the separator unit so that it receives all amalgam
process wastewater and that it is sized to incorporate all
wastewater that may pass through it.
In addition, dental practices must retain any records of the
following for a three-year time period (with the exception of
the One-Time Compliance Report that must be retained for the
duration of ownership of the practice):
1) Any reports filed.
2) A visual inspection log - including documentation of the
date, person(s) conducting the inspection, the results
of each inspection and a summary of follow-up actions,
if needed.
3) Documentation of any repair or replacement - including the
date, person(s) making the repair/replacement, a description
of the repair/replacement and documentation of amalgam
retaining contai