The US Environmental Protection Agency (EPA) Dental Effluent Guidelines (40 CFR 441) took effect on July 14, 2017. Dentists that place or remove amalgam are required to install amalgam separators and follow two Best Management Practices (BMPs). Existing dentists have three years to comply with the new regulations, but new facilities that start discharging after the effective date need to comply immediately. In both situations, the dental practice will need to submit a One-Time Compliance Report to Regional San.
Information here is specific to dental facilities located in the Regional San service area. Click here to determine if you are in Regional San’s service area. Please contact your local sewer agency for their requirements and One-Time Compliance Report form.
The regulations and information from the EPA can be found at the following links:
Dentists who place or remove amalgam must install an amalgam separator and implement BMPs.
This includes institutions, permanent or temporary offices, clinics, home offices, and Federal, state, or local government owned and operated facilities
Dentists who never place amalgam and do not remove amalgam except in limited unplanned, unanticipated circumstances (estimated to be less than 5% of removals) must certify as such but do not have to install an amalgam separator or implement the BMPs.
The following dentists are exempt from this regulation:
Dentists that exclusively practice one or more of the following specialties: oral pathology, oral and maxillofacial radiology, oral and maxillofacial surgery, orthodontics, periodontics, or prosthodontics
Mobile units providing services in multiple locations
Dentists that do not discharge amalgam wastewater to the sewer
What is required?
Installation of an appropriately sized amalgam separator compliant with one of the following:
ANSI American National Standard/ADA Specification 108 for Amalgam Separators (2009) with Technical Addendum (2011) or subsequent versions with a minimum 95% removal efficiency
ISO 11143 Standard (2008) or subsequent versions with a minimum 95% removal efficiency
An equivalent device may be used if it meets the requirements listed in 40 CFR 441.30(2)
Implementation of the following BMPs:
Waste amalgam must not be discharged to the sewer
Oxidizing or acidic cleaners, including but not limited to bleach, chlorine, iodine, or peroxide cleaners or cleaners with pH lower than 6 or greater than 8, must not be used to clean dental unit wastewater lines, chair-side traps, and vacuum lines
When is compliance required?
No separator and not exempt?
If discharge from your facility started after July 14, 2017, comply immediately and submit a One-Time Compliance Report within 90 days
If discharge from your facility started before July 14, 2017, comply by July 14, 2020, and submit a One-Time Compliance Report no later than October 12, 2020
Maintain the following documents for a minimum of three years:
Documentation of amalgam retaining unit replacement
Documentation of any repair or replacement of the amalgam separator
Manufacturer’s operating manual
For hazardous waste questions in Sacramento County, contact the Sacramento County Environmental Management Department, Environmental Compliance Division at (916) 875-8550, or in West Sacramento contact the Yolo County Environmental Health Division, Hazardous Materials Programs at (530) 666-8646.
Continuing Compliance Requirements
Inspect the amalgam separator according to the manufacturer’s operating manual
Repair or replace a malfunctioning amalgam separator within 10 days of being discovered
Replace the amalgam retaining units in accordance with the manufacturer’s schedule or when it has reached the maximum level, whichever comes first
Regional San is working to reduce mercury discharges to the Sacramento River, and the dental community is part of the solution! Improperly disposed mercury can find its way into Sacramento waterways and the environment. In water, mercury can be converted to methylmercury, a more toxic pollutant. Methylmercury then accumulates in some fish making them potentially harmful for people to eat.
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