Under a federal rule adopted by the EPA in 2017, many dental practices will need an installed amalgam separator by July 14, 2020.
Under a federal rule adopted by the Environmental Protection Agency in 2017, many dental practices will need an installed amalgam separator by July 14, 2020. The new standards under the Clean Water Act are consistent with the state level Amalgam Rule and aim to prevent the mercury contained in dental amalgam from entering the air, water, and land.
To comply with the rule, offices must install an amalgam separator by Jul 14, 2020. The installed separator must be compliant with either the American National Standards Institute (ANSI) American National Standard/American Dental Association (ADA) Specification 108 for Amalgam Separators (2009) with Technical Addendum (2011) or the International Organization for Standardization (ISO) 11143 Standard (2008) or later versions so long as the version requires at least a 95 percent removal efficiency.
Additionally, offices must submit a one-time compliance report by October 12, 2020. Dental offices starting business after July 14, 2017, must complete and submit the report within 90 days of accepting patients.
If your office is served by a municipality with a pretreatment sewer program, you must submit your compliance form to the respective pretreatment control authority. A list of municipal forms are provided below:
If your office is NOT served by a municipal pretreatment program, you must submit your Department of Ecology compliance report by mail to your regional Department of Ecology office. You can find your regional office here.
Recordkeeping Requirements
Dental practices must keep a copy of the completed compliance report on record for the lifetime of dental practice ownership. Practices must also maintain a record of any reports filed, a visual inspection log, documentation of repair or replacement, disposal records, and the manufacturer’s current operating manual for the device for at least 3 years.
Exemptions
The majority of dental offices must comply with the rule regardless of whether they place amalgam. However, offices that do not place dental amalgam, and do not remove dental amalgam except in limited emergency or unplanned, unanticipated circumstances are exempt from further requirements as long as they submit a one-time compliance report certifying their exempt status. Dental offices that exclusively practice in the following specialties are exempt from the rule: oral pathology, oral and maxillofacial radiology, oral and maxillofacial surgery, orthodontics, periodontics, and prosthodontics.
Additional resources: