Dental Office Regulations
On June 14, 2017, the United States Environmental Protection Agency (USEPA) promulgated pretreatment standards to reduce discharges of mercury from dental offices into publicly owned treatment works (POTWs). The Dental Office Category regulation is codified at 40 CFR Part 441.
All dental offices within the DELCORA service area 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. Please note, this regulation applies to all dental offices that may not be direct customers of DELCORA but whose wastewater ultimately flows to DELCORA for treatment.
The amalgam separator must comply with one of the following:
- American National Standards Institute (ANSI) American National Standard/American Dental Association (ADA) Specification 108 for Amalgam Separators (2009) with Technical Addendum (2011)
- International Organization for Standardization (ISO) 11143 Standard (2008)
- Subsequent versions – as long as the separator achieves at least 95% removal efficiency
The following offices are exempt from installing an amalgam separator:
- Offices that exclusively practice at least one of these specialties: oral pathology; oral & maxillofacial radiology; oral & maxillofacial surgery; orthodontics; periodontics; prosthodontics
- Mobile dental units or offices that discharge wastewater into a private septic system
- Offices that do not place amalgam and only remove amalgam in limited, emergency or unanticipated circumstances (estimated less than 5% of procedures per year)
Offices with installed amalgam separators are also required to comply with the following:
- Monitor the separator according to manufacturer’s guidelines
- Inspect separators at least once a month to ensure proper operation and maintenance of the separator
- Replace/Repair any malfunctioning separators according to manufacturer instructions within 10 business days of discovering the defect
- Maintain separators by replacing amalgam retaining cartridges, separator canisters or units as directed by the manufacturer, or annually, whichever comes first
- 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.
- Do not use oxidizing, acidic cleaners when flushing dental unit water lines, chair-side traps and vacuum lines. Do not use bleach, chlorine, iodine or peroxide cleaning agents that have a pH of lower than 6 or higher than 8.
- Install the separator unit so that it receives all amalgam process wastewater and that it is sized to incorporate all wastewater than may pass through it.
In addition, dental practices must retain any records of the following for a 3 year time period:
- Any reports filed
- Visual inspection log – including the date, person(s) conducting the inspection, the results of each inspection and a summary of follow-up actions (if needed)
- Any repair or replacement- including the date, person(s) making the repair/replacement, a description of the repair/replacement and documentation of the amalgam retaining container replacement (including date)
- Disposal records – including all dates that collected dental amalgam is picked up or shipped for proper disposal, and the name of the permitted or licensed treatment, storage or disposal facility receiving the amalgam retaining containers
- Manufacturer’s current operating manual for the device in place
To verify compliance with this requirement, DELCORA has developed a mandatory one-time compliance reporting form that must be submitted by all new and existing dental offices. Once the form is completed and returned to DELCORA, the DELCORA pretreatment staff will evaluate its completeness to determine the need for follow-up evaluation and/or an onsite inspection. Completeness of this form is imperative and failure to submit may result in further regulatory oversight and requirements. A copy of the one-time compliance reporting form must also be retained onsite.
Dental offices existing before June 14, 2017 that are subject to this regulation must achieve compliance no later than July 14, 2020. Newly constructed or purchased dental offices established after July 14, 2017, must have achieved compliance immediately and submit a one-time compliance report no later than 90 days of operation.
For more information, please contact the DELCORA pretreatment department via email at pretreatment@delcora.org.
Additional References
The Academy of General Dentistry: https://www.agd.org/docs/default-source/advocacy-papers/finalized-epa-amalgam-separator-frequently-asked-questions.pdf?sfvrsn=e6aa76b1_0
The American Dental Association (ADA): https://www.ada.org/en/advocacy/advocacy-issues/dental-amalgam
United States Environmental Protection Agency (USEPA): https://www.epa.gov/eg/dental-effluent-guidelines