It is each office's responsibility to make sure they comply with the 2017 regulations (40 CFR 441) by the due dates.
- New offices (those opening after July 14, 2017) are required to be in compliance upon opening.
- Existing offices (those in operation before July 14, 2017) are required to meet compliance by July 14, 2020 and to submit a one-time compliance report by October 12, 2020.
Find out more about the regulation at the EPA website.
Do you install or replace dental amalgam?
- If the answer is "No" or "Only in Emergencies", you qualify for an exemption from the regulations if you complete a one time exemption report. Signed hardcopies only please.
- If the answer is "Yes", you are designated as a DIU (Dental Industrial user) status and must comply with the regulation.
Requirements for Dental Industrial Users (DIUs)
- Install an ISO or ANSI-compliance amalgam separator before the July 14, 2020 due date.
- Correct any problems or deficiencies within 10 business days if the amalgam separator does not work properly.
- Replace the amalgam separator as recommended by the manufacturer. Complete routine inspections and maintenance. (You will need a copy of the manufacturer's operating manual to find when the unit needs to be replaced and the frequencies and types of maintenance required.)
- Maintain documentation for at least 3 years. Document any inspections, repair, container replacement and waste disposal. These documents shall be made available to the City during inspections or as required.
- Best Management Plan: Do not use oxidizing or acidic cleaners that can dissolve amalgam. (see below)
- Best Management Practices (BMPs): Do not discharge or flush scrap amalgam down any drains. (see below)
- File a one-time compliance report with the Industrial Pretreatment Program stating that you are in compliance with the regulation (hard copy only please). Update this report within 90 days of any change in ownership
- Operating Manuals for Solmetex Units can be found at their website: https://www.solmetex.com/support/
- Operating Manuals for Rasch Units can be found at their website: http://www.amalgamseparation.com/
More Info for DIUs:
- One-Time Compliance Reports will be mailed to all existing DIUs in 2020.
- Do you have an older model amalgam separator installed that doesn't meet the new ISO Standard? You may qualify for the "grandfather clause" under 40 CFR 441.
- Dental Labs are exempt from the regulation. No reporting required for the labs that already filled out the 2017 survey.
Best Management Practices (BMPs)
The new regulation includes a BMP that prohibits the use of oxidizing or acidic cleaners in equipment that discharges to the separator (such as chairside traps and vacuum lines).
Why? Because these oxidizing cleaners (like those containing bleach) can break down the amalgam particles collected in the separator resulting in mercury discharges to the sewer. Acidic cleaners (those with low pH) can also hinder the operation of the separator.
The regulation does not prohibit the use of these cleaning agents in equipment connected to the water supply (hand pieces, ultrasonic scalers or air/water syringes). The prohibition in the regulation was not intended to prohibit
the safety of the water that the dentists uses. If you choose to use these cleaners on the water supply equipment, it
would be best to direct the discharge of cleaning wastes to a sink that is not served by the amalgam separator.
You can read more about the effects line cleaners have on amalgam separators from the ADA published research: The Effect of Disinfectants and Line Cleaners on the Release of Mercury from Amalgam. Research information on the cleaning products you use. You can also ask your amalgam separator distributor about recommended products.
The second BMP in the regulation requires is that waste amalgam including, but not limited to, dental amalgam from chair-side traps, screens, vacuum pump filters, dental tools, cuspidors or collection devices, must not be discharge to the sewer.
This BMP may seem obvious, but many times, we see people clean out a trap by rinsing it into a nearby sink. If the sink is not attached to the amalgam separator, this is now illegal. If the sink is served by a separator, you are needlessly filling up the separator capacity with wastes you have already treated using the screen.
The ADA has more information on the proper disposal of waste amalgam at www.ada.org/en/membercenter/