Since July 14, 2020, most dental offices that place or remove amalgam have had to comply with the EPA's Dental Office Category rule (40 CFR Part 441), often called the "Dental Rule" or "amalgam separator rule." Its goal is to keep mercury out of municipal sewers. It requires offices to capture amalgam waste and recycle it.
Who it applies to
The rule applies to dental offices that discharge wastewater to a public sewer system and that place or remove dental amalgam. Some offices are exempt: offices that practice exclusively oral pathology, oral and maxillofacial radiology, oral and maxillofacial surgery, orthodontics, periodontics or prosthodontics; mobile units; and offices that don't place amalgam and remove it only in limited emergency or unplanned circumstances. That last group still has to file a one-time certification with its control authority. Your local sewer authority (the "control authority") is the final word on your status.
The compliance checklist
- ☐ Amalgam separator installed. It must meet ISO 11143 (2008) or ANSI/ADA Specification 108 with at least 95% removal efficiency, or be an equivalent device that removes at least 95% of amalgam solids.
- ☐ Separator inspected and maintained according to the manufacturer's schedule, and repaired or replaced promptly if it fails.
- ☐ No scrap amalgam down the drain.
- ☐ Line cleaners that aren't oxidizing or acidic. Don't clean chairside traps, vacuum lines or dental unit water lines with oxidizing or acidic cleaners such as bleach, chlorine, iodine or peroxide, or with any cleaner that has a pH below 6 or above 8.
- ☐ One-Time Compliance Report submitted to your control authority. Existing offices had to file by October 12, 2020. New offices file within 90 days of first discharging to the sewer, and a new report is due within 90 days after a change of ownership. Keep the report for as long as the office operates.
- ☐ Records kept for at least three years: separator inspections (date, who inspected, results and follow-up), amalgam container replacements, the dates amalgam waste was picked up or shipped and the name of the facility that received it, separator repairs or replacements, and the manufacturer's operating manual for your device.
ADA best practices for amalgam waste
- Recycle amalgam waste as much as possible: separator contents, chairside traps, vacuum pump filters, non-contact scrap and contact amalgam.
- Don't put extracted teeth with amalgam restorations in biohazard (red bag) containers, sharps containers or the regular trash.
- Use precapsulated alloys, and stock a range of capsule sizes to cut down on scrap.
The easy way to recycle: mail-back pails
BulbCycle's 2-Gallon Dental Waste Disposal Pail holds up to 2 lbs of dental amalgam plus 24 lbs of other dental waste, including separator filters, traps and lead foil. Collect waste in the pail, ship it back with the prepaid label, and keep the recycling documentation with your Dental Rule records.
Still developing film? Our 2-Gallon Dental Fixer Recycling Pail handles used x-ray fixer solution. See all dental waste disposal kits.
No account, no pickup to schedule, and free shipping. Questions? Call (858) 412-6536 or email info@bulbcycle.com.
This article is general information, not legal advice. Sources: EPA Effluent Guidelines for the Dental Category (40 CFR Part 441, including 441.10, 441.30 and 441.50); American Dental Association, Amalgam Separators and Waste Best Management Practices.
