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Dentals and New Amalgam Rule

Dentals and New Amalgam Rule
On July 14, 2017, the EPA (Environmental Protection Agency) signed into law the Dental Amalgam Categorical Standard (40 CFR 441). Pursuant to the standard, all “Existing Sources” and "New Sources" are subject to the new rule and must achieve the following pretreatment standards no later than July 14, 2020:
(1) Installation, operation, and maintenance of one or more amalgam separators that meet the requirements:

(i) 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 (IS) 11143 Standard (2008) or subsequent versions so long as that version requires amalgam separators to achieve at least a 95% removal efficiency.  Compliance must be assessed by an accredited testing laboratory under ANSI’s accreditation program for product certification or a testing laboratory that is a signatory to the International Laboratory Accreditation Cooperation’s Mutual Recognition Arrangement.  The testing laboratory’s scope of accreditation must include ANSI/ADA 108-2009 or ISO 11143. In addition to installing the amalgam separator, you will need to comply with all requirements as outlined in 40 CFR 441.30 Pretreatment Standards for Existing Sources.  Once the separator has been successfully installed you will need to contact our offices to schedule an inspection and complete a One-Time Compliance Report.  A maintenance log will be issued during the inspection and it will be the facility’s responsibility to maintain a record of the name of the third-party service provider that maintains the amalgam separator(s) or equivalent device(s) operated at the dental office.  You will also need to adhere to the following Best Management Practices (BMP’s) as outlined in 40 CFR 441.30 Pretreatment Standards for Existing Sources: 
(b) Implementation of the following Best Management Practices (BMPs):

(1) 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 discharged to a POTW.

(2) Dental unit waterlines, chair-side traps, and vacuum lines that discharge amalgam process wastewater to a POTW must not be cleaned with oxidizing or acidic cleaners, including but not limited to bleach, chlorine, iodine, and peroxide that have a pH lower than 6 or greater than 8. The dental dischargers, as agent or representative of the dental discharger, must maintain and make available for inspection in either physical or electronic form, for a minimum of three years: 
(1) Documentation of the date, the person(s) conducting the inspection, and results of each inspection of the amalgam separator(s) or equivalent device(s), and a summary of follow-up actions, if needed.

(2) Documentation of amalgam retaining container or equivalent container replacement (including the date, as applicable).

(3) Documentation of all dates that collected dental amalgam is picked up or shipped for proper disposal in accordance with 40 CFR 261.5(g)(3), and the name of the permitted or licensed treatment, storage or disposal facility receiving the amalgam retaining containers.

(4) Documentation of any repair or replacement of an amalgam separator or equivalent device, including the date, person(s) making the repair or replacement, and a description of the repair or replacement (including the make and model).
Where applicable, your facility will need to complete the following documentation and return it to the SGRWRF Pretreatment Department at the following address:
Attn: Pretreatment Department
3780 W. 1550 W. 
St. George, Utah 84770
Dental New Source PDF - 07-20-2020 View Download
Dental One-Time Compliance Report PDF - 07-20-2020 View Download
Dental Amalgam Questionnaire PDF - 07-20-2020 View Download
Weekly Amalgam Separator Visual Log PDF - 07-20-2020 View Download