Amalgam Separator Compliance - Colorado Dental Association

Based on regulations adopted by the Environmental Protection Agency (EPA), dental practices are required to submit one-time compliance reports to attest to the installation of amalgam separators and adhere to best management practices (BMPs) for amalgam waste. Even if your dental practice is exempt from installing an amalgam separator, you may be required to file a one-time compliance report.

Existing dental practices have a deadline of July 14, 2020 to install a compliant amalgam separator. The one-time compliance report must be filed by October 12, 2020. However, new dental practices and those who transfer ownership have been required to be compliant since July 14, 2017. In those jurisdictions that have approved pretreatment programs, dental practices must file this one-time compliance report directly with the control authority. In other jurisdictions, dental practices will file directly with the EPA.

Are You in Compliance?

Install a compliant amalgam separator

(DEADLINE: July 14, 2020 for existing dental practices; already in effect for new dental practices)

RESOURCES:

Confirm with your separator supplier that the separator is compliant with ANSI/ADA Specification 108 (2009/2011) or ISO 11143 Standard (2008)
An already installed amalgam separator in your practice is grandfathered if it does not meet the above standards until June 14, 2027 or the unit’s replacement date, whichever comes first
Offices exempt from installing an amalgam separator include:
- Specialties of oral pathology, oral and maxillofacial radiology, oral and maxillofacial surgery, orthodontics, periodontics or prosthodontics
- Mobile dental unites
- Dentists on septic systems
- Dentists who do not place amalgam and only remove amalgam in unplanned or emergency situations (must be less than 5% of procedures performed in the office)
Even if your office is exempt form installing an amalgam separator, you may still be required to file a compliance report with your wastewater district.
SolmeteX is the CDA’s endorsed amalgam separator distributor and provides CDA member pricing. SolmeteX provides amalgam separators, installation support and waste disposal/recycling services. Get more information.

Implement applicable BMPs

(DEADLINE: July 14, 2020 for existing dental practices; 90 days after installation for new dental practices)

Monitor and maintain the unit according to the manufacturer’s recommendations. Keep copies of the separator’s user guide and maintenance manual on file. These should be available through your supplier.
Inspect at least once per month to ensure proper operation and maintenance of the separator, including confirmation that amalgam process wastewater is flowing through the retaining cartridge, separator canister, or amalgam separating portion of the amalgam separator (preventing bypass). Keep a log of these inspections.
Maintain the unit by replacing the amalgam retaining cartridge(s), separator canister(s), or separator unit(s) as specified by the manufacturer’s operating manual or whenever the collection of retained solids reaches the manufacturer’s stated design capacity, whichever comes first. Keep records of all maintenance including container replacement, repairs, system replacement and waste disposal.
Replace or repair the unit within 10 business days if any malfunction is detected.
Do not discharge waste amalgam including, but not limited to, dental amalgam from chair-side traps, screens, vacuum pump filters, dental tools, cuspidors, or collection devices, to a publicly owned treatment work (a POTW, otherwise known as a municipal sewage treatment plant). In short, this means no flushing waste down the drain.
Do not clean or flush dental unit water lines, chair-side traps, and vacuum lines 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.
Install the separator unit such that it:
- receives all amalgam process wastewater
- is sized to incorporate all wastewater that may pass through it

RESOURCES:

ADA webinar
ADA guidelines
Download the employee training log and visual inspection log, or visit www.solmetex.com/dentalcerts.

File compliance report with relevant wastewater district or EPA

(DEADLINE: October 12, 2020 for existing dental practices; already in effect for new dental practices)

Check your wastewater bill to identify your wastewater district
Complete the applicable form (see next section) and submit to the district based on the submission instructions provided
If your wastewater district has regulations beyond the EPA rule, be sure to comply. Additional regulations are noted in CDA resources, as we are aware of them. Contact your district with any related questions.
One-Time Compliance Reports must be updated within 90 days after transfer of practice ownership.
Keep a copy of any compliance reports filed in your business records for the lifetime of your businesses.

GENERAL RESOURCES:

ADA Amalgam Separator Compliance Resources

Compliance Forms and Contacts

Compliance form
Guidance document

Please return completed and signed form to Rhonda Barton, via mail at:
3036 Environmental Drive
Fort Collins, CO 80525

or fax to: 970-221-6938

or email to: rbarton@fcgov.com

Contact information:
Rhonda Barton
Industrial Pretreatment Specialist
970-221-6938 (phone)
970-221-6970 (fax) rbarton@fcgov.com

Additional Requirements:
Federal regulations require existing dental facilities to comply with applicable obligations by July 14, 2020. New dental facilities must comply immediately according to the Rule. However, City of Fort Collins City Code [Section 26-340(e)] does not differentiate between new and existing dental facilities; all dental facilities that place or remove amalgam are required to have an ISO 11143 certified amalgam separator in place and follow outlined Best Management Practices.

Compliance form

The original signed form MUST be submitted via U.S. mail, common courier or hand delivered to:
Bill Thomas
Pretreatment Coordinator
Loveland Water and Power
200 North Wilson Avenue
Loveland, CO 80537

Additional Standards:
(Not mandatory unless a facility has issues maintaining appropriate documentation) The City has recommended dental facilities create a 3-ring binder to hold specific information required of the dental regulation, such as, but not limited to:
- The One-Time Compliance Report form.
- The Amalgam Separator Operation’s Manual.
- The Safety Data Sheet for the line cleaner.
- Inspection/Maintenance log for the past three years.

Contact Information:
Bill Thomas
bill.thomas@cityofloveland.org
970-962-3719

Compliance form

Original reports must be submitted via US Mail (no electronic copies or photocopies will be accepted) to:
Metro Wastewater Reclamation District
6450 York Street
Denver, CO 80229

Additional Standards:
Refer to the Metro District’s Rules & Regulations, Section 6.16.1, Dental Amalgam Control Program (link on website), for additional BMP requirements, including: Staff amalgam-handling training and documentation, scrap amalgam disposal, and the prohibition of bulk mercury. All dental facilities within our service area will be inspected for compliance.

Contact Information:
Suzanne Renter
IP Sector Investigator II
303-286-3128
srenter@mwrd.dst.co.us

Compliance form
Best Management Practices

Submit to:
Security Sanitation District
Pretreatment Department
231 Security Blvd.
Security, CO 80911

Additional Standards:
Dental BMPs are a required action of all dental facilities in the District as well as the annual submission of self-inspection form.

Contact Information:
Chris Scott, Pretreatment Coordinator
Security Sanitation District
Phone: 719-392-7844
Fax: 719-392-0916
c.scott@securitywsd.com