The EPA has promulgated Pretreatment Standards to reduce mercury discharges from dental offices into publicly owned treatment works (POTWs). These Pretreatment Standards are in a regulation codified at 40 Code of Federal
A detailed macro view of a human molar tooth, showcasing a shiny silver amalgam filling.
Regulations Part 441 and titled Dental Office Point Source Category (the “Dental Rule”). The Dental Rule became effective on July 14, 2017.
If your Colorado dental practice places or removes amalgam (even in limited emergency or unplanned, unanticipated circumstances) and discharges to a POTW without an approved Pretreatment program (an “unapproved Pretreatment area”), you must submit a One‑Time Compliance Report to the EPA.
What the Dental Rule requires:
- Install an ISO 11143‑compliant amalgam separator (or equivalent device).
- Follow Best Management Practices:
- Do not use oxidizing or chlorine line cleaner chemicals.
- Ensure all amalgam process wastewater — including from chair‑side traps, screens, vacuum pump filters, dental tools, cuspidors, or collection devices — is treated through the amalgam separator.
One‑Time Compliance Report:
Dental offices are required to complete and submit a One‑Time Compliance Report to the control authority. A control authority is a POTW approved by the EPA to implement a Pretreatment program. If you discharge to a POTW without an approved Pretreatment program, the EPA is your control authority. Existing sources should have submitted the report by October 12, 2020, or within 90 days of any transfer of ownership; new sources must submit within 90 days of introducing wastewater to a POTW.
If you have not yet submitted your One-Time Compliance Report, please do so promptly to avoid potential federal enforcement. Complete this report in full — do not leave any fields blank — and submit it by email or mail.
How to submit:
By mail:
EPA Region 8
Attn: Althea Mirabella
1595 Wynkoop Street
8ECA-W-N
Denver, CO 80202
By email:
mirabella.althea@epa.gov
(303) 312-6026
Unsure of your status? If you are not certain whether you are located in an approved pretreatment area or whether your office has already submitted a report, contact Althea Mirabella via email or phone (see contact information above) and she can confirm your location and reporting status.
