Dental Amalgam Rule

DENTAL AMALGAM RULE AND REPORTING REQUIREMENTS FOR DENTAL OFFICES

EPA’s 40 CFR 441-DENTAL OFFICE POINT SOURCE CATEGORY

EPA passed the Dental Office Point Source Category on June 14, 2017. The ruling requires all dental offices to install and maintain amalgam separators if they discharge to a Publicly Owned Treatment Works (POTW). The ruling came into effect on July 14, 2017. All dental offices are to be compliant with the ruling by July 14, 2020.

Exemptions to the rule:

40 CFR 441 does not apply to offices that are only oral pathology, oral and maxillofacial radiology, oral and maxillofacial surgery, orthodontics, periodontics, or prosthodontics.

40 CFR 441 does not apply to offices that do not discharge to POTWs and operate their own wastewater treatment plant with a sanitary discharge permit through the LDEQ. However, should your sewage treatment plant be pumped out by an authorized sewage sludge hauler at any time and hauled to a POTW, an amalgam separator WILL BE REQUIRED.  See your specific permit coverage for any additional LDEQ-imposed requirements for handling mercury.

Requirements for Dental Offices that Use Mercury Amalgam:

• Dental offices that discharge to POTWs that do not place or remove amalgam need to submit a One-Time Certification.

• Existing dental offices that place or remove amalgam must operate and maintain an amalgam separator and must not discharge scrap amalgam or use certain kinds of line cleaners. They must also submit a One-Time Compliance Report by October 12, 2020.
  
  • Existing amalgam separators, which do not meet EPA specifications, may be operated for their lifetime or ten years, whichever comes first. When a separator needs replacement, or the ten-year period has ended and the separator does not meet the standard of the final rule, a dental office must replace it with one that meets the requirements of the final rule.

• New dental dischargers (dental offices that begin operating on or after July 14, 2017) must comply with the rule immediately and submit a One-Time Compliance Report within 90 days of commencement of discharge.

• These reports are only required per practice. Therefore, if more than one dentist is associated with a practice only ONE report is required.

Compliance Deadlines:

• For existing dental dischargers, a One-Time Compliance Report must be submitted no later than October 12, 2020, or 90 days after a transfer of ownership.

• For new dental dischargers, a One-Time Compliance Report must be submitted no later than 90 days following the introduction of wastewater into a POTW.

Compliance Report Submittal:

Do you pay your water/sewer bill to one of the below municipalities? If so, you are required to submit a compliance report to that municipality.  Please use the city-specific compliance reports below.  If no report is available as of yet, please contact the city staff for instructions.  Below are the contacts and mailing addresses to submit your reports. Please also submit a copy of the report to LDEQ at the address below.

Don’t see your city listed?

Your reports are required to be submitted back to LDEQ. Please address all reports to the following:

Have questions?

Please contact Ms. Rachel Davis at 225-219-3515 or at rachel.davis@la.gov.

Associated Links:

Frequently Asked Questions: https://www.epa.gov/sites/production/files/2017-12/documents/dental-office-category_frequent-questions_nov-2017.pdf

Final EPA Rule: https://www.federalregister.gov/documents/2017/06/14/2017-12338/effluent-limitations-guidelines-and-standards-for-the-dental-category

Effluent Guidelines: https://www.epa.gov/eg/dental-effluent-guidelines