It depends on the volume of amalgam that your practice removes. Dentist offices that do not place or remove amalgam except in “limited circumstances” as a frequency of less than five percent of their procedures, would be exempt from further requirements of the rule. In this case, the dentist office would only need to file a one-time compliance report. Additional data obtained from page 27163 of the 2017 Federal Register for “Effluent Limitations Guidelines and Standards for Dental Category” also states that if a dentist office removes 9 cases or less of amalgam per year, an amalgam separator may not be needed.

In accordance with the final rule issued by EPA on June 14, 2017, a separate amalgam separator is not required for every chair. The final rule does include cost analysis for multiple chair offices. However, the rule also contends that over time, amalgam may no longer be used in dental offices as usage is decreasing about 2% each year. Whether you decide to furnish each chair with an amalgam separator likely depends on your practice. If you do not place amalgam and only remove amalgam sporadically, your need for chairs fitted with amalgam separators will likely be diminished. Some amalgam systems can be centrally located and service multiple chairs while other systems are designed for single chairs. Some states may require an amalgam separator for each chair so be sure to check with your state regulatory authorities.

The EPA estimates that amalgam separators and affiliated services will cost dental offices on average approximately $800 per office per year for one amalgam separator (in 2016 dollars). The charges are listed “per year” to average out the cost of an amalgam separator, as the devices may function for approximately a decade and then need to be exchanged. Prices will vary depending on how often the filter needs to be replaced, contract services such as removal and disposal, and other factors. As always, volume discounts will allow for more economical costs.

Best management practices:

1) Prohibit the discharge of waste (or scrap) into the water ways. Flushing waste amalgam from chair-side traps, screens, vacuum pump filters, dental tools, or collection devices into drains is prohibited.

2) Prohibit the use of line cleaners that may lead to the dissolution of solid mercury when cleaning chair-side traps and vacuum lines. Those cleaners include but are not limited to bleach chlorine, iodine, and peroxide that have a pH lower than 6 or greater than 8.

The final rule allows dental offices to continue to operate existing amalgam separators for its lifetime or ten years (whichever comes first), if the dental discharger complies with the other rule requirements including the specified BMPs, operation and maintenance, reporting, and recordkeeping requirements. Once the separator needs to be replaced or the ten-year period has ended, dental offices will need to replace the amalgam separator with one that meets the requirements of the final rule.

Dental practices that are in the process of changing ownership will be required to notify the District Engineering department of the change of ownership to complete and submit an Application for Service. The practice will also need to contact the District Industrial Pretreatment Program Coordinator so a new One-Time Compliance Report applicable to the new practice can be recorded and file by the District.