Dental Practice Amalgam Separator Requirements & Support
Environmental Services
The City of Petaluma Environmental Services team is dedicated to pollution prevention, stormwater management, and protecting City infrastructure. We offer resources and information to help maintain the health and wellness of our community by preventing pollution in our sewer and storm collections systems. If you have a stormwater concern, please call the Environmental Services line at (707) 776-3777 or email [email protected].
Dental Practice Amalgam Separator Requirements & Support FAQs
- What is Dental Amalgam?
- Why is mercury challenging to remove from Ellis Creek Water Recycling Facility (ECWRF)?
- What is an Amalgam Separator Device?
- Why does an Amalgam Separator Device need to be installed?
- Who needs to install an Amalgam Separator Device?
- Who has the authority to regulate the Amalgam Separator Device?
- What if the landlord or another dental practice oversees the maintenance of the Amalgam Separator Device?
- How does the City know that the mercury from its WWTP is from dental practices?
- What is an amalgam waste container or amalgam bucket?
- Why is the disposal of amalgam waste in red bag waste or garbage receptacles prohibited?
- What is inspected?
- What documentation needs to be available for review?
- How is compliance determined?
- What if the inspector determines the dental practice is not in compliance?
What is Dental Amalgam?
Dental amalgam is a filling material used to restore teeth affected by cavities or decay. It is a mixture of metals, including liquid mercury (about 50 %), combined with a powdered silver, tin, and copper alloy.
Why is mercury challenging to remove from Ellis Creek Water Recycling Facility (ECWRF)?
- Mercury does not break down in the environment; instead, it accumulates in water bodies, sediments, and organisms. Once released, it can persist for long periods, making removal challenging.
- Even at low concentrations, mercury is highly toxic. Wastewater Treatment Plants (WWTP) are not designed to detect or effectively remove such trace levels, making compliance with strict regulatory limits difficult.
- Standard WWTP processes (e.g., sedimentation, biological treatment) are not designed to target mercury. Some mercury may settle out with biosolids, but dissolved mercury remains in treated effluent.
- Mercury can bind to sludge during treatment, but if the sludge is not properly handled, incinerated, or disposed of in a secure landfill, the mercury can re-enter the environment.
What is an Amalgam Separator Device?
An amalgam separator, defined by the U.S. Environmental Protection Agency (EPA), is designed to capture and remove dental amalgam waste from wastewater before it enters the public sewer system. The purpose of these separators is to reduce the discharge of mercury and other metals found in amalgams into the environment. https://www.epa.gov/eg/dental-effluent-guidelines
Why does an Amalgam Separator Device need to be installed?
An amalgam separator must be installed as required by 40 CFR Part 441 (the EPA’s Dental Office Category Rule) to reduce the discharge of mercury and dental amalgam waste into the public water system. This regulation aims to protect the environment by preventing mercury from entering wastewater treatment plants, where it can accumulate and pose a risk to human health and aquatic life. https://www.ecfr.gov/current/title-40/chapter-I/subchapter-N/part-441
Who needs to install an Amalgam Separator Device?
All dental offices that discharge wastewater into WWTP and place or remove dental amalgam must install an Amalgam Separator Device.
Exceptions:
- Dental facilities that exclusively practice one or more of the following:
- Oral pathology
- Oral and maxillofacial radiology
- Oral and maxillofacial surgery
- Orthodontics
- Periodontics
- Prosthodontics
- Offices that only perform diagnostic or preventive services
- Mobile dental units
- Dental dischargers that do not place dental amalgam and do not remove amalgam except in limited emergency or unplanned, unanticipated circumstances and that certify such to the Control Authority
- Practices that are not connected to the City’s sewer collection system
Who has the authority to regulate the Amalgam Separator Device?
- U.S Environmental Protection Agency (EPA)
- State and the Local Municipalities (ex. City of Petaluma)
- American National Standards Institute (ANSI) and International Standards Organization (ISO)
- Occupational Safety and Health Administration (OSHA)
- State Dental Boards and Associations
What if the landlord or another dental practice oversees the maintenance of the Amalgam Separator Device?
Each dental practice is responsible for ensuring that an approved amalgam separator has been installed for a shared vacuum system. Communicate with the other dental practices and building owners and determine who will be responsible for installation and maintenance of the separator.
How does the City know that the mercury from its WWTP is from dental practices?
According to the EPA, dentistry is the single largest source of mercury discharged to a WWTP, accounting for approximately 50% of total mercury entering the municipal wastewater system.
What is an amalgam waste container or amalgam bucket?
According to the EPA, the container or bucket is specifically designed, airtight, and properly labeled container used for the collection, storage, and disposal of dental amalgam waste.
Items that should be deposited in an amalgam waste container include:
- Non-contact amalgam (scrap amalgam)
- Contact amalgam (e.g., extracted teeth with amalgam restorations)
- Amalgam sludge from chairside traps, vacuum filters, and separators
- Spent amalgam capsules
- Chairside traps and vacuum filters
Amalgam waste containers must be disposed of as hazardous waste material that goes to the proper facility for disposal.
Why is the disposal of amalgam waste in red bag waste or garbage receptacles prohibited?
Red bag waste may require incineration. In incineration, mercury volatilizes and becomes an air pollutant. It may also eventually end up in surface water.
If the amalgam is disposed of with other garbage, the mercury may end up in the landfill leachate, eventually contaminating groundwater or surface water.
Inspections
Under normal circumstances inspections are scheduled ahead of time with the dentist, office manager, or whoever manages the amalgam separator system.
The City aims to inspect dental facilities every three (3) years.
Depending on the size of the practice, it should take 30 to 45 minutes.
What is inspected?
The amalgam separator is inspected to verify:
- If the amalgam separator is correctly installed according to the 40 CFR Part 441
- If the amalgam separator is connected to the sanitary sewer
- What type of amalgam separator is installed and if it meets the required ANSI/ADA or ISO rating
- The amalgam levels inside the amalgam separator cartridge
- The most frequently used amalgam separators have lines on the separator cartridge that denotes when the separator has met full capacity and is no longer effectively collecting amalgam
The amalgam waste container:
- Contents that should be deposited inside the amalgam waste container for disposal include:
- Non-contact amalgam
- Contact amalgam
- Amalgam sludge from chairside traps, vacuum filters, and separators
- Spent amalgam capsules
- Used chairside traps and vacuum filters
- Proper labeling of the amalgam container will be verified
The vacuum line cleaner:
- Federal regulations require vacuum line cleaners that are used by dental facilities to have a pH between 6-8 SU.
- Cleaners outside the range can lead to leaching of captured mercury from the amalgam separator.
- Oxidizing or acidic cleaners (Ex. bleach, chlorine, iodine, and peroxide) are strictly prohibited to use as a vacuum cleaner.
What documentation needs to be available for review?
- Maintenance records for the amalgam separator and amalgam waste container for the last three (3) years
- Staff training records for handling and disposal of amalgam waste
- SDS for the vacuum line cleaner
How is compliance determined?
The following items will be inspected to verify compliance:
- The amalgam separator is installed adequately according to manufacturer specifications
- The loading level on the amalgam separator does not exceed the limits per manufacturer specifications
- The most frequently used amalgam separators have lines on the separator cartridge that denotes when the separator has met full capacity and is no longer effectively collecting amalgam
- Contents inside the amalgam waste container
- Proper label on the amalgam waste container
- Dental practice staff have records of training to handle amalgam waste and disposal
- Amalgam separator and container records for the last three (3) years
- Vacuum line cleaner type used
- Type of X-ray machine
If the dental practice is found in compliance with the items above, the facility would receive a passing inspection with no further requirements.
What if the inspector determines the dental practice is not in compliance?
Below are the types of actions that may be issued by an inspector if it’s determined corrections need to be made at the dental practice:
- Warning - If the inspector determines that one of the items in the above “How is compliance determined?” section does not meet compliance.
- Ex. missing staff training logs, missing paperwork for amalgam separator or container
- Corrective Action – If the inspector identifies a piece of equipment damaged or broken that is associated with the amalgam separator.
- Ex. vacuum line connected to the amalgam separator is leaking
- Ex. red bag is used to dispose of amalgam waste
- Ex. pH line cleaner is out of the allowable range
- Fail – If the inspector determines that the amalgam separator or container is out of compliance.
- Ex. the amalgam separator is over the fill line limit according to the manufacturing limit
- Ex. missing amalgam container
- Ex. amalgam scrap is disposed of in the garbage
