Dental Amalgam Rule Compliance Deadline July 2020 Implementation Resources on MDA web page


n June 14, 2017, the U.S. EPA final- ized technology-based pretreat- ment standards under the Clean

Water Act to reduce discharges of mercury and other metals from dental offices into municipal sewage treatment plants known as publicly owned treatment works (POTWs). Compliance with those standards is this July. The federal rule requires dental offices to comply with requirements based on the ADA’s recommended practices, including the use of amalgam separators. You can find this rule and supporting documents at the MDA web page “EPA Dental Amalgam Rule: Missouri DNR Implementation” at modental. org/moamalgam which was created last year.

In general, the rule places dental facilities in two categories: new or existing (that remove and replace dental amalgam). Basic require- ments for these are: • A new dental facility that commenced operation on or after July 14, 2017 must 1) have an amalgam separator installed from the onset of seeing patients; and, 2) within 90 days of the first discharge to the POTW, submit a one-time compli- ance report (OTCR).

• An existing dental facility established prior to July 14, 2017 must 1) submit an OTCR before October 12, 2020; and, 2) have a compliant amalgam separator or equivalent device installed by July 17, 2020. If an existing facility has an equiv- alent device, it must install a compliant separator by July 14, 2027, or when the equivalent device breaks down.

More details on the basic requirements of EPA Dental Amalgam Rule are found in the Dental Amalgam Rule Facts section, “What are the basic requirements of the rule?” at

The Missouri Department of Natural Resources (MoDNR) implemented EPA’s Dental Amalgam Rule by using the new rule as guidelines, and have informed the regu- lated community (municipalities with POTW state-approved pretreatment programs)

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how to best interpret the new rule. Many POTWs with state-approved pretreatment program responsibilities have implemented an outreach effort to contact dental facilities regarding the need to comply with the rule.

For POTWs with state-approved pretreat- ment programs, the responsibility for seeking compliance with the dental amalgam rule rests with these local POTW authorities. Any subsequent enforcement action related to noncompliance with the rule also rests with these POTW authorities. In this case, to submit a OTCR, contact the local POTW authority or “control authority” for a form, or see “Where do I get a one-time compliance report” in the Dental Amalgam Rule Facts section at To determine whether your municipality is the control authority for you dental amalgam pro- cess wastewater discharge, see “Who is the control authority?” and the “State Approved

Pretreatment Programs” sec- tion.

For POTWs without state-approved pretreat- ment program responsibilities, MoDNR acts as the control authority. For assistance in determining whether MoDNR is your control authority, see “Who is the control authority?” For those dental facilities that discharge to a POTW without a state-approved program, the MoDNR’s OTCR form is available online at

For compliance assistance with the EPA Dental Amalgam Rule, contact your local POTW authority or MoDNR under “Contact Information” also listed on the MDA page. If you have additional questions after reviewing this article and the web page at modental. org/moamalgam, call 800-361-4821 or 573- 751-6825. f

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