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Budget office reviews EPA separator proposal

June 06, 2014

By Craig Palmer

Washington—The Environmental Protection Agency submitted a draft proposed rule to the White House Office of Management and Budget for review of pretreatment standards for existing and new dental practices that discharge dental amalgam to publicly owned treatment works.

The draft rule, titled Effluent Guidelines and Standards for the Dental Point Source Category, is under review by the OMB. The OMB notice at, EPA/WATER RIN: 2040-AF26 Publication ID: Spring 2014, said the affected sectors include dental laboratories and offices of dentists.

The ADA supports a national separator mandate in accordance with common sense principles established by Association policy and patterned on ADA best management practices(

The language of the draft regulation is not a matter of public record, and the Association was unable to review it as the OMB review process began. A notice of proposed rulemaking could follow OMB review and initiate an EPA rulemaking process. The EPA declined to share the draft proposal with the Association.

The OMB abstract of the draft proposal said, "EPA is developing pretreatment standards for pollutant discharges from dental offices. When dentists place or remove amalgam fillings, mercury and other contaminants are flushed into the sewer. Dental amalgam contains mercury and other metals that have the potential to pass through or interfere with municipal wastewater treatment at publicly owned treatment works. The EPA's technology assessment will focus on best management practices, such as use of amalgam separators, as a regulatory requirement."

The EPA in 2010 announced its intention to issue a national pretreatment rule applicable to wastewater discharges from dental offices. The EPA May 30 announced on that a Dental Amalgam Effluent Guideline was submitted to the OMB for interagency review.

ADA Business Resources selected HealthFirst of Mountlake Terrace, Washington, as its exclusive endorsed provider for amalgam separators and amalgam recovery services for ADA members. The company's chief compliance officer, Dr. Don Cohen, said of amalgam disposal, "Ultimately, reducing mercury pollution is a good thing for everyone." He added that he sees a silver lining where organized dentistry can potentially address EPA concerns preemptively, ahead of a ruling. "There is still time for us to take matters into our own hands and show that we are environmentally responsible members of our communities," he said.