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ADA amalgam separator principles

February 24, 2015 The 2010 ADA House of Delegates by unanimous consent adopted principles that should be used to develop a mandatory national pretreatment standard for dental office wastewater.

"Resolved, that the appropriate agencies of the ADA engage the United States Environmental Protection Agency in a negotiated rulemaking process regarding a national pretreatment standard for dental office wastewater, and be it further

"Resolved, that the following principles guide the Association's position in any negotiations with the United States Environmental Protection Agency:"

  1. Any regulation should require covered dental offices to comply with best management practices patterned on the ADA's best management practices (BMPs), including the installation of International Organization for Standardization (ISO) compliant amalgam separators or separators equally effective;
  2. Any regulation should defer to existing state or local law or regulation requiring separators so that the regulation would not require replacement of existing separators compliant with existing applicable law;
  3. Any regulation should exempt dental practices that place or remove no or only de minimis amounts of amalgams;
  4. Any regulation should include an effective date or phase-in period of sufficient length to permit affected dentists a reasonable opportunity to comply;
  5. Any regulation should provide for a reasonable opportunity for covered dentists to repair or replace defective separators without being deemed in violation of the regulation;
  6. Any regulation should minimize the administrative burden on covered dental offices by (e.g.) primarily relying upon self-certification (subject to verification or random inspection) and not requiring dental-office specific permits;
  7. Any regulation should not include a local numerical limit set by the local publicly owned treatment works (POTW);
  8. Any regulation should not require wastewater monitoring at the dental office, although monitoring of the separators to assure proper operation may be required, and
  9. Any regulation should provide that compliance with it shall satisfy the requirements of the Clean Water Act unless a more stringent local requirement is needed.