Amalgam separator requirement in effect July 14

Dr. Kevin Nelson
Dr. Nelson
Peoria, Ill. — General dentist Kevin T. Nelson never considered the outflow of amalgam waste from his solo dental practice to be an environmental hazard.

But then he learned something from an earlier ADA News story on amalgam separators that quoted the Environmental Protection Agency’s website: “Although most dental offices currently use some type of basic filtration system to reduce the amount of mercury solids passing into the sewer system, dental offices are the single largest source of mercury at sewage treatment plants.”

He reconsidered.

“I suppose the net effect of all the area dental offices could have an environmental effect, or at least that’s what the EPA tells us,” he said. “So if the government mandates amalgam separators, then we’d better comply.”

He complied and installed a separator just in time for the EPA’s amalgam separator requirements to go into effect July 14.

The rule mandates that most dental offices install, maintain and monitor an amalgam separator. Dentists may continue to operate an already installed amalgam separator for its lifetime or 10 years (whichever comes first), as long as they comply with the other rule requirements including specified best management practices, operations, maintenance, reporting and record-keeping requirements.

Newly purchased or built offices must comply within 90 days of taking ownership.

Dental offices must submit a compliance report and have maintenance and inspection records available. Dentists can utilize the ADA’s amalgam decision tree flowchart (PDF) to determine how to comply.

Dentists should note that the agency issued a policy in April that said it would not levy penalties temporarily for noncompliance resulting from the pandemic.

“Regulated entities are expected to make every effort to comply with all applicable requirements,” according to an EPA FAQ about the temporary enforcement policy. Further, the EPA considers seven days’ notice sufficient to terminate the applicability of the policy, and may also terminate it sooner in some locations than others, depending on the recommendations of state and local public health departments.

The ADA Practice Resource team has additional information available for member dentists looking for more resources at

The HealthFirst Rebec Environmental CatchHG amalgam separator has earned the endorsement of ADA Member Advantage. HealthFirst offers ADA-member pricing on the Rebec Environmental CatchHG amalgam separator and discounts on HealthFirst’s Amalgam Recovery Program. For more information on the HealthFirst Amalgam Recovery Program, visit the HealthFirst website.