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EPA Dental Regulation Implementation Period:
ALL dental practices are required to install either a ISO 11143:2008 certified amalgam separator or a certified ANSI/ADA Standard No.108 amalgam separator, both at a separation rate of 95%.

  • New dental practices have 90 days to install an amalgam separator.
  • Existing dental practices have until July 14, 2020 to install an amalgam separator.
  • Existing dental practices who already have an amalgam separator installed have until July 14, 2024 to install an amalgam separator that meets all the regulation requirements.  

The dental rule applies to offices, including large institutions such as dental schools and clinics, where dentistry is practiced that discharge to a POTW. The new EPA dental regulation does not apply to mobile units or offices where the practice of dentistry consists only of the following dental specialties: oral pathology, oral and maxillofacial radiology, oral and maxillofacial surgery, orthodontics, periodontics or prosthodontics.

Change out:

  • The regulation requires dental offices to follow manufacturer’s guidelines when changing out their containers.
  • Dental offices that discharge to POTWs but do not place or remove amalgam need only submit a certification.
  • Dental offices that place or remove amalgam must install, operate and maintain an amalgam separator and must dispose scrap amalgam properly (may use a Solmetex amalgam bucket).
  • Dental offices must use line cleaners with a pH level between 6-8.
  • Dental offices must submit a compliance report. While these reporting mechanisms will be required the details on how and when they are to be done is still to be determined and will mostly likely fall to the individual states and local water authorities.


  • Each dental office will be responsible for implementing the ADA’s Best Management Practices (BMPs) regarding amalgam waste within their practice. While amalgam separators are the focus of the proposed regulation, the regulation is about responsible management of amalgam waste.
  • Dental offices are required to manage the disposal of wet amalgam waste (amalgam separator) and dry amalgam waste (amalgam bucket for example) as defined in the BMPs.   Dry amalgam waste includes all items that come in contact with amalgam, such as chairside traps, amalgam capsules, vacuum filters and contact & non-contact amalgam.
  • A malfunctioning amalgam separator must be repaired or replaced no later than 10 days after the problem is discovered.

Important Links:

States Deadlines  
Maine December 31, 2004
New Hampshire October 1, 2005
Connecticut January 11, 2006
Massachusetts June 22, 2006
Vermont January 1, 2007
New Mexico December 31, 2014
New York May 12, 2008
Rhode Island July 1, 2008
New Jersey October 1, 2009
Oregon January 1, 2010
Michigan December 31, 2013
Local Areas
Wichita – KS June 1, 2001
King County (WA) June 1, 2003
Palo Alto – CA March 31, 2005
Fort Collins – CO July 1, 2005
San Francisco Bay Area January 1, 2007
Eau Claire – WI January 1, 2008
Watertown – WI January 1, 2008
Milwaukee – WI February 1, 2008
Racine – WI February 1, 2008
La Crosse – WI March 26, 2008
Neenah Menasha – WI June 1, 2008
Dane County – WI December 31, 2008
Waukesha – WI December 31, 2008
Madison Metropolitan Sewerage District – WI December 31, 2008
Chippewa Falls – WI April 1, 2009
Albuquerque June 30, 2010
Bernalillo County – NM June 30, 2010
Menomonie – WI July 1, 2010
Central Marin Sanitation Agency / Las Gallinas Valley – CA December 31, 2010
San Josè / Santa Clara – CA 07/2009 – 12/2010


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Tiffanie Winfrey

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