Dental Office Compliance
Effective July 14, 2017, the U.S. Environmental Protection Agency (EPA) adopted the Effluent Limitations Guidelines and Standards to reduce the discharge of mercury-containing amalgam from dental offices into municipal sewage treatment plants known as publicly owned treatment works (POTWs).
To simplify implementation and compliance for dental offices, this rule establishes that dental dischargers are not Significant Industrial Users (SIU), nor Categorical Industrial Users (CIU) subject to categorical pretreatment standards. This significantly reduces the reporting requirements that would otherwise apply. However, dental offices within the City of Houston must complete and submit the One-Time Compliance Report to the City as the regulatory control authority.
IF YOUR DENTAL OFFICE CHANGED OWNERSHIP OR MADE A SIGNIFICANT CHANGE TO THE OPERATION OF AN EXISTING OFFICE, A NEW ONE TIME COMPLIANCE REPORT NEEDS TO BE SUBMITTED WITHIN 90 DAYS OF THE CHANGE.
A scanned copy of the completed one time compliance report signed by an authorized representative is recommended be submitted to [email protected] for complimentary review. However, to comply with the requirements of the City’s approved pretreatment program, the original form with the wet signature must be submitted to the following address: 10500 Bellaire Blvd, Houston, TX 77072.
For questions, please contact 832-395-8000.
Each covered facility must already have or must install an amalgam removal and collection system to prevent amalgam from being sent to the sanitary sewer system. The amalgam removal system must consist of one or more amalgam separators meeting either the American National Standards Institute (ANSI) American National Standard/American Dental Association (ADA) Specification 108 for Amalgam Separators (2009) with Technical Addendum (2011), the International Organization for Standardization (ISO) 11143 Standard (2008) or subsequent versions so long as that version requires amalgam separators to achieve at least a 95 percent removal efficiency.
This rule also provides for alternative amalgam removal systems that meet certain performance requirements.
The system must be sized to accommodate the maximum discharge rate of amalgam process wastewater.
The amalgam separator(s) must be inspected in accordance with the manufacturer’s operating manual to ensure proper operation and maintenance of the separator(s) and to confirm that all amalgam process wastewater is flowing through the amalgam retaining portion of the amalgam separator(s).
A malfunctioning unit must be repaired or replaced no later than 10 business days after the malfunction is discovered.
This rule requires dental dischargers to adopt two specific best management practices (BMPs) in addition to the equipment requirements:
• Waste amalgam, including but not limited to dental amalgam from chair-side traps, screens, vacuum pump filters, dental tools, cuspidors or collection devices, must not be discharged to a POTW.
• Dental unit water lines, chair-side traps and vacuum lines that discharge amalgam process wastewater to a POTW must not be cleaned with oxidizing or acidic cleaners, including but not limited to bleach, chlorine, iodine and peroxide that have a pH lower than 6 or greater than 8.
Dental dischargers must submit a One-Time Compliance Report to the City of Houston. If a dental discharger transfers ownership of the facility, the new owner must submit a new One-Time Compliance Report to the City of Houston no later than 90 days after the transfer. The dental discharger must maintain and make available for inspection a copy of the One-Time Compliance Report if it is in operation or until ownership is transferred.
Dental dischargers or an agent or representative of the dental discharger must maintain and make available for inspection in either physical or electronic form for a minimum of three years the following:
• Documentation of the date, person(s) conducting the inspection and results of each inspection of the amalgam separator(s) or equivalent device(s) and a summary of follow-up actions, if needed.
• Documentation of amalgam retaining container or equivalent container replacement (including the date, as applicable).
• Documentation of all dates that collected dental amalgam is picked up or shipped for proper disposal in accordance with 40 CFR 261.5(g)(3) and the name of the permitted or licensed treatment, storage or disposal facility receiving the amalgam retaining containers.
• Documentation of any repair or replacement of an amalgam separator or equivalent device, including the date, person(s) making the repair or replacement and a description of the repair or replacement (including make and model).
• The manufacturer’s operating manual for the current device.
Pretreatment Information
Industrial Wastewater Service
10500 Bellaire Blvd
Houston, TX 77072
Phone: (832) 395-5800
Email: [email protected]