Mercury Management for Dental Offices

Legal Requirements: 


Questions? Contact Karen Knaebel at (802) 522-5736 or by email at karen.knaebel@vermont.gov.


Vermont Dental Best Management Practices and Amalgam Separators

In 2005, legislation was passed in Vermont requiring dental offices to comply with environmental best management practices (BMPs) for amalgam wastes developed by the Department of Environmental Conservation. The law requires the installation of amalgam separators in the wastewater discharge.

How Does a Dental Office Comply?

IMPORTANT: Orthodontists, periodontists, endodontists, and oral and maxillofacial surgeons are NOT required to file a self-certification form or install an amalgam separator.

All other dental practices:
  1. Read and comply with the Dental BMPs (condensed).
  2. Install an amalgam separator on your wastewater discharge.
  3. Self-certify your compliance status with the Dental BMPs by filing a self-certification form by January 31st every other year starting in 2011.

Federal Rule - Effluent Limitations, Guidelines, and Standards for the Dental Category

On July 14, 2017, Federal Rule Effluent Limitations Guidelines and Standards for the Dental Category went into effect. Existing sources must be in compliance with this rule by July 14, 2020, while new sources must meet the requirements of the rule beginning July 14, 2017.

How Does a Dental Office Comply?

IMPORTANT: Endodontists, are NOT exempt from the Federal Rule, only from the Vermont Requirements.

This is a one-time Federal Reporting. The reporting requirement for this Federal Rule does not have to be repeated unless:
  • The dental office is a new office or a new location that has not previously been a dental office.
  • The dental office has changed ownership.
  • If either of the above applies, contact Karen Knaebal at (802) 522-5736 or by email at karen.knaebel@vermont.gov.

Dental offices that completed the online Vermont self-certification form for 2019 also completed the form for this Federal Amalgam Rule at the same time. The data for this reporting is retained by Vermont DEC WMPD through anronline.vermont.gov. The online reporting system for the Vermont certification will automatically include the Federal Reporting information for any dental office that has not completed the Federal Requirement. Endodontists MUST complete and mail a Federal reporting form for any new office or change or ownership of an exsisting office.


Vermont Hazardous Waste Handler Site ID Form for Dental Offices (Permanent EPA ID# begins with VTR or VTD plus 9 numbers).

A dental facility that maintains an amalgam separator is required to obtain this number as a generator of amalgam waste from an amalgam separator. Complete this FORM to obtain an EPA ID number, which is a one-time submission and renews annually with a $75 fee due April 1st each year.

This EPA ID number applies to the physical location of where the amalgam waste from the separator is generated. If a dental office moves to a new location, a new EPA ID number must be obtained. If a dentist owns several locastions, EACH location must have its own individual number. If a dental office changes ownership, complete the same form (available above) for a new practice except:

  • Box #1 (under Reason for Submittal) check the box “To provide subsequent notification” and write in CHANGE IN OWNERSHIP
  • Box #2 Write in the existing EPA ID number (Starting with VTR or VTD +9 numbers)
  • Box #3 Write in the new name of the dental facility if it has changed.
  • Box #4 MUST be the physical location that is affiliated with the EPA ID number for which it was originally assigned.
  • Boxes #5 & 6 are completed and the remaining portion of Page 1 can be completed with new ownership information, etc.
  • Page 2 has one checkbox already completed for a dental office – no other information required.
  • Page 3 – has the waste code already identified and requires a signature at the bottom to complete the form. 

To submit a new or amended form or for more information contact Wendy Edwards at (802) 522-0261 or e-mail: wendy.edwards@vermont.gov

 


Amalgam Separator Installation and Maintenance Requirements

Installation Requirements

Vermont dental offices are required to install amalgam separators no later than January 1, 2007. This requirement applies to any practice that places or removes dental amalgam. The following categories of dental practices are exempt from the requirement: orthodontists, periodontists, endodonists, and oral and maxillofacial surgeons.

Vermont Dental Amalgam Separator Pilot Project Report
Dental Amalgam Separator Report

A list of approved amalgam separators that meets the installation requirement (ISO 11143 Standard for amalgam separators) will be updated periodically. Further information on amalgam separators and practical considerations in choosing an amalgam separator are contained in the Vermont Dental Amalgam Pilot Project Report. You may benefit by speaking to other dentists that have installed separators, dental suppliers, and the vendors/manufacturers of amalgam separators. Installation may require the services of a plumber.

Inspection & Maintenance Requirements

It is important to perform routine maintenance on amalgam separators to ensure that they are serving their intended purpose of amalgam removal. Failure to perform maintenance and change cartridges or collector boxes when full can lead to bypass of the system and discharges of mercury in the wastewater.

The Dental Best Management Practices require that an inspection log be maintained for your amalgam separator. Click on the links below to view a sample inspection log and a log that you can download for your use.

For further information or if you have questions, please contact the Environmental Assistance Office at 802-622-4111.


Additional Resources

Agency of Natural Resources
Department of Environmental Conservation
Waste Management and Prevention Division

Davis Building - 1st Floor
One National Life Drive
Montpelier, VT 05620-3704
802-828-1138