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Mercury Management for Dental Offices

Legal Requirements: 

Questions? Contact Sarah Hobson at (802) 636-7926 or by email at

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 from this approved amalgam separator list 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 Sarah Hobson at (802) 636-7926 or by email at

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 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 existing 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 locations, EACH location must have its own individual number. If a dental office changes ownership, complete the same form (available above) for a new practice.

To submit a new or amended form or for more information contact Wendy Edwards at (802) 522-0261 or e-mail:

Additional Resources






  • Video Instructions for Dental Office Self-Certification with ANROnlineDental Self-Cert Video Link