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EPA Dental Rule Compliance

Dental Office Category - 40 CFR, Part 441

On June 14, 2017, the USEPA promulgated pretreatment standards to reduce discharges of mercury from dental offices into publicly owned treatment works (POTW).  The effective date of the rule is July 14, 2017.

What does the rule require of dental offices?

  • Dental offices that discharge to POTWs that do not place or remove amalgam need only submit a one-time certification to the Control Authority.  (Your Control Authority is either your local wastewater utility [POTW] if it has an approved Industrial Pretreatment Program [IPP], or EGLE.)
  • Dental offices that place or remove amalgam must operate and maintain an amalgam separator and must not discharge scrap amalgam or use certain kinds of line cleaners.  They must also submit a One-Time Compliance Report.
  • Existing dental dischargers (dental offices that were in operation before July 14, 2017) must comply with the rule by July 14, 2020. 
  • New dental dischargers (dental offices that begin operating on or after July 14, 2017) must be in compliance immediately.
  • One-Time Compliance Report deadlines.  For existing dental dischargers, a One-Time Compliance Report must be submitted to the Control Authority no later than October 12, 2020, or 90 days after a transfer of ownership.  For new dental dischargers, a One-Time Compliance Report must be submitted to the Control Authority no later than 90 days following the introduction of wastewater into a POTW.
  • Existing amalgam separators may be operated for their lifetime or ten years, whichever comes first.  When a separator needs replacement, or the ten-year period has ended and the separator does not meet the standard of the final rule, a dental office must replace it with one that meets the requirements of the final rule and file a One-Time Compliance Report within 90 days of installation.
  • EPA Amalgam Recycling Rule Decision Tree

What form do I use for my One-Time Compliance Report?

EGLE has developed a single form, State of Michigan One-Time Compliance Report for Dental Dischargers, for use by all dental offices required to submit a One-Time Compliance Report or One-Time Certification to their Control Authority for compliance with the Dental Office Categorical Regulations.

Where do I send the completed form?

Step 1: Open the spreadsheet Contributing Municipalities and Control Authorities with approved IPP's.  Determine if the municipality your facility is located in is listed in Column A of the spreadsheet. If your municipality is listed in Column A, complete the form and mail it to the associated Control Authority listed in Column B. 

Step 2: If the municipality your facility is located in is not listed in the spreadsheet, then the Michigan Department of Environment, Great Lakes, and Energy (EGLE) is your Control Authority; however, your local municipality will be receiving the reports in the interim.  Complete this form and mail to the address of your local municipality as indicated in the notice to you.