Amalgam waste from dental practices and clinics is a significant source of mercury releases to the environment when it is thrown into the trash or washed down a drain. A University of Massachusetts study of several commercially available amalgam separator technologies confirmed that they effectively remove most mercury from dental wastewater.

The Massachusetts Department of Environmental Protection (MassDEP) is working toward reductions of mercury releases to the environment from dental practices and facilities in two phases:

• First, the agency implemented a voluntary program with the Massachusetts Dental Society (MDS) to encourage early installation and use of amalgam separators by dentists.
  
  
• Second, MassDEP issued regulations that require most dental practices and facilities in Massachusetts to install and operate amalgam separator systems, recycle mercury-containing amalgam wastes, and periodically certify their compliance with these requirements.

The regulations, which took effect on April 24, 2006, were developed with assistance from a stakeholder workgroup including individual dentists, MDS representatives, sewerage authorities, and environmental groups.

Back to Dental Amalgam/Mercury Recycling index

310 CMR 73.00: Amalgam Wastwater & Recycling Regulations for Dental Facilities

Web page

Note: These regulations apply to all dental practices and facilities located in Massachusetts. Those that do not generate or discharge wastewater from amalgam-related processes (i.e., dentistry is limited to oral and maxillofacial, orthodontic, periodontic, and/or oral medicine practices), use only mercury-free filling material, or do not place or remove mercury amalgam are not required to install amalgam separators, but need to file one-time certifications to establish their exempt status.

The Dental Amalgam/Mercury Recycling certification program requires dental practices and facilities to certify to MassDEP every five years that they:

• Have installed an amalgam separator system that serves every dental chair in the practice or facility where waste amalgam is generated. The system must be one that has been demonstrated to remove at least 98 percent of the amalgam waste containing mercury (using the ISO 11143 protocol or an equivalent method acceptable to MassDEP).
  
  
• Maintain and operate the amalgam separator system according to manufacturer specifications.
  
  
• Use only non-corrosive and biodegradable cleaners to clean vacuum system lines.
  
  
• Recycle all amalgam waste containing mercury.
  
  
• Ensure that facility staff are informed about procedures for handling waste amalgam, and that at least one employee is familiar with procedures for operating and maintaining the installed amalgam separator system.
  
  
• Keep records to document that the program requirements are being met.

A Note About Amalgam Separators Installed by Voluntary Program Participants

While the voluntary program required that amalgam separators be demonstrated to achieve 95 percent efficiency in removing waste amalgam from wastewater, the regulations require that amalgam separators meet a 98 percent removal efficiency standard. Facilities that participated in the voluntary program are allowed to continue using their 95 percent efficient amalgam separators, as long as the equipment continues to achieve this removal efficiency and is maintained in accordance with manufacturer instructions. When separators need to be replaced, units that meet the 98 percent removal efficiency standard must be installed.

Back to Dental Amalgam/Mercury Recycling index

Compliance Certification Forms: File Online or by Mail

Web page

Deadline for Certification Filing

• Massachusetts dental practices that did not participate in the voluntary program must install and use amalgam separators, recycle amalgam waste containing mercury, and file their initial certifications by June 22, 2006.
  
  
• Dental practices and facilities that are exempt from the regulation must file one-time certifications to establish their exempt status by June 22, 2006.
  
  
• New dental practices and those that expand beyond the capacity of their existing amalgam separator(s) must install new amalgam separator equipment before the new facilities start operating, and must file initial certifications with MassDEP within 60 days of startup.
  
  
• Dental facilities that joined the voluntary program during its first year (between January 31, 2004, and February 28, 2005) must file their first required certifications by June 15, 2010.
  
  
• Dental facilities that joined the voluntary program during its second year (between March 1, 2005, and April 21, 2006) must file their first required certifications by June 15, 2007.
  
  
• After initial certifications are filed with MassDEP, follow-up certifications are required every five years (by June 15 of the year they are due).

Back to Dental Amalgam/Mercury Recycling index

List of Amalgam Separator Technologies Approved for Use in Massachusetts

Web page

Amalgam separators remove particles of amalgam from wastewater that passes through your facility's vacuum system, vacuum line filters and screens, and/or chair-side traps, before the wastewater is discharged to a sewer.

• Amalgam separators must be demonstrated to remove at least 98 percent of the waste amalgam in wastewater. These demonstrations are usually conducted by professional laboratories at the request of the separator manufacturers, using a specific protocol developed by the International Organization for Standardization (ISO protocol 11143).
  
  
• Facilities that participated in the voluntary program are allowed to continue using their 95 percent efficient amalgam separators, as long as the equipment continues to achieve this removal efficiency and is maintained in accordance with manufacturer instructions. When separators need to be replaced, units that meet the 98 percent removal efficiency standard must be installed.
  
  
• The separator must serve all wastewater that contains waste amalgam (including wastewater from chairs and cuspidors), and needs to be sized to accommodate the facility's maximum amalgam wastewater flow.
  
  
• The separator must be installed, operated, and maintained according to the manufacturer's instructions.
  
  
• At least one employee must be familiar with the procedures for operating and maintaining your amalgam separator system. In addition, all staff members who handle waste amalgam must be informed about these procedures.

Cleaning & Disinfecting Vacuum Lines & Drains

• Use only disinfectants and cleaning agents that are biodegradable, non-corrosive (pH between 6.5 and 9.0) and non-oxidizing in your facility's vacuum lines and all other drains that are connected to amalgam separator equipment.
  
  
• Bleach is not an acceptable disinfectant, since it mobilizes the mercury in the separator and prevents the separator from capturing waste amalgam.
  
  
• Follow manufacturer instructions on appropriate disinfectants, cleaning agents and maintenance procedures.

Back to Dental Amalgam/Mercury Recycling index

Web page

Recommended Practices for Handling Amalgam & Mercury Wastes

Web page

All amalgam waste generated at dental practices and facilities must be sent to facilities that reclaim mercury from the amalgam waste material. This is a form of recycling. It is illegal to throw amalgam waste into the trash (i.e., to treat it as solid waste) or to mix amalgam with medical or "red bag" waste.

There are two types of amalgam wastes:

• Contact amalgam has been used on patients and generally includes extracted teeth, scrap amalgam from removed fillings, chair-side traps and screens, and sludge from vacuum pump filters, amalgam separators, and other devices that capture waste amalgam.
  
  
• Non-contact amalgam has never been used on patients and generally includes broken and unusable amalgam capsules, excess amalgam, and empty capsules from restorative treatments.

All amalgam wastes should be stored safely in air-tight containers with secure lids until enough has been collected for shipment to a reclamation facility or recycler. See other recommended practices for handling amalgam wastes.

To recycle amalgam waste, you may send it directly to a recycling facility that has obtained a Class A Hazardous Waste Recycling Permit from MassDEP, or a recycling facility located in another state that is authorized by that state to reclaim mercury. You may send it to a licensed hazardous waste facility or a consolidation facility, which will in turn send the amalgam waste to a reclamation facility.

A common carrier (such as the U.S. Postal Service, United Parcel Service, Federal Express, or other shipping service) may be used to transport amalgam waste. You are not required to use a licensed hazardous waste transporter. Some amalgam separator vendors provide shipping services as part of a standard maintenance agreement. Your reclamation facility and/or shipping service can assist you with necessary record-keeping, packaging, and labeling.

Back to Dental Amalgam/Mercury Recycling index

Dental practices and facilities need to keep on-site records to demonstrate their compliance with the Amalgam Wastewater & Recycling Regulations for Dental Facilities (310 CMR 73.00). Records must be kept for at least five years, coinciding with the period covered by the certification. These records include:

• Maintenance and service records for the amalgam separator(s), to demonstrate that manufacturer instructions are being followed.
  
  
• Shipping records indicating that amalgam waste has been transported to a recycling facility that is approved to accept it. In Massachusetts, the facility needs a Class A Hazardous Waste Recycling Permit.
  
  
• Any other information that the facility has relied on to complete its certification as required by 310 CMR 70.00 and 310 CMR 73.00.

Back to Dental Amalgam/Mercury Recycling index

eDEP Online Filing of Certifications

Contact Steve White:
617-574-6888 or steve.white@state.ma.us

Hazardous Waste Disposal/Recycling Requirements

Web page

or call the Business Compliance Assistance Hotline:
617-292-5898

Wastewater Treatment & Amalgam Collection/Recycling Requirements

Contact John Reinhardt:
617-292-5667 or john.reinhardt@state.ma.us

Mercury Pollution, its Health Effects, and What Massachusetts is Doing

Web page

Or call the MassDEP Mercury Hotline:
1-866-9MERCURY (1-866-963-7287)

Massachusetts Dental Society

508-480-9797 or 800-342-8747

Naval Dental Research Institute

Web site

Northeast Waste Management Officials Association

Web site

Back to Dental Amalgam/Mercury Recycling index