Why control Dental Amalgam Waste?

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.

History of the Voluntary Program

MasssDEP worked with MDS in 2004 to establish a voluntary program for dental practices and facilities to certify to MassDEP that they were using amalgam separators and recycling amalgam waste containing mercury.

Dental practices participating in this voluntary program before March 1, 2005, were exempted from MassDEP amalgam separation system installation, operation, maintenance and upgrade regulations, and related fees, until February 1, 2010. Dentists who submitted voluntary certifications after February 28, 2005, but before February 1, 2006, were exempted from additional amalgam separator rules and fees until February 1, 2007.

Why The Program Was Launched

The program was intended to reduce the amount of mercury released into the environment by Massachusetts dental practices and facilities. MassDEP initially implemented a voluntary approach to encourage early installation and use of amalgam separators by dentists before adopting regulations that now require these actions.

Amalgam waste from the dental sector contributes to the mercury released into the environment from Massachusetts sources and was identified as a potential candidate for pollution prevention.

MassDEP Regulations

Subsequent to rolling out the voluntary program, MassDEP developed regulations requiring dental facilities to install and operate amalgam separators, and to use "best management practices" for waste amalgam containing mercury. See: 310 CMR 73.00: Amalgam Wastewater & Recycling Regulations for Dental Facilities

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.