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Dental Amalgam Rule: One-Time Compliance Report Due October 12th

The compliance date for existing dental offices to install amalgam separators was July 14, 2020. From that date, dental offices have 90 days to submit a One-Time Compliance Report to their pretreatment Control Authority, by October 12, 2020. Your Control Authority is either the local wastewater utility/sanitation agency, the state environmental agency, or U.S. EPA Regional Office.

In California, to determine your Control Authority, the California State Water Resources Control Board (SWRCB) requests dental offices to contact the local sanitation agency on your sewer bill, and ask if that agency, or another affiliated local sanitation agency, implements a federal Pretreatment Program for industrial discharges into the public sewer system.

  1. If a local sanitation agency implements a federal Pretreatment Program for its sewer system, that sanitation agency is your Control Authority.
    • Send your One-Time Compliance Report to the agency per their instructions. Most local sanitation agencies required to collect the report have contacted the dental practices in their respective service areas.
  2. If the local sanitation agency does not implement a federal Pretreatment Program, the SWRCB assumes the role of the Control Authority.

Dental offices that only remove amalgam fillings in limited emergency, unplanned, unanticipated circumstances are exempt from the requirements as long as they certify as such in a One-Time Compliance Report to their Control Authority. Additionally, EPA’s Dental Amalgam Rule does not apply to 1) mobile units, 2) to offices that do not discharge wastewater to public utilities (i.e. those connected to a septic system), or 3) to offices where the practice of dentistry consists only of the following dental specialties: oral pathology, oral and maxillofacial radiology, oral and maxillofacial surgery, orthodontics, periodontics, or prosthodontics.

Since 1992, OSHA Review, Inc. has provided dental professionals with comprehensive programs to support regulatory compliance and infection control. We are a registered continuing education provider in the state of California, specializing in Dental Practice Act, infection control, and OSHA training.

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