New Federal Dental Effluent Rules and Important Deadlines

From the office of Austin Water, the official regulating agency of the EPA amalgam separator ruling. Please use the following calendar to ensure compliance with the ruling. The website links are also available on the CADS website, www.capitalareadental.org. Representatives with Austin Water will be on hand during the Capital Area Dental Conference to address the attendees and answer questions.

New Federal Dental Effluent Rules and Important Deadlines
The US Environmental Protection Agency (EPA) has adopted new pre-treatment standards, recordkeeping and reporting requirements to reduce discharges of mercury from dental offices into publicly owned treatment works (POTWs). The Dental Office Category regulation is codified in Title 40 of the Code of Federal Regulations Part 441.
These regulations mean that dental offices who receive wastewater service from Austin Water (directly or indirectly) are subject to a number of requirements, including one that stipulates the submission of a One Time Compliance Report to Austin Water to demonstrate your compliance with the law.
More detailed guidance from the EPA is available at: www.epa.gov/eg/dental-effluent-guidelines. You should consult this EPA guidance document and the published rules for much more specific descriptions of the requirements as they apply. For your convenience, the following simplified schedule of important applicable due dates in the regulations is provided below (in the event of any conflict, the EPA guidance and regulatory language governs):


June 14, 2017 General Date the regulations were adopted.

July 14, 2017 General Effective date of rule.   Any Dental Office whose first discharge to a POTW was on or before this date is considered an “Existing Dental Office.” Any Dental Office whose first discharge was after this date is considered a “New Dental Office.” All Dental Offices subject to this rule are required to comply with record keeping requirements including, but not limited to: records related to amalgam separator maintenance, inspections and repairs; and amalgam retaining unit shipment and waste disposal.

July 14, 2017 Deadline for New Dental offices New Dental Offices are required to comply with amalgam separator or removal device installation, treatment and disposal requirements by this deadline. Any New Dental Office that starts discharging after this date must install a separator or removal device prior to discharging. Also required to follow certain Best Management Practices related to preventing waste amalgam and mercury from being discharged to POTW.

90 Days after Discharge starts or ownership is transferred. Deadline for New Dental Offices or Existing Dental Offices whose ownerships transferred One Time Compliance Report must be submitted to Austin Water no later than 90 days after the discharge starts or the ownership transfer is complete. One Time Compliance Report is also subject to record keeping requirements.

July 14, 2020 Deadline for Existing Dental Offices Existing Dental Offices are required to comply with amalgam separator or amalgam removal device installation requirements unless an amalgam separator or removal device had already been installed prior to June 14, 2017 (refer to entry for June 14, 2027).
Treatment and disposal requirements apply. Also required to follow certain Best Management Practices related to preventing waste amalgam and mercury from being discharged to POTW.

Any time after July 14, 2020 Existing Dental Offices Any time an amalgam separator installed before July 14, 2017, reaches the end of its manufacturer’s recommended life span or isnot working as designed and can no longer be repaired in accordance with manufacturer’s specifications, it must be replaced with a separator that meets the more stringent requirements of the rule no more than 10 days later.

October 12, 2020 Deadline for Existing  Dental Offices One Time Compliance Report must be submitted to Austin Water.  One Time Compliance Report is also subject to recordkeeping requirements.

June 14, 2027  Final Deadline for Existing Dental Users to Replace Existing Amalgam Separators Existing Dental Offices that had an amalgam separator that was in place prior to June 14, 2017, must install an amalgam separator or amalgam removal device meeting the more stringent requirements in the rule no later than June 14, 2027. The requirement to replace the separator earlier applies, as noted above, any time separator in place exceeds the recommended lifespan described by the manufacturer or requires any repair other than those allowed in accordance with manufacturer’s specifications.


Please use the following link to find the Dental Discharger’s One-Time Compliance Report:
http://www.austintexas.gov/sites/default/files/files/Water/SSD/Pretreatment/DentalDischarger_OneTimeComplianceReport_Form.pdf

Please use the following link to find more information about the City of Austin’s Pretreatment Program:
http://www.austintexas.gov/department/industrial-waste-control-pretreatment

The Dental Discharger’s One-Time Compliance Report can be sent to the following mailing address:

City of Austin / Austin Water Special Services Division / Office of Industrial Waste
3907 S. Industrial Drive, Suite 100, Austin, TX 78744-1070
Contact Information: Phone: 512-972-1060
Email: IndustrialWaste@austintexas.gov