(May 30, 2018) - The NACWA Pretreatment & Pollution Prevention Committee is considering questions and clarifications that are still needed about the Dental Amalgam Separator Rule after EPA published a Frequently Asked Questions (FAQ) document on May 14.
EPA staff discussed the FAQ during the NACWA Pretreatment & Pollution Prevention Workshop on May 16, and the FAQ was also a topic of discussion at the Pretreatment & Pollution Prevention Committee meeting during the Workshop. While the document does clarify and explain some aspects of the rule, the Committee still had questions about how the rule will be implemented and enforced.
In particular, Committee members raised concerned regarding the self-implementing nature of the rule as codified in 40 CFR Part 441 versus the General Pretreatment Regulations in 40 CFR Part 403, including the requirement to identify all industrial users which may be subject to pretreatment standards.
The Committee will develop a complete list of items that need further explanation and NACWA will ask EPA to provide additional guidance or update the FAQ. Please contact Cynthia Finley with any questions or comments about the Dental Amalgam Rule or the FAQ.