NACWA Pretreatment Committee: Clarifications Needed for Dental Amalgam Rule
Members of NACWA’s Pretreatment & Pollution Prevention Committee held a conference call on July 16 to discuss issues with implementation of the Dental Amalgam Rule. The rule requires that all dental offices install a dental amalgam separator and follow best management practices if they place or remove dental amalgam. The rule was published in June 2017 and will go into effect for existing dental offices in June 2020. EPA published a Frequently Asked Questions document about the rule, which EPA staff discussed during a panel at the 2018 NACWA Pretreatment & Pollution Prevention Workshop.
Based on the FAQ, the panel discussion, and roundtable discussions at the Workshop, questions have arisen regarding the responsibilities of utility pretreatment programs in the implementation and enforcement of the rule. The committee members discussed the potential problems with the intent of the rule to be self-implementing and the General Pretreatment Regulations of 40 CFR Part 403. NACWA plans to ask EPA for clarification on these issues. NACWA members with questions or concerns about the Dental Amalgam Rule should contact Cynthia Finley, NACWA’s Director of Regulatory Affairs.