(December 4, 2019) – Members of NACWA’s Pretreatment & Pollution Prevention Committee met on November 21 to discuss the implementation of the Dental Amalgam Rule.  The 2017 rule requires that dental offices install dental amalgam separators and follow best management practices (BMPs) by July 2020.  Dental offices must submit a one-time compliance report to their wastewater utility by October 12, 2020. 

The rule’s preamble states that utilities must receive, review, and retain these one-time compliance reports, and flexibility is provided for how utilities enforce the rule.  Although dental offices are not defined as categorical or significant industrial users in the rule, they are still industrial users (IUs).  This means that requirements in 40 CFR Part 403 related to IUs still apply, such as the POTW responsibility to identify IUs in their service areas and notify them of pretreatment requirements.  POTWs may need to modify their Enforcement Response Plans (ERPs) to provide a procedure for responding to non-compliant dental offices that is different than the response to other categorical or significant IUs. 

NACWA members with questions about the Dental Amalgam Rule should contact Cynthia Finley, NACWA’s Director of Regulatory Affairs.  The Pretreatment Committee’s next meeting, which will focus on PFAS, will be scheduled for early 2020.