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FAQ on Amalgam Recycling Rule

FAQ on Amalgam Recycling Rule banner image

As of July 14, 2020, sources subject to the Amalgam Separator Rule must comply.

The amalgam recycling rule is an implementation of the Clean Water Act and was in effect as of July 14, 2017. It is designed to reduce the discharge of amalgam waste from dental offices into the municipal sewage. If you practice in a state or municipality that already has an amalgam separator rule that’s not quite the same as this federal rule, they may have reporting requirements that differ so you may need to continue those reporting obligations. However, the state or municipality (which handle the administration of this federal rule) may decide to conform their requirements to this federal rule and EPA has encouraged this approach, but not mandated it. The entire rule may be read here.

The rule mandates that most dental offices install, maintain, and monitor an amalgam separator that complies with the American National Standards Institute (ANSI) American National Standard/American Dental Association (ADA) Specification 108 for Amalgam Separators (2009) with Technical Addendum (2011) or the International Organization for Standardization (ISO) 11143 Standard (2008). You may continue to operate an already installed amalgam separator for its lifetime or ten years (whichever comes first), as long as you comply with the other rule requirements including the specified Best Management Practices (BMP), operation and maintenance, reporting, and record-keeping requirements. Newly purchased or built offices must comply within 90 days of taking ownership.

Dental offices must also submit a compliance report. Additionally they will need to have maintenance and inspection records available.


Disclaimer: These materials are intended to provide helpful information to dentists and dental team members. They are in no way a substitute for actual professional advice based upon your unique facts and circumstances. This content is not intended or offered, nor should it be taken, as legal or other professional advice. You should always consult with your own professional advisors (e.g. attorney, accountant, insurance carrier). To the extent ADA has included links to any third party web site(s), ADA intends no endorsement of their content and implies no affiliation with the organizations that provide their content. Further, ADA makes no representations or warranties about the information provided on those sites.

  • Who must comply?
  • When does it take effect?
  • Does the EPA's amalgam separator rule apply to dentists on septic systems?
  • What are the specifications for an acceptable amalgam separator?
  • What is the required paperwork?
  • Where do I find the one-time compliance report that I am to fill out and submit?
  • Where should I send my one-time compliance report? Who is my "Control Authority?"
  • Is there a website where I can submit my one-time compliance report electronically?
  • What are the in-office procedures I must follow?
  • Does the ADA have a list of compliant amalgam separator manufacturers?
  • What happens if I already have an amalgam separator in place?
  • What about state and local requirements that are different than what I read here?
  • What did the ADA do during the rulemaking process to help make it easier for dentists?