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Dental Amalgam/Mercury Recycling 

Introduction

Regulations & program requirements

Compliance certification forms and deadlines 

Amalgam separators

Managing & recycling amalgam & mercury wastes

Record-keeping requirements

For more information

Introduction 

Amalgam waste from dental practices and clinics is a significant source of me

to the environment when it is thrown into the trash or washed down a drain.

of Massachusetts study of several commercially available amalgam separator

confirmed that they effectively remove most mercury from dental wastewate

The Massachusetts Department of Environmental Protection (MassDEP) is wo

reductions of mercury releases to the environment from dental practices and

two phases: 

z First, the agency implemented a voluntary program with the Massach

Society (MDS) to encourage early installation and use of amalgam sep

dentists. 

z Second, MassDEP issued regulations that require most dental practice

in Massachusetts to install and operate amalgam separator systems, r

mercury-containing amalgam wastes, and periodically certify their com

these requirements. 

The regulations, which took effect on April 24, 2006, were developed with as

a stakeholder workgroup including individual dentists, MDS representatives, 

authorities, and environmental groups. 

Back to Dental Amalgam/Mercury Recycling index

Regulations & Program Requirements 

310 CMR 73.00: Amalgam Wastwater & Recycling Regulations for Dental Fac

Web page

Mass DEP :: MA DEP: Dental Amalgam Mercury Recycling Page 1 of 5

http://www.mass.gov/dep/service/dentists.htm 10/5/2007
Note: These regulations apply to all dental practices and facilities located in Mass

Those that do not generate or discharge wastewater from amalgam-related proce

dentistry is limited to oral and maxillofacial, orthodontic, periodontic, and/or oral m

practices), use only mercury-free filling material, or do not place or remove mercu

not required to install amalgam separators, but need to file one-time certifications

exempt status. 

The Dental Amalgam/Mercury Recycling certification program requires dental

facilities to certify to MassDEP every five years that they: 

z Have installed an amalgam separator system that serves every dental

practice or facility where waste amalgam is generated. The system mu

has been demonstrated to remove at least 98 percent of the amalgam

containing mercury (using the ISO 11143 protocol or an equivalent me

acceptable to MassDEP). 

z Maintain and operate the amalgam separator system according to man

specifications. 

z Use only non-corrosive and biodegradable cleaners to clean vacuum sy

z Recycle all amalgam waste containing mercury. 

z Ensure that facility staff are informed about procedures for handling w

amalgam, and that at least one employee is familiar with procedures f

and maintaining the installed amalgam separator system. 

z Keep records to document that the program requirements are being m

A Note About Amalgam Separators Installed by Voluntary Program Participan

While the voluntary program required that amalgam separators be demonstrated t

percent efficiency in removing waste amalgam from wastewater, the regulations re

amalgam separators meet a 98 percent removal efficiency standard. Facilities tha

the voluntary program are allowed to continue using their 95 percent efficient ama

separators, as long as the equipment continues to achieve this removal efficiency 

maintained in accordance with manufacturer instructions. When separators need t

units that meet the 98 percent removal efficiency standard must be installed. 

Back to Dental Amalgam/Mercury Recycling index

Compliance Certification Forms & Deadlines 

Compliance Certification Forms: File Online or by Mail 

Web page

Deadline for Certification Filing 

z Massachusetts dental practices that did not participate in the voluntar

must install and use amalgam separators, recycle amalgam waste con

mercury, and file their initial certifications by June 22, 2006. 

z Dental practices and facilities that are exempt from the regulation mu

time certifications to establish their exempt status by June 22, 2006. 

z New dental practices and those that expand beyond the capacity of th

amalgam separator(s) must install new amalgam separator equipmen

new facilities start operating, and must file initial certifications with M

60 days of startup. 

z Dental facilities that joined the voluntary program during its first year

Mass DEP :: MA DEP: Dental Amalgam Mercury Recycling Page 2 of 5

http://www.mass.gov/dep/service/dentists.htm 10/5/2007
January 31, 2004, and February 28, 2005) must file their first require

by June 15, 2010. 

z Dental facilities that joined the voluntary program during its second y

March 1, 2005, and April 21, 2006) must file their first required certifi

June 15, 2007. 

z After initial certifications are filed with MassDEP, follow-up certification

every five years (by June 15 of the year they are due). 

Back to Dental Amalgam/Mercury Recycling index

Amalgam Separators 

List of Amalgam Separator Technologies Approved for Use in Massachusetts 

Web page

Amalgam separators remove particles of amalgam from wastewater that pas

your facility's vacuum system, vacuum line filters and screens, and/or chair-s

before the wastewater is discharged to a sewer. 

z Amalgam separators must be demonstrated to remove at least 98 per

waste amalgam in wastewater. These demonstrations are usually con

professional laboratories at the request of the separator manufacturer

specific protocol developed by the International Organization for Stan

(ISO protocol 11143). 

z Facilities that participated in the voluntary program are allowed to con

their 95 percent efficient amalgam separators, as long as the equipme

to achieve this removal efficiency and is maintained in accordance wit

manufacturer instructions. When separators need to be replaced, unit

the 98 percent removal efficiency standard must be installed. 

z The separator must serve all wastewater that contains waste amalgam

wastewater from chairs and cuspidors), and needs to be sized to acco

facility's maximum amalgam wastewater flow. 

z The separator must be installed, operated, and maintained according

manufacturer's instructions. 

z At least one employee must be familiar with the procedures for opera

maintaining your amalgam separator system. In addition, all staff me

handle waste amalgam must be informed about these procedures. 

Cleaning & Disinfecting Vacuum Lines & Drains 

z Use only disinfectants and cleaning agents that are biodegradable, no

(pH between 6.5 and 9.0) and non-oxidizing in your facility's vacuum

other drains that are connected to amalgam separator equipment. 

z Bleach is not an acceptable disinfectant, since it mobilizes the mercur

separator and prevents the separator from capturing waste amalgam.

z Follow manufacturer instructions on appropriate disinfectants, cleanin

maintenance procedures. 

Back to Dental Amalgam/Mercury Recycling index

Managing & Recycling Amalgam & Mercury Wastes 

Mass DEP :: MA DEP: Dental Amalgam Mercury Recycling Page 3 of 5

http://www.mass.gov/dep/service/dentists.htm 10/5/2007
List of Companies That Provide Amalgam Mercury Recycling Services 

Web page

Recommended Practices for Handling Amalgam & Mercury Wastes 

Web page

All amalgam waste generated at dental practices and facilities must be sent t

that reclaim mercury from the amalgam waste material. This is a form of rec

illegal to throw amalgam waste into the trash (i.e., to treat it as solid waste)

amalgam with medical or "red bag" waste. 

There are two types of amalgam wastes: 

z CONTACT AMALGAM has been used on patients and generally inc

extracted teeth, scrap amalgam from removed fillings, chair-side trap

and sludge from vacuum pump filters, amalgam separators, and othe

capture waste amalgam. 

z NON-CONTACT AMALGAM has never been used on patients and 

includes broken and unusable amalgam capsules, excess amalgam, an

capsules from restorative treatments. 

All amalgam wastes should be stored safely in air-tight containers with secur

enough has been collected for shipment to a reclamation facility or recycler. 

recommended practices for handling amalgam wastes. 

To recycle amalgam waste, you may send it directly to a recycling facility tha

a Class A Hazardous Waste Recycling Permit from MassDEP, or a recycling fa

in another state that is authorized by that state to reclaim mercury. You may

licensed hazardous waste facility or a consolidation facility, which will in turn

amalgam waste to a reclamation facility. 

A common carrier (such as the U.S. Postal Service, United Parcel Service, Fe

or other shipping service) may be used to transport amalgam waste. You are

to use a licensed hazardous waste transporter. Some amalgam separator ven

shipping services as part of a standard maintenance agreement. Your reclam

and/or shipping service can assist you with necessary record-keeping, packa

labeling. 

Back to Dental Amalgam/Mercury Recycling index

Record-Keeping Requirements 

Dental practices and facilities need to keep on-site records to demonstrate th

with the Amalgam Wastewater & Recycling Regulations for Dental Facilities (

73.00). Records must be kept for at least five years, coinciding with the perio

the certification. These records include: 

z Maintenance and service records for the amalgam separator(s), to de

manufacturer instructions are being followed. 

z Shipping records indicating that amalgam waste has been transported

facility that is approved to accept it. In Massachusetts, the facility nee

Hazardous Waste Recycling Permit. 

z Any other information that the facility has relied on to complete its ce

required by 310 CMR 70.00 and 310 CMR 73.00. 

Mass DEP :: MA DEP: Dental Amalgam Mercury Recycling Page 4 of 5

http://www.mass.gov/dep/service/dentists.htm 10/5/2007
 

Back to Dental Amalgam/Mercury Recycling index

For More Information 

eDEP Online Filing of Certifications 

Contact Steve White: 

617-574-6888 or steve.white@state.ma.us

Hazardous Waste Disposal/Recycling Requirements 

Web page

or call the Business Compliance Assistance Hotline: 

617-292-5898 

Wastewater Treatment & Amalgam Collection/Recycling Requirements 

Contact John Reinhardt: 

617-292-5667 or john.reinhardt@state.ma.us

Mercury Pollution, its Health Effects, and What Massachusetts is Doing 

Web page

Or call the MassDEP Mercury Hotline: 

1-866-9MERCURY (1-866-963-7287) 

Massachusetts Dental Society 

508-480-9797 or 800-342-8747 

Naval Dental Research Institute 

Web site

Northeast Waste Management Officials Association 

Web site

Back to Dental Amalgam/Mercury Recycling index

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Mass DEP :: MA DEP: Dental Amalgam Mercury Recycling Page 5 of 5

http://www.mass.gov/dep/service/dentists.htm 10/5/2007