Dental Certification Forms

Local certification form
The district requires all local dental clinics to certify annually that they are managing amalgam waste according to local requirements. The paper certification form is linked below. 

MMSD amalgam certification form

EPA compliance forms
EPA also requires amalgam reporting information from all clinics that discharge amalgam waste into sewer systems. Under the EPA dental effluent rule, clinics are required to send a one-time compliance report to their local control authority. If your clinic is new in the MMSD service area, or if you have assumed ownership of an existing clinic in the area, submit the corresponding form below to MMSD within 90 days of beginning operation or transferring ownership:

New clinic: One-Time Compliance Report

Existing clinic Transfer of Owner One-Time Compliance Report 

Inspection logs
The EPA rule requires that dental clinics maintain records of amalgam separator inspections, replacements and repairs. You can use the example logs linked below or develop your own system to meet these requirements of the rule.

Separator inspection and replacement logs

Other Resources
 
  • Dane County Clean Sweep has a waste collection program for businesses that qualify as very small quantity generators (VSQGs) of hazardous waste, including amalgam and non-controlled pharmaceuticals.
     
  • Milwaukee Metropolitan Sewerage District and UW-Extension produced a guide to amalgam management for dental offices, including recommendations and case studies as well as comparisons of different amalgam separators
 

Pollution Prevention for Dental Clinics

Dental clinics have played a central role in MMSD’s mercury minimization program. Because dental amalgam was one of the largest sources of mercury in the wastewater to the treatment plant, MMSD worked with dental offices to reduce amalgam contributions to the sewer system. 

The cooperation paid off: since the deadline for dental offices to install amalgam separators, MMSD has seen a significant decrease in the incoming and outgoing mercury at the treatment plant. MMSD continues to work with dental offices through annual certification reports and periodic site visits to ensure that mercury reductions persist.

Amalgam Management

 Training Resources for Clinic Staff

The District has developed resources to help dental clinic staff learn about amalgam management requirements and practices to minimize pollution. The presentations linked below are intended for dental clinic staff who are involved in handling and disposing of amalgam waste, and can be an introduction for staff new to amalgam management or a refresher for staff experienced in working with amalgam. Click the links to view the videos on YouTube.

  1. Mercury, Amalgam, and Wastewater (7:07) -- Background on mercury pollution and why the District regulates amalgam waste.
  2. Amalgam Requirements for Dental Clinics (23:24) -- Overview of local and federal amalgam management requirements and descriptions of each required best management practice.
  3. Reporting Requirements, Tools, and Other Resources (11:00) -- Summary of EPA and MMSD amalgam reporting requirements, an oveview of the MMSD annual certification, and other recommended pollution prevention practices for dental clinics.

In addition to these informational modules, you can also view a recorded demonstration of accessing and completing the online certification form or review instructions for accessing and navigating through the form

 

To maintain dental mercury reductions, MMSD asks dental clinics in its service area to take the following steps. Several of these actions are required by MMSD’s Sewer Use Ordinance (Section 7.1).

  • Maintain your amalgam separator according to manufacturer recommendations. Amalgam separators can remove over 99% of the amalgam from dental wastewater, but if they become too full, amalgam-containing wastewater can bypass the separator and drain to the sewer. Ensure that the separator cartridge is replaced with the recommended frequency or before contents exceed the fill point. 
  • Fill out and return the district's annual amalgam certification report, which verifies that your clinic is following required practices. MMSD will send out this form every year, but you can download and print the form by clicking the link to the right.  
  • Follow WDA best management practices for amalgam management.
  • Use a vacuum line cleaner that is compatible with your amalgam separator. Line cleaners that contain bleach or chlorine, or have a high or low pH, can diminish the effectiveness of the amalgam separator. Check with the separator manufacturer to make sure your cleaner is appropriate for the separator.
  • Recycle amalgam scraps, amalgam containing teeth, and other materials, (like amalgam capsules), using Dane County Clean Sweep's Small Business recycling program, or another responsible amalgam recycler - list of resources from the WDA.
  • Handle old plumbing fixtures as potentially mercury-containing waste when conducting renovations or demolitions. Mercury can settle in old fixtures, such as sumps and traps, making them hazardous waste.
NEW EPA DENTAL AMALGAM RULE
On July 14, 2017, the EPA finalized a federal rule requiring all dental clinics that handle amalgam to install and maintain amalgam separators and follow best management practices to keep amalgam out of the drain. Many of the requirements in this rule overlap with MMSD's existing requirements for dental clinics, so if your clinic is already following all of MMSD's requirements, you are already in compliance with much of this rule. However, there are still some differences between the EPA rule and MMSD's program, so there will be some additional actions you will need to take. 

MMSD has created an explanatory document for local dental clinics to help clarify the similarities and differences between the local requirements and new EPA requirements, and what actions local clinics need to take as a result of the EPA rule. MMSD will be sending out the required One-Time Compliance report in August 2018. If you have any questions or concerns about local or federal amalgam requirements, please contact Emily Jones (EmilyJ@madsewer.org) or Catherine Harris (CatherineH@madsewer.org). 

 

Other Pollutants

Although less prevalent than amalgam in dental offices, other substances used in dental settings can be water pollutants, so MMSD recommends the steps below to minimize them.
 
  • Properly dispose of medications via a waste management company, rather than flushing them or placing them in the trash. If you need to dispose of a small amount of non-controlled medications, Dane County Clean Sweep may be a disposal option. Be aware that household medication collection sites, such as MedDrop boxes, cannot be used to dispose of business pharmaceutical waste.
  • Capture silver fixer if using non-digital X-rays to prevent the fixer from going down the drain.
  • Educate staff on what can and can’t be disposed of down the drain. You can post MMSD’s Flushable? poster near sinks and other drains as a reminder.
  • Educate patients about actions they can take to protect water. You can distribute this pollution prevention flier in your office or post to your website.