Regulatory Control
- Revised Ordinance of Honolulu
- Enforcement Response Plan
- Amalgam Rules
- F.O.G. Control Program
DENTAL AMALGAM RULES
Dental Amalgam Separator
Pursuant to 40 CFR Part 441, Dental offices are required to use Amalgam Separators and to implement Best Management Practices as recommended by the American Dental Association (ADA). Effective July 14, 2017, all NEW SOURCES subject to the rule must comply immediately, and all EXISTING SOURCES subject to the rule must comply with the standards by July 14, 2020. A one-time Compliance Report Statement and record keeping will be required and are subject to inspection by the City and County of Honolulu.
AMALGAM SEPARATOR (New source after June 13, 2017)
The installation, operation, and maintenance of one or more amalgam separators must meet the following requirements:
Compliance with either 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) or subsequent versions so long as that version requires amalgam separators to achieve at least 95% removal efficiency.
Compliance must be assessed by an accredited testing laboratory under ANSI’s accreditation program for product certification or a testing laboratory that is a signatory to the International Laboratory Accreditation Cooperation’s Mutual Recognition Arrangement. The testing laboratory’s scope of accreditation must include ANSI/ADA 108-2009 or ISO 11143.
AMALGAM SEPARATOR (Existing, installed before June 14, 2017)
The existing amalgam separator(s) may be operated until it needs replacement or by June 14, 2027, whichever is sooner. When a separator needs replacement, the new device must meet the standard as described in the Amalgam Separator (New source after June 13, 2017 section above. If a new amalgam separator is installed, the permittee shall inform the City and County of Honolulu by sending a letter to the Department of Environmental Service, Regulatory Control Branch, 1000 Uluohia Street, Kapolei, Hawaii 96707 or by emailing to the following address: envpermits@honolulu.gov.
AMALGAM REMOVAL DEVICE (Other than an amalgam separator installed before June 14, 2017)
For the installation, operation, and maintenance of one or more existing amalgam removal device(s) other than an amalgam separator, the following requirements shall apply:
Removal efficiency of at least 95 percent of the mass of solids from all amalgam process wastewater. The removal efficiency must be calculated in grams recorded to three decimal places on a dry weight basis. The removal efficiency must be demonstrated at the maximum water flow rate through the device as established by the device manufacturer’s instructions for use. The removal efficiency must be determined using the average performance of three samples. The removal efficiency must be demonstrated using a test sample of dental amalgam that meets the following particle size distribution specifications: 60 percent by mass of particles that pass through a 3150 μm sieve but which do not pass through a 500 μm sieve, 10 percent by mass of particles that pass through a 500 μm sieve but which do not pass through a 100 μm sieve, and 30 percent by mass of particles that pass through a 100 μm sieve. Each of these three specified particle size distributions must contain a representative distribution of particle sizes.
The device(s) must be sized to accommodate the maximum discharge rate of amalgam process wastewater.
The devices(s) must be accompanied by the manufacturer’s manual providing instructions for use including the frequency for inspection and collecting container replacement such that the unit is replaced once it has reached the maximum filling level at which the device can perform to the specified efficiency.
If the amalgam removal device is replaced with a new amalgam separator, the permittee shall inform the City and County of Honolulu by sending a letter to the Department of Environmental Service, Regulatory Control Branch, 1000 Uluohia Street, Kapolei, Hawaii 96707 or by emailing to the following address: envpermits@honolulu.gov.
APPLICABLE TO ALL EXISTING AND NEW AMALGAM SEPARATORS
The amalgam separator(s) must be sized to accommodate the maximum discharge rate of amalgam process wastewater.
The devices(s) must be accompanied by the manufacturer’s manual providing instructions for use including the frequency for inspection and collecting container replacement such that the unit is replaced once it has reached the maximum filling level at which the device can perform to the specified efficiency.
The amalgam separator(s) must be inspected in accordance with the manufacturer’s operating manual to ensure proper operation and maintenance of the separator(s) and to confirm that all amalgam process wastewater is flowing through the amalgam retaining portion of the amalgam separator(s).
In the event that an amalgam separator is not functioning properly, the amalgam separator must be repaired consistent with manufacturer instructions or replaced with a unit that meets the requirements above as soon as possible. This must be done no later than 10 business days after the malfunction is discovered by the dental discharger or an agent/representative of the dental discharger. If a new amalgam separator is installed to replace a broken-down amalgam separator, the permittee shall inform the City and County of Honolulu by sending a letter to the Department of Environmental Service, Regulatory Control Branch, 1000 Uluohia Street, Kapolei, Hawaii 96707 or by emailing to the following address: envpermits@honolulu.gov
The amalgam retaining units must be replaced in accordance with the manufacturer’s schedule as specified in the manufacturer’s operating manual or when the amalgam retaining unit has reached the maximum level, as specified by the manufacturer in the operating manual, at which the amalgam separator can perform to the specified efficiency, whichever comes first.
ONE-TIME COMPLIANCE REPORT FOR EXISTING AND NEW SOURCES
For existing sources, a One-Time Compliance Report must be submitted to the City and County of Honolulu no later than October 12, 2020, or 90 days after a transfer of ownership. For new sources, a One-Time Compliance Report must be submitted to the City and County of Honolulu no later than 90 days following the introduction of wastewater into a Publicly Owned Treatment Works (POTW) facility. The one time compliance report form can be downloaded from the City’s website at envhonolulu.org. The report can either be sent through a letter to the Department of Environmental Service, Regulatory Control Branch, 1000 Uluohia Street, Kapolei, Hawaii 96707 or by scanning a copy and emailing it to the following address: envpermits@honolulu.gov
BEST MANAGEMENT PRACTICES (BMPs) FOR EXISTING AND NEW SOURCES
The following BMPs must be implemented:
Waste amalgam including, but not limited to, dental amalgam from chair-side traps, screens, vacuum pump filters, dental tools, cuspidors, or collection devices, must not be discharged to a POTW.
Dental unit water lines, chair-side traps, and vacuum lines that discharge amalgam process wastewater to a POTW must not be cleaned with oxidizing or acidic cleaners, including but not limited to bleach, chlorine, iodine and peroxide that have a pH lower than 6 or greater than 8.
EPA Dental Effluent Guidelines – Fact Sheet
EPA Part 441 Dental Point Source Category
American Dental Association Specification 108
Effluent Limitations Guidelines and Standards for the Dental Category