Best Management Practices for Mercury Waste Management in Dental Offices

The JEA Amalgam Best Management Practices (BMPs) for Dental Facilities are designed to comply with environmental regulations, prevent pollution, and assist dental offices in the proper management of mercury and amalgam waste in their day-to-day activities.

The JEA Dental Amalgam Program 

As part of the Dental Effluent Guidelines established by the Environmental Protection Agency (EPA) on June 14, 2017 (40 CFR, Part 441) the EPA will require all dental facilities that handle or remove amalgam in practice to install, operate, and maintain one or more appropriately sized amalgam separators or similar devices that have a 95% amalgam removal efficiency. This efficiency must be proven through an accredited laboratory. 

The EPA delegates this responsibility to the State of Florida Department of Environmental Protection (FDEP). In Jacksonville, the FDEP has delegated local authority to JEA. It is the responsibility of JEA’s Industrial Pretreatment program to regulate non-residential discharges to the publicly owned treatment works

In order to comply with this regulation, JEA will require all dental facilities to submit a one-time compliance certification. As long as the dental discharger is subject to this rule, they must keep the one time certification on file and make it available in the event of an inspection. Dischargers are also required to maintain files of amalgam removal device maintenance and amalgam removal manifests for a period of three (3) years and make them available in the event of an inspection. 

Amalgam Letter

Amalgam Form

JEA Amalgam Best Management Practices guide 

This best management practices guide contains a set of required and recommended operating procedures and guidelines designed to reduce the amount of mercury discharged to the JEA sanitary sewer system, a publicly owned treatment works (POTW). Proper implementation of these procedures is intended to protect Northeast Florida’s natural environment from the discharge of hazardous mercury-containing compounds.
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Because of the hazardous nature of mercury, JEA may require dental facilities to obtain an Industrial User Discharge Permit. By implementing these JEA Best Management Practices, dental facilities may be exempt from obtaining such a permit.

As part of the Clean Water Act, the National Pretreatment Regulation (40CFR 403) was established to protect publicly owned treatment works and the waterways into which they discharge. The Environmental Protection Agency (EPA) delegates this responsibility to the State of Florida Department of Environmental Protection (FDEP). In Jacksonville, the FDEP has delegated local authority to JEA (the electric, water, and sewer utility). It is the responsibility of JEA’s Industrial Pretreatment program to regulate non-residential discharges to the publicly owned treatment works.

This manual identifies certain practices that dental offices are required to follow. These requirements are summarized at the end of each topic as BMP Summary Requirements. In addition, guidance is given on optional practices that offer environmentally preferable practices for dental offices and may help save money through waste minimization. These will be summarized in each section.

Why We Are Concerned with Mercury

The practice of dentistry can result in the release of mercury-containing amalgam to the environment. Even though mercury is a naturally occurring element, it bio-accumulates in the tissues of fish as a persistent, toxic contaminant. In dental use, mercury is chemically bound to other metals such as silver, copper, tin and zinc to create a restorative material – dental amalgam.

Once in the environment, elemental mercury may be converted into a more toxic form that works its way up the food chain into larger fish. Fish, such as tuna, swordfish, king mackerel and tilefish, can have very high levels of mercury in their bodies. At these high levels, mercury can affect the developing human nervous system. Populations who are at greatest risk for health effects associated with consuming contaminated fish include pregnant women, women planning to become pregnant and children under the age of six.
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