Dental Amalgam Program

Following EPA-issued rules regarding dental amalgam waste, Metro Water Recovery’s Dental Amalgam Control Program requires area dental offices to use a qualifying amalgam separator and comply with industry best management practices to reduce amalgam waste.

On June 14, 2017, the EPA issued a final rule regarding the handling of dental amalgam waste at 40 CFR Part 441, Effluent Limitations Guidelines and Standards for the Dental Category, with an effective date of July 14, 2017. The final rule requires dental offices to use a qualifying amalgam separator and comply with industry best management practices to reduce amalgam waste. 

Effective July 2, 2018, Metro’s Dental Amalgam Control Program’s Rules and Regulations were revised to better reflect this final federal ruling while continuing to meet our own local limits.  Metro’s program Rules and Regulations meet the requirements of the federal rule and are in some areas more stringent than the federal requirements. 

Questions about the program? Contact us.

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All dental facilities are required to comply with best management practices and requirements to operate and maintain an amalgam separator according to its manufacturer’s recommendations, as required by 40 CFR Part 441 and Metro’s Rules and Regulations, Section 6.16.1 – Dental Amalgam Control Program. Links to all forms are available under the Program Resources and Documents tab on this page. 

Dental Amalgam Control Program poster
Contact us for a laminated poster in English or Spanish.

Within 90 days of initial discharge, dental sources (both exempt and non-exempt) must complete a One-Time Compliance Report and, if non-exempt, also must submit with this report a copy of your Operations and Maintenance Plan.  All One-Time Compliance Reports must be signed by an Authorized Representative of the facility. Links to all forms are available under the Program Resources and Documents tab on this page. 

Please complete the report that most accurately fits your dental operations, and mail it to Metro Water Recovery at 6450 York Street, Denver, CO 80229.  Metro reserves the right to review and/or deny any exemption claims that do not match previously identified operations at your facility.  Information may also be verified via an on-site inspection by our staff. 

Be advised, failure to submit the One-Time Compliance Report within the 90-day deadline may result in enforcement action(s) that may include the assessment of penalties and/or suspension or termination of sanitary sewer service and/or other administrative or legal actions as provided for in Section 6.28 of Metro’s Rules and Regulations. 

These new regulations now allow a broader range for exemption status. Businesses may claim exemption status if any of the following apply:

  • 1. A business exclusively practices: 
  •      Oral pathology
    • Oral and maxillofacial radiology
    • Oral and maxillofacial surgery 
  •      Orthodontics
    • Periodontics
    • Prosthodontics
    • Mobile dentistry 
  • 2. Or, the dental facility does not place any amalgam, and whose removal of teeth with amalgam comprises less than 5 percent of the dental facility’s business.
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Failure to Comply


Any non-domestic discharger who fails to comply with pretreatment program standards and requirements faces the possibility of serious enforcement actions, including monetary penalties and termination of service. Our Pretreatment Enforcement Management System details the our policies and procedures for identifying, documenting, and responding to Pretreatment Program violations. Use the form on this page to submit an inquiry for more details about the program.
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Contact Us for Additional Information


Suzanne Renter, Amalgam Control Program Investigator

303-286-3128

srenter@mwrd.dst.co.us

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