From Kaitlyn Maxwell of GT Philadelphia:

The United States Environmental Protection Agency (“EPA”) has proposed standards for pretreatment of water that goes down the drain at a dentist’s office.  The proposed rule, available here, would require dental practices to meet technology-based pretreatment standards pursuant to the Clean Water Act for discharge of dental amalgam into publicly owned treatment works (“POTWs”), that is, municipal sewage treatment systems.

Dental amalgam contains mercury and enters the waste stream when a dentist fills a patient’s cavity, or removes an old filling.  The rule would require dental offices to control the discharge of mercury and other metals by using best available technology.  One available technology is an “amalgam separator” that removes solids that go down the chair-side drain or vacuum from wastewater.  Additionally, best management practices prohibit dental offices from flushing scrap amalgam down the drain and require offices to use a cleaner that does not contain bleach for chair-side traps because bleach can solubilize any mercury and increase discharge.

The proposed rule would also seek to streamline permitting and oversight requirements due to the large number of facilities subject to these proposed standards.  While EPA classifies the amalgam separator as an affordable and readily available technology, dentists should be aware of these proposed standards and any potential impact on their practice.  The deadline for public comment is December 22, 2014.

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Photo of Caleb Holmes Caleb Holmes

Caleb’s practice focuses on complex environmental litigation and environmental compliance. Caleb has represented clients in state and federal courts and in administrative proceedings. In his environmental litigation practice, Caleb often represents corporate clients in cost recovery, contribution and government enforcement actions under Comprehensive

Caleb’s practice focuses on complex environmental litigation and environmental compliance. Caleb has represented clients in state and federal courts and in administrative proceedings. In his environmental litigation practice, Caleb often represents corporate clients in cost recovery, contribution and government enforcement actions under Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Caleb has litigated such matters through trial and has also helped clients negotiate and settle matters. He has worked with clients on cases involving a wide variety of contaminants, including but not limited to PCBs, PFAS, and dioxins. Caleb also has broad experience litigating complex commercial litigation, including products liability and mass tort/toxic tort matters. He has a depth of experience with all aspects of discovery, including work with experts, taking and defending depositions, motion practice, trial preparation and settlement negotiation.

Caleb provides practical advice to clients in the acquisition and disposition of businesses and assets and the re-development of brownfield sites. He works with clients to achieve compliance with state-specific voluntary cleanup programs, including Pennsylvania’s Land Recycling Program (Act 2).

Caleb counsels clients on compliance with a broad range of federal and state environmental laws, including RCRA, the Clean Air Act, the Clean Water Act, and a host of other federal and state environmental laws.

In addition to his legal work, Caleb is active in various professional and civic organizations. He is currently serving as the Council’s Secretary for the Pennsylvania Bar Association’s Environmental and Energy Law Section.