EPA Dental Amalgam Rule – Top 5 Things to Know

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Scrap amalgam waste dental amalgam capsules

The Environmental Protection Agency (EPA) has officially signed and submitted the final rule on dental amalgam effluent limitations for publication in the Federal Register (FR).  With the rule going into effect in January 2017, HealthFirst is helping inform dental practices of the top 5 things they need to know about the new EPA dental amalgam rule.

Practices Affected by the EPA Dental Amalgam Rule

This rule applies to all offices that practice dentistry and discharge their wastewater to a Publicly Owned Treatment Works (POTW), including large institutions and dental clinics.  It does not apply to mobile units or certain dental specialties, such as: oral pathology, oral and maxillofacial radiology, oral and maxillofacial surgery, orthodontics, periodontics, or prosthodontics.

EPA Requirements for Affected Offices

If you are a dental office that places or removes amalgam and discharges to a POTW, you must do the following:

  • Operate and maintain one or more ISO 11143 compliant amalgam separators.
  • Follow two Best Management Practices (BMP)
    • Must not discharge scrap amalgam waste to POTWs.
    • Must not use line cleaners that have a pH level higher than 8 or lower than 6.

ISO 11143 Compliant Amalgam Separators

The EPA rule states that all amalgam separators installed by dental practices must achieve ISO 11143 standards for mercury removal efficiency and design requirements.  The International Organization for Standardization (ISO) established standard 11143 for measuring amalgam separator efficiency and included certain design requirements for proper use and maintenance.

The EPA rule requires that all amalgam separators being installed today must achieve at least a 95% removal efficiency.  The EPA also recognizes that offices may currently have amalgam separators in place that do not meet the new requirements.  These offices are allowed to continue to operate these older separators for their lifetime or ten years (whichever comes first) as long as the dental practices comply with the other rule requirements, such as following the specified BMPs, operation and maintenance, reporting and record keeping requirements.

Visual or Auditory Warning Indicator

Because warning indicators make it easy to detect when the separator is not operating optimally, the ISO 11143 standard requires that all non-sedimentation separators must have an auditory or visual sign warning indicator when the separator is nearly full or in by-pass mode.

While not required for sedimentation amalgam separators, some manufacturers of these separators have included visual or auditory warning indicators into their design.

Compliance Reports and Maintenance Records

All dental offices, whether they place or remove amalgam, must submit a One-Time Compliance Report to Control Authorities.

For dental offices that place or remove dental amalgam, the One-Time Compliance Report must include information on the dental facility and its operations and a certification that the dental discharger meets the requirements of the applicable performance standard.

For dental offices that do not place or remove dental amalgam (except in limited circumstances) the One-Time Compliance Report must include information on the facility and a certification statement that the dental discharger does not place dental amalgam and does not remove amalgam except in limited circumstances.

Amalgam Separator Operation and Maintenance Records

For those offices required to install an amalgam separator must also maintain records of ongoing operation and maintenance.  These maintenance records can be facilitated by third parties, such as dental office suppliers and amalgam separator manufacturers.

 

HealthFirst Amalgam Recovery Program: the Right Solution for EPA Compliance 

HealthFirst and Rebec Environmental are ready to respond to the EPA rule by offering a comprehensive, cost-effective amalgam recovery solution for dental practices, which is endorsed by ADA Business Resources.

Rebec Amalgam Separators

rebec-400and1000_separator-comboThe Rebec Catch HG line of amalgam separators exceed the ISO 11143 compliance required by the EPA rule by effectively filtering out 99.6% of waste mercury from your office’s wastewater.  They are also built out of highly durable stainless-steel, which allows HealthFirst to offer a 100% product replacement warranty for the life of the product against manufacturer defects to all ADA members who purchase and maintain the system through our Amalgam Recovery program.

HealthFirst Amalgam Waste Recovery Containers

awr_1-3-5gal-containers_400pixPrevent scrap amalgam waste from being discharged into the POTW by using HealthFirst’s line of Amalgam Waste Recovery containers.  These ADA and ANSI 109 approved mail-back systems come in 3 convenient sizes (1.25, 3.5 and 5 Gallon) and the UPS prepaid return shipment and waste processing service is included in the price.

VacuBlu Evacuation Line Cleaner and Amalgam Separator Conditioner

VacuBluvacublu01 is a simple and easy solution to keep your vacuum lines clear and your amalgam separator working properly. VacuBlu is a concentrated, aqueous, enzymatic, biodegradable dental vacuum line cleaner, which is safe for use on all vacuum equipment and specially formulated for amalgam separator maintenance. It has a neutral pH that is within the levels required by the EPA rule and contains no bleach or chemicals that can dissolve amalgam particles.

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Dr. Donald Cohen, a trusted figure and key opinion leader, has been a licensed and practicing dentist for over 30 years. Additionally, Dr. Cohen has 20 years of teaching experience at Columbia University SDOS, and 20 years as an Attending Dentist at Columbia Presbyterian Hospital in New York City. With his many years of experience in the field and in the classroom, “Dr. Don” is an expert in the areas of dental compliance, regulations, and best practices.

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