The Environmental Protection Agency (EPA) finalized a rule in 2017 designed to reduce the amount of mercury entering the environment from dental offices, making it all-the-more important to utilize an effective amalgam separator. The EPA amalgam separator rule went into effect July 2020 and only impacts new installations. In this article we’ll attempt to answer the burning questions you might have regarding this rule and how it might impact your dental office.
Which type of dental offices are 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 individual 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.
What are the requirements?
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.
Is there a specific type of amalgam separator I should use?
Yes, 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.
Optional Additional Feature: 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.
What are the reporting and recordkeeping requirements?
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.
What are the reporting and recordkeeping requirements?
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 for EPA Compliance
HealthFirst and Rebec Environmental have collaborated to offer a comprehensive EPA-compliant amalgam recovery program for dental offices to help you stay compliant.
Amalgam Recovery Program
HealthFirst dental amalgam separators from Rebec® are a simple, affordable solution for amalgam separation in dental clinic wastewater
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