From the Winter 2017 Journal of the Colorado Dental Association
On Dec. 15, the federal Environmental Protection Agency (EPA) issued a final regulation regarding the handling of dental amalgam waste. The new federal rules will require most U.S. dental offices to use a qualifying amalgam separator and comply with industry best management practices (BMPs) to reduce amalgam waste. Dental offices will have three years to come into compliance with the newly issued EPA standards.
Amalgam Separator Requirements:
- Install an ISO or ANSI-compliant amalgam separator before 2020.
- Correct any problems or deficiencies within 10 business days if an amalgam separator stops working properly.
- Replace the amalgam separator according to the manufacturer’s recommendations.
- Maintain documentation of meeting certain amalgam separator operation and maintenance standards for at least three years (or contract with a vendor to provide these services). Maintain documentation on any inspections, repair, container replacement, system replacement and waste disposal.
- Make records available to local wastewater districts for inspection.
BMP Requirements:
- Do not discharge or flush scrap amalgam into drains. This includes amalgam from chair-side traps, screens, vacuum pump filters, dental tools, cuspidors or collection devices.
- Use a compliant line cleaner. Do not use certain oxidizing or acidic cleaners that may dissolve amalgam. Restricted oxidizing line cleaners include but are not limited to bleach, chlorine, iodine, peroxide and other chemicals that have a pH lower than six or greater than eight. Many alternative cleaners use enzymatic or other processes that do not lead to the dissolution of mercury when used to clean chair-side traps and vacuum lines.
Additional requirements:
- File a one-time compliance report with your local wastewater treatment district.
- Update the compliance report within 90 days of a change in practice ownership.
- Comply with any additional standards imposed by your local wastewater treatment district.
Exemptions:
- Dental offices whose practice is limited to the following specialties: oral pathology, oral and maxillofacial radiology, oral and maxillofacial surgery, orthodontics, periodontics or prosthodontics.
- Dental offices that do not place or remove amalgam must complete a one-time form to secure an exemption from further requirements.
- Local jurisdictions may have more stringent regulations that restrict these exemptions.
Many Colorado dentists are already subject to local ordinances and water district regulations requiring the use of amalgam separators. EPA standards supplement existing local and state standards. The requirements of wastewater treatment districts that have more stringent standards will continue to apply. If the EPA’s standard for a policy category is more stringent than local standards, the EPA standard will apply. Dental offices that have already installed amalgam separators to meet local standards are permitted to continue to operate existing separators for their manufacturer-specified lifetime or 10 years (whichever comes first), as long as the office complies with the other rule requirements, including BMPs.
For Denver area dentists who recently went through compliance with Metro Wastewater Reclamation District amalgam separator requirements, no major changes are expected at this juncture. Amalgam separators that met the Metro District’s standards should meet the new EPA requirements and the Metro District already requires local dental offices to comply with EPA-required BMP standards. The CDA is closely coordinating with the Metro District and will keep members informed of any proposed changes to the local program.
Over the last several years, the CDA has worked to prepare members for this policy change. Since 2009, the CDA has worked with SolmeteX to provide amalgam separators at special CDA member pricing to interested dental offices. SolmeteX provides amalgam separators, installation support and waste disposal/recycling services.
CDA members who purchase a SolmeteX Hg5 amalgam separator system will receive a free Hg5 collection container as a CDA benefit (a $189 value). In addition, the CDA has worked with SolmeteX to offer a free Hg5 recycling kit (a $126 value) as part of this special offer. Visit cdaonline.org/solmetex for more information.
While acknowledging that less than 2% of the mercury released into the environment is estimated to come from dental uses, the ADA has encouraged good stewardship efforts among the profession with respect to dental amalgam in the waste stream. The ADA advocated extensively with the EPA in developing fair and reasonable standards for the profession through the new rule.
In Brief: What Dental Offices Need to Do
- Install an ISO-compliant amalgam separator before 2020
- Do not flush amalgam scrap into drains
- Use a compliant line cleaner
- File a one-time compliance report with your local wastewater treatment authority
- Update the compliance report within 90 days of a change in practice ownership
- Inspect the amalgam separator to ensure it is working in accordance with the manufacturer’s operating manual
- Maintain operation and maintenance records for at least three years (or contract with a vendor to provide these services)
- Correct any problems or deficiencies within 10 business days if an amalgam separator stops working properly
- Replace the amalgam separator according to the manufacturer’s recommendations
- Comply with any additional standards imposed by your local wastewater treatment authority