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The dental profession has long acknowledged the impact of dental amalgam on the environment. In the year 2014, the American Dental Association adopted nine principles on keeping amalgam particles out of dental office wastewater. Then, following consultation between the ADA and the Environmental Protection Agency, the EPA finally issued a final rule on amalgam separation on June 9, 2017; now, most dentists have until July of 2020 to comply.

The final rule sets guidelines on everything from how to dispose of amalgam waste to minimum efficiency standards for amalgam separators (right down to the decimal point.) Though they may appear daunting, these regulations are not far from the existing APA best practices, and practitioners who start now should have no trouble meeting their obligations by 2020.

Dental Economics magazine has published a helpful summary of the rule. These are the main takeaways for dentists and other dental professionals looking to incorporate amalgam separation into their practices.

Who Needs to Use an Amalgam Separator?

Most dental offices in the United States are subject to the EPA’s rule on amalgam separation. In most cases, even those practitioners who do not place amalgam fillings must begin using amalgam separators. However, there are notable exceptions.

• Certain dental specialists may be exempt from the rule, including practices that specialize in oral pathology, oral and maxillofacial radiology, orthodontics, periodontics or prosthodontics.
• The rule does not apply to mobile units.
• Dental practices that neither place nor remove amalgam except in limited circumstances (which the rule defines as fewer than 5% of procedures or nine cases per year) may not have to use an amalgam separator.

If your practice falls into one of these categories, it is possible you may not have to start using an amalgam separator. However, certain localities have dental amalgam pre-treatment requirements, and many states have rules that exist alongside the EPA’s new guidelines.

How Does the EPA’s Final Rule Differ from ADA Best Practices?

Although the American Dental Association worked with the EPA to develop the requirements, the result does differ from the ADA’s best practices in several important ways. The most significant differences are:

• Amalgam separator efficiency requirement. The ADA recommended that dental offices use a system that removes at least 95% of amalgam particles from wastewater, in line with 2008 ISO 11143 standards. The EPA requires an amalgam separator to be 2008 ISO 11143–certified and remove 99% of amalgam particles.
• Frequent inspections. The EPA imposes onerous inspection requirements on all dental offices that use an amalgam separator. Dental professionals must inspect the equipment as per Manufacturer Instructions and generate a visual inspection log that details who conducted the inspection, the results of examining each device, and a summary of any follow-up actions. 

Most amalgam separators manufactured and sold in the United States and Canada claim to operate at 99% efficiency. However, dentists who have already invested in the equipment should confirm that their system meets the EPA requirements before 2020.

How Can Dentists Demonstrate Compliance?

The rule requires that dental practitioners report compliance annually to their respective state Control Authority.

The Control Authority differs state-to-state, but it is typically an EPA regional office, a local wastewater utility, or a state environmental agency. Dentists in Alabama, Connecticut, Mississippi, Nebraska and Vermont should report to their state environmental agency; dentists in all other states can contact their regional EPA office to find out who acts as the Control Authority in their state.

You can read more about the importance of dental amalgam separation and tips for compliance on our blog.

 Please visit www.dds-epa.org for FREE record keeping software and more information.

Dental amalgam has long been recognized as a safe and affordable material for fillings. However, the American Dental Association (ADA) acknowledges that amalgam waste from dental offices in the United States contribute 29.7 tons of mercury pollution to wastewater systems each year. This statistic prompted the Environmental Protection Agency (EPA) to finalize regulation on the use of amalgam separators in 2017.

Copyright: 123RF Stock Photo

This article provides an overview of the use of amalgam separation in the dental office, including the ADA’s best practices on amalgam separators.

Dental Amalgam and Mercury Pollution

Dental amalgam consists of approximately 40 to 50% mercury, 25% silver, and 25 to 35% mixture of copper, zinc and tin. These materials are bound together as a hard, stable substance.

Amalgam has been subject to numerous studies and reviews that demonstrate it is safe and effective for use in dental fillings. The problem with amalgam is not its effect on dental patients, but rather the difficulty of disposing of dental amalgam safely.

When dentists place new amalgam fillings or remove old ones, water containing amalgam particles is flushed into chair-side drains. These mercury-containing particles then enter the wastewater disposal system and water treatment plants. From there, the amalgam particles may be incinerated, land-filled, or made into fertilizer pellets for lawns or gardens. In each case, mercury from amalgam fillings is discharged into the environment, where it may bioaccumulate in fish and contaminate the food chain.

To summarize, dental offices that work with amalgam fillings (including “mercury-free” practices that only remove them) flush amalgam particles containing mercury down the drain and into the wastewater system. These particles ultimately become environmental pollutants.

One survey found that dental amalgam is the greatest contributor of mercury pollution in the wastewaters of California, Minnesota, Ohio, and Maine; numerous studies have also identified the dental industry as the top source of mercury in sewers in Canada and Europe.

Regulating the Use of Amalgam

The EPA’s National Pollution Discharge Elimination System (NPDES) mandates the reduction of mercury and other contaminants to ensure the discharge does not negatively affect water quality or people’s health. On July 14, 2017, the agency finalized regulation specifically targeting the use of dental amalgam.

The regulation applies to most dental practices that discharge waste into a public sewer or wastewater system. The basic requirements are:

• Using amalgam separators (or equivalent devices) to remove dental amalgam solids from all amalgam process wastewater;
• Implementing best management practices;
• Complying with reporting requirements; and
• Maintaining certain records documenting compliance.

Practices have until July 2020 to comply.

What Are Amalgam Separators?

An amalgam separator is a device installed on a dental vacuum line to filter out mercury and other particles from water waste before they enter the sewer system. The captured mercury can then be recycled to industry or safely disposed of.

Traditionally, dental practices used chair-side traps and vacuum filters to capture amalgam waste; however, the ADA estimates that 6.5 tons of mercury bypass these filters annually.

Amalgam separation is proven to reduce the impact of amalgam on environmental pollution. In Toronto, the amount of mercury in wastewater sludge decreased by 58% after regulation requiring the use of amalgam separators in dental offices took effect.

In addition to reducing environmental pollution, using an amalgam separator can help to extend the life of vacuum pumps by preventing solid particles from entering and damaging the pump.

To comply with EPA regulation, an amalgam separator must be ISO 11143:2008-certified to remove greater than 95% of solids by weight. Most amalgam separators on the North American market meet this standard.

Amalgam Separation Best Practices

To assist in complying with the new regulation, the ADA has published best practices for the use of amalgam separators. These practices recommend that dental practitioners:

• Use chair-side traps, vacuum pump filters, and amalgam separators to capture and recycle amalgam particles.
• Use pre-capulated mercury alloys instead of bulk mercury in amalgam fillings.
• Salvage, store and recycle scrap amalgam whenever possible, including amalgam pieces from restorations and used disposable amalgam capsules.
• Recycle teeth that contain amalgam restorations (ask your recycler whether these teeth must be disinfected first).
• Never dispose of amalgam waste in biohazard containers, regular garbage, or down the drain.
• Flush wastewater lines with line cleaners that minimize dissolution of amalgam (like BioPure Evacuation System Cleaner) instead of bleach or chlorine cleaners.

By implementing these practices and following the EPA regulation, dental practitioners, specialists, and registered dental hygienists can work towards reducing their impact on the environment.

Contact us to learn more about line cleaners that minimize amalgam dissolution. We look forward to assisting in building a more sustainable dental practice.