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What You Should Know About the EPA’s Rule on Dental Amalgam Separation

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.

 

EPA rules for Dental Wastewater

 

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.

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