The EPA Regulation for Amalgam Separators is being sent to print today!
Which means starting July 14th, 2017 dental practices in the United States will require having an amalgam separator by July 14th, 2020, at the latest.
As the regulation has passed and being sent to print, you will find that Privately/Publicly Owned Treatment Works (POTWs) will require dental offices to get an amalgam separator sooner than later. This is because the Water Treatment Plants (POTWs) have the issue of high mercury discharge and are aware that the highest pollution of mercury is coming from dental offices.
What Does the EPA Regulation Mean for Those Who Have an Amalgam Separator
For those of you who already have an amalgam separator and think you will be compliant, please read this article. Every ISO 11143:2008 amalgam separator will meet the EPA regulation, but they may not meet POTW standards. As an Independent Studies have shown, most amalgam separators create and release soluble mercury, a large concerned for your local POTWs. Please see this excerpt of the Purves Environmental Study on Amalgam Separators.
When the EPA Regulation is released, it cannot be enforced by the EPA. As stated in the regulation, this responsibility will be passed on to your local POTWs. In 2015, the EPA took away the POTWs ability to dilute water to meet their mercury discharge allowances. The EPA Regulation requires an ISO 11143 amalgam separator, the use of an evacuation line cleaner with the pH range of 5-8.5, as well as proper disposal of the dental waste. The amalgam separator will need to be maintained to manufacturer specifications (i.e.: if you were to install a filter type amalgam separator, their manual requires a weekly maintenance to check for clogging and over filling). For a detailed breakdown of the EPA Regulation please view follow this link EPA Regulation.
Preventative Maintenance Course.
In the EPA Regulation, if your local POTW deems your mercury discharge too high, they have the right to supersede the EPA and require a stricter standard for your practice. Soluble mercury is currently a big issue for POTWs, because they do not possess the technology to remove soluble mercury.
Should the local POTW deem your discharge too high, your offices will be forced to follow the Best Management Practices (BMPs) of your local POTW. This means your local POTW has to find the source of the pollution and resolve the issue. This could be done by setting fines, creating new local standards and regulations or selling pollution permits, to name a few options.
History Behind the Pollution
In 2014, studies were released, providing evidence that the highest source of soluble mercury pollution is from dental practices. As we all know, mercury amalgam contains tin, which has an ionic charge that releases mercury into its free state, which is a gas. What might not be well known, when this mercury is submerged under water it releases into soluble mercury at a high rate. This is a major concern to POTWs.
The Issue with ISO 11143
All amalgam separators are required to be ISO 11143 certified, which only tests for solid mercury. Unfortunately, the technology and standards of ISO testing on amalgam separators have not been updated to meet the current requirements of the POTWs who will be setting and verifying the discharge limits.
Generally, how amalgam separators work is based on settling of anything heavier than water. The issue with this method, as mentioned above, is when mercury amalgam is submerged in water it is released into its soluble form. This means these types of amalgam separators will generate and release soluble mercury, making it harder to meet the POTW discharge limits. The M.A.R.S LibertyBOSS goes one step further by adding an extra-large media bed to filter soluble mercury.
The LibertyBOSS has been independently tested to be the only amalgam separator to capture soluble mercury. This is one of the ways the M.A.R.S. LibertyBOSS is different from any ISO tested amalgam separator. Our process makes the LibertyBOSS not only the most Environmental amalgam separator but the Best Available Technology in the industry.
What is best for your Practice?
When you are deciding on an amalgam separator to for your practices, M.A.R.S. suggests the follow standards when making your decision; Does the amalgam separator manufacturer offer a written guarantee of compliance.
1)Does the amalgam separator manufacturer offer a written Guarantee of Compliance?
M.A.R.S. is so confident in the LibertyBOSS that we offer, in writing; “any practice with a LibertyBOSS will meet or exceed any local EPA or POTW Regulation. If you don’t meet the Standards, M.A.R.S. will make sure you do.” Why spend money on an amalgam separator without this guarantee?
2) Have you done some research?
It is a good idea to call around to different amalgam separator manufacturers to get information about the systems you are considering. Remember to ask them if they guarantee their product to comply with any current or future regulations, as your local POTW may not have their Best Management Practices written yet. Also, read the manual of the amalgam separator you are purchasing, many filter based amalgam separators require weekly inspections for filling and clogging.
Ask your service company which systems they sell, you will find, even the large service companies will only carry 2-3 systems. It would be a good idea to call different Dental Supply Companies, as amalgam separator manufacturers may choose to not work with every service company.
3)What maintenance is required and the costs that are involved?
We would suggest getting a 2 or 3-year estimate. When considering the cost, it is best to look at the whole cost of the unit which may include filter changes, recycling, and added maintenance. Often the cost of the service on some filter type units could be 2-3 times the cost of the amalgam separator alone. Look above the marketing, some systems will give you a “Free” amalgam separator. This is because filter based amalgam separators run on the Gillette Principal. “I will give you a free amalgam separator, as long as you keep buying my filters”
During your search for the right product, if the amalgam separator you choose has any maintenance, you bought the wrong amalgam separator. A maintenance based amalgam separator leaves a chance for failure, which has been known to damage suction pumps, cause complete office shut downs and repercussions from local regulating bodies (POTW). Though you might pay a service company to maintain your amalgam separator, it is still the Doctor’s legal responsibility to maintain their amalgam separator to manufacture specifications.
The LibertyBOSS only requires the use of a good, neutral pH evacuation line cleaner, daily (a process already done by many offices for maintaining and disinfecting your evacuation lines) and is changed out on the following schedule:
1 to 3 chairs up to 3 years
4 to 9 chairs up to 2 years
10 to 16 chairs up to 1 year
There is a reminder program in place, to assist your office in staying compliant.
The cost of the LibertyBOSS includes:
- Guaranteed Compliance for up to 3 years
- Safe Recycling and a reminder near the end of your system’s service life
- Written warranty against defects
- Free Advertisement as an Environmental Practice
Please remember, do not make this decision lightly. The right amalgam separator could be a large asset to your practice. It will not only protect your equipment and make them last longer, they will also protect your community for your patients and family. Making the wrong choice in amalgam separators could cost you and your practice.