EPA Amalgam Separator Regulation: Circulating Misinformation about Amalgam Separator Requirements- Part 2 “Change Annually”

Our last blog on EPA Amalgam Separator Regulation Misinformation discussed the “Grandfathering” rule in the EPA Regulation. We further expanded on and explained the meaning behind the rule and how it is not a haven for Dental Practices with current amalgam separators. This blog is about some creative marketing that states a non-existing segment of the new EPA Regulation.

 

The Inaccurate “Changed Every 12 Months Rule”

A common misinformation about the EPA Amalgam Separator Regulation that is circulating around the Dental Industry is; “Doesn’t the EPA regulation state that containers must be changed out when full OR at the one year mark?”

Unfortunately, this misinformation about service life has been floating around, confusing dental professionals for some time. Information that could be coming from amalgam separator manufacturers trying to level the playing field to compete against superior technology. The truth is, there is an amalgam separator that is “Best Available Technology,” can last for several years without any service or maintenance, and can meet all local and federal regulations because it can capture soluble mercury. Having the ability to capture soluble mercury is a requirement of many Water Treatment Plants. Independent studies done by Water Treatment Plants, have measured up to 50% of the mercury discharge from a dental practice is soluble mercury. The M.A.R.S LibertyBOSS is the only amalgam separator to capture soluble mercury, making it the new Standard in amalgam separation.

EPA Amalgam Separator Regulation

An amalgam separator (according to EPA Regulation) needs to be maintained to manufacturer’s specifications. Please see segments below, pulled from the EPA Amalgam Separator Regulation pertaining to this half-truth.

 

Segments of the EPA Amalgam Separator Regulation Concerning Amalgam Separator Required Maintenance

Page 87 of 94
(ii) The amalgam separator(s) must be sized to accommodate the maximum discharge rate of amalgam process wastewater.
(iv) The amalgam separator(s) must be inspected in accordance with the manufacturer’s operating manual to ensure proper operation and maintenance of the separator(s) and to confirm that all amalgam process wastewater is flowing through the amalgam retaining portion of the amalgam separator(s).
(v) In the event that an amalgam separator is not functioning properly, the amalgam separator must be repaired consistent with manufacturer instructions or replaced with a unit that meets the requirements of § 441.30(a) (i) and (ii) as soon as possible, but no later than 10 business days after the malfunction is discovered by the dental discharger, or an agent or representative of the dental discharger.

Page 88 of 94
(vi) The amalgam retaining units must be replaced in accordance with the manufacturer’s schedule as specified in the manufacturer’s operating manual or when the amalgam retaining unit has reached the maximum level, as specified by the manufacturer in the operating manual, at which the amalgam separator can perform to the specified efficiency, whichever comes first.

Page 88 of 94
(iv) The devices(s) must be accompanied by the manufacturer’s manual providing instructions for use including the frequency for inspection and collecting container replacement such that the unit is replaced once it has reached the maximum filling level at which the device can perform to the specified efficiency.

Conclusion

Simply put, if the manufacturer of an amalgam separator doesn’t believe enough in their product to offer a WRITTEN GUARANTEE to comply with any local or federal regulation, then Dentists shouldn’t be spending their money on a compliance product that doesn’t offer such a guarantee.

Please visit the M.A.R.S Blog Page to learn more about the EPA Amalgam Separator Regulation and the requirements of Dental Practices. M.A.R.S encourages the Dental Industry to not rush into any decision about amalgam separators. Take your time, do your homework, with a little research you will find, as regulators do, the M.A.R.S LibertyBOSS is the “Best Available Technology” and the best amalgam separator for Dental Practices.

Reference

Effluent Limitations Guidelines and Standards for the Dental Category. (2017, February 09). <https://www.federalregister.gov/documents/2017/06/14/2017-12338/effluent-limitations-guidelines-and-standards-for-the-dental-category> Updated July 14, 2017. Accessed September 11, 2017.

 

Please visit the M.A.R.S Blog Page to learn more about the EPA Amalgam Separator Regulation and what will be expected from Dental Practices. M.A.R.S encourages the Dental Industry to not rush into any decision about amalgam separators. Take your time, do your homework, with a little research you will find, as regulators do, the M.A.R.S LibertyBOSS is the “Best Available Technology” and the best amalgam separator for Dental Practices.