EPA Amalgam Separator Regulation: Circulating Misinformation about Amalgam Separator Requirements – Part 1 “Grandfathering”

The battle to enlighten the Dental Industry on the truth about the EPA Amalgam Separator Regulation and what is expected from Dental Practices seems to be an uphill battle. Distortion and cherry picking of phrases from the EPA Amalgam Separator Regulation have been advertised heavily throughout the Dental Industry, further confusing the requirements from Dental Practices. Dental Professionals are encouraged to be careful where they get their information about the EPA Regulation. The high level of misinformation released to the public will require the use of critical thinking skills to ensure the correct information is being used to protect Dentists and their Practices.

The following two blogs are about two significant misinformation that M.A.R.S has found to keep occurring when Dental Professionals speak about the EPA Amalgam Separator Regulation. The first deceptive information about the EPA Regulation is the cherry picking of a few lines regarding “Grandfathering” existing amalgam separators. The second fabrication of the EPA Regulation is the notion that all amalgam separators require changing at a minimum of every 12 months. Both are a half-truth or whole lies, and hopefully, the following will help clarify is information.

“Grandfathering” Amalgam Separators

“If your practice has an existing amalgam separator, you can continue to operate it for its lifetime or 10 years, whichever comes first.” (1) A common line paraphrased from the EPA Amalgam Separator Regulation, often missing the rest of the rule. The rest of the line from the EPA Regulation reads “As long as the dental discharger complies with the other rule requirements including the specified BMPs, operation and maintenance, reporting, and recordkeeping requirements.” (2)

In a nutshell, if an existing amalgam separator (regardless of age) is found not meeting the discharge limits, your local “Control Groups” (most likely POTWs) are allowed to require you to replace your existing unit with “Best Available Technology.” This is according to the face to face meeting Michael Darcy, President of M.A.R.S Bio-Med, had with an EPA representative at a Water Treatment Plant Pre-Treatment Workshop in July of 2017.

 

EPA Amalgam Separator Regulation Deadline

If you are a Dental Professional who wishes to install an amalgam separator before the deadline of July 2020, to ensure you are making the right investment, it is suggested to follow the “One Rule” when they are considering purchasing an amalgam separator. The “One Rule”; Get a WRITTEN Guarantee of Compliance from any Amalgam Separator Manufacturer before purchasing their system. A manufacturer of a compliance product should be confident enough in their products to guarantee that all Dental Practices with their system will meet or exceed any current or future requirements. If the manufacturer cannot guarantee your compliance, why invest in their products?

References

(1) How To Make Sure Your Dental Practice Is Epa Compliant …” Dentistry iQ N.p., n.d. Web. 11 Sep. 2017 <http://www.dentistryiq.com/articles/2017/07/how-to-make-sure-your-dental-practic>.

(2) 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.