There are many flaws to the new EPA Regulation that has been confusing the regulators, Water Treatment Plants, and Dental Professionals. This segment of the series will be highlighting some of the mistakes made by the EPA when writing their regulation, as well as explain why your local regulator may not be as well versed in compliance as you may think. The last segment of this blog series touched on the EPA’s dilution of their regulation. The “Flaws in the EPA Regulation” segment will be touching on the following topics;
- Regulators don’t know Dental Industry
- “One-Time” Compliance Reports
- EPA’s wrong “Exemptions” list
- Regulators know how Amalgam Separators Work
- Issues with the ISO 11143:2008
- Understanding Evacuation Line Cleaners
Part one of the “Flaws in the EPA Regulation” will speak about the aptitude of your local regulators, the Water Treatment Plants. We want to explain our experiences with the ones M.A.R.S has trained, and help Dental Professionals understand what may happen in municipalities who may not have got the right education.
Water Treatment Plants Thrown into Regulating a New Industry
Your local Regulator for the EPA Regulation is most likely a representative of your Water Treatment Plants. The EPA has put the responsibility of writing, implementing, and enforcing BMPs for Dental Practices on the Water Treatment Plants, as they are responsible for dealing with the mercury from your discharge.
For those of you are unaware, these Water Treatment Inspectors are normally limited for a municipality, often in charge of inspecting many industries for compliance. Some of the industries, other than Dental, they are currently responsible for are;
- Gas stations
- Car Washes
There are typically thousands of business and only a handful of inspectors. Before the new EPA Regulation, Water Treatment Plants knew nothing about the Dental Industry, as many of them do not have access to proper training. The lack of understanding may be to the benefit of the Dentist in the beginning, but remember, as the Water Treatment Plant’s understanding changes, so will their requirements. Never assume what is required now will remain. That is why it is important a Dental Practice stay vigilant with their amalgam separator maintenance, inspections, and compliance. You never know what your inspectors may require from you in the future.
Figure 1- Water Treatment Plants Inspector Checklist for Amalgam Separators
The easiest way of ensuring your compliance is to get an amalgam separator that requires no inspections, no maintenance and guarantees your compliance.
Flaws in the EPA Regulation Continued
Follow us Friday where we will be continuing part two of the EPA Flaws section of this blog series. Our next segment will be discussing “One-time” Compliance Reports and how the EPA got their “exempted” list of Dental Specialties incorrect.