Manufacturers and Dental Supply/Service Companies Simply Quoting the EPA Regulation may NOT Keep You Compliant – Flaws in the EPA Regulation – Part 3

We began this blog series giving the history of the EPA Regulation, then continued to speak about how it became diluted; resulting in the flawed regulation that it is now.

Today, we continue this series discussing the Flaws in the EPA Regulation. So far, we have discussed the following issues with the EPA Regulation;

  • Regulators don’t know Dental Industry
  • “One-Time” Compliance Reports
  • EPA’s wrong “Exemptions” list

“Flaws in the EPA Regulation” segment continues to discuss the following topics;

  • Regulators know how Amalgam Separators Work
    • Issues with the ISO 11143:2008
  • Understanding Evacuation Line Cleaners

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.

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Generally, amalgam separators work on the principle of sedimentation, capturing any material heavier than water.

The issue with this method 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 capture soluble mercury.

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The LibertyBOSS has been independently tested, at EPA Standard 245.7, to be the only amalgam separator to capture soluble mercury. This is one of the ways the M.A.R.S LibertyBOSS differs from any ISO tested amalgam separator. Our process makes the LibertyBOSS not only the most Environmentally Friendly amalgam separator but the Best Available Technology in the industry.

Vague Evacuation Line Cleaner Standards

A study completed in 2014 had shown that mercury amalgam dissolves when underwater. When that mercury is exposed to a pH outside the range of neutral, the mercury dissolves at a faster rate. For this reason, the EPA Regulation requires Dental Practices to use a non-oxidizing, non-corrosive, neutral pH evacuation line cleaner. Unfortunately, the EPA Regulation is not very specific to what is acceptable, and which cleaners should be used in a clinic.

There are a lot of evacuation line cleaners on the market, many of which are not EPA compliant, and even more that can void the warranty of your Dental Equipment. In the past, M.A.R.S has provided a blog series highlighting the means in which a Dental Professional can choose an effective, neutral pH, non-foaming evacuation line cleaner.

Neutral pH – Acidic and Alkaline Cleaners can damage metals in suctions lines and equipment, as well as void warranties.

Non-foaming – Foaming Cleaners can damage Dry AND Wet Vacuums

Safe for Staff – Many SDS requires special equipment when handling. Be sure the staff is well trained in the appropriate handling. Cost-Effective – Many cleaners can get rather expensive, especially if they are overused.

In the past M.A.R.S has expressed, just because the cleaner is wildly used, expensive, or recommended by your supply company does not mean it is compliant, nor effective. The dentist should do their own research, get feedback from other Dental Professionals, look for before/and after photos. Unfortunately, because of the EPA’s new rule, many manufacturers scrambled to make a line cleaner that meets the EPA standard but could be found to be ineffective.

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How to Ensure your Compliance

Now that you have learned the history of the EPA Regulation, understand your regulators, and have seen the flaw in the EPA Regulation; how do you ensure your compliance? Follow the last segment of this series to learn the simplest and most economical way to ensure your amalgam separator compliance.