Thank you for following M.A.R.S’ blog series on the breakdown of our EPA Regulation Flowchart. In 2017, M.A.R.S created this flowchart to make the 94 page EPA Regulation much easier to understand and more accessible to the entire Dental Industry.
Our last blog release discussed who requires amalgam separators and which offices are exempt from the EPA Regulation. Today, we will be discussing installation and compliance deadlines for those Dental Practices who requires an amalgam separator.
Installation/Compliance dates are where many Dental Professionals get confused with the new Regulation. To make it simple, M.A.R.S breaks the installations into three dates.
After June 14th, 2017
Any Dental Practice built after June 14th, 2017 will be required to have an amalgam separator installed in their practice within 90 days of opening. Depending on your local regulators, this rule could apply to existing Dental Practices without a compliant amalgam separator or Dental Professionals who are renovating their office.
Dental Professionals have to be aware; the EPA Regulation is a bare minimum requirement that can be superseded by your local regulator.
July 2020 is USA’s National cut-off date for compliance. By July of 2020, every Dental Practice who are not considered “exempt” from the rule, will be required to have a legal, functioning amalgam separator in their office.
Before July 2020
As mentioned above, the EPA Regulation is just a starting point. Many Water Treatment Plants have already sent out their compliance due dates, much earlier than July 2020.
Up to the point you are required by your local regulator or the EPA to install an amalgam separator, it is up to you to choose when to install your amalgam separator. You can wait for your local deadline, whenever it may be. Just remember, there are only 10 amalgam separator manufacturers who supply
North America. Each of these manufacturers has the ability to produce a finite amount of units. If 85,000 dentist decided to purchase an amalgam separator within 6 months of the July 2020 cut-off date, you might find getting any amalgam separator in time for your compliance due date, let alone the system you want, increasingly expensive and difficult.
Adopt EPA Regulation Compliance Early
Begin researching now; it may pay off to become compliant earlier than later, especially since many manufacturers are providing discounts to achieve compliance early. The important factors to consider are;
1) Ask for a Guarantee of Compliance in Writing
2) Ensure you get a Guaranteed Service Life breakdown or an accurate service life expectancy for your unit. The guaranteed service life will give you an accurate depiction of costs.
Existing Amalgam Separator
There is a lot of misinformation in the Dental Industry about offices with an amalgam separator installed BEFORE June 14th, 2017. Many Dental Professionals believe that their current amalgam separator will keep them compliant because they believe they are “grandfathered” into compliance. Unfortunately, that is 100% incorrect. Many amalgam separator manufacturers are guilty of using the “grandfathering” rule to trick Dental Practices in buying an amalgam separator early. The reason for this misinformation; most people did not read the entire sentence regarding existing amalgam separators. Most people who read the EPA Regulation reads the first part of the regulation pertaining to “grandfathering.” If you keep reading the sentence, you will find that no amalgam separator is “grandfathered” (see the highlighted parts below). At any point, your local regulator can require you to find better technology if your current amalgam separator does not meet their discharge limits.
The best way to avoid having to reinvest in a new amalgam separator is to get some kind of guarantee of compliance from your amalgam separator manufacturer.
Up Next – “One-Time” Compliance Reports
Follow us for our next release to learn who will be regulating you, what would they be expecting, and what you need to comply with their Best Management Practices.