Manufacturers and Dental Supply/Service Companies Simply Quoting the EPA Regulation may NOT Keep You Compliant – Introduction and EPA Regulation History

Mentioned in many of the M.A.R.S® blogs; the thought of having an amalgam separator will ensure the compliance of your Dental Practice is incorrect. Many Dental Companies are releasing blogs, newsletters, advertisements, or social media posts, in hopes of making the EPA Regulation understandable. What these companies may not know; there is a lot of a grey area, and misunderstanding when it comes to the new EPA Amalgam Separator Regulation. Even governing bodies like Water Treatment Plants don’t have a firm grasp of compliance requirements.

So who do you believe? What does this mean for Dental Practices? Is there a way to make certain you comply with your local regulations? All good questions and the simple answer is; there is no right answer to all those questions, other than do your homework and buy the “Best Available Technology.”

Today’s blog will start a series helping you understand the history of the EPA Regulation, who will be regulating Dental Practices, what they may require, and how to best ensure your compliance.

EPA Regulation History

In 2014, studies were released, providing evidence that the highest source of soluble mercury pollution is from dental practices. The average Dental Practice was found to discharge 14,000 ng/L of total mercury, tested at the manhole cover. These levels are diluted by surrounding industries; when tested at the source, the mercury content is in the hundreds of thousands, if not millions parts per trillion. According to the Ohio based study, the mercury content from other industries has diminished over time, while Dental kept increasing the mercury discharge rates.

EPA Regulation

The issue with mercury amalgam, it generates and releases more mercury than basic mercury. As you may know, mercury amalgam contains tin, which has an ionic charge that releases mercury into its free state, gas. What might not be well known is, when this mercury is submerged underwater/liquids, it creates soluble/dissolved mercury at a high rate. Soluble mercury discharge is a significant concern to POTWs.

Purves Study (5)Mercury Discharge Chart

Since the release of this information, the EPA put restrictions on the mercury discharge of Water Treatment Plants. In the past, Water Treatment Plants use to purchase millions of gallons of freshwater to dilute the mercury content of their discharge. The EPA has squashed this practice, telling Water Treatment Plants to regulate the polluters because “dilution is not the solution to pollution.” Based on Independent Studies, the Water Treatment Plants and the EPA knows that Dentistry is the highest polluters of mercury waste into our waterways.

After the release, the EPA wrote a Regulation to give the power to the Water Treatment Plants to regulate the dischargers who are polluting mercury into the waterways. Unfortunately, after a committee of experts created the EPA Regulation, certain Dental Groups got their hands on the document and diluted the rule to the point the basic standards will not help Water Treatment Plants meet their own discharge standards.

Dilution of the EPA Regulation

Please follow the next segment of our series to learn why the EPA Regulation is a bare minimum requirement that will most likely change on the local level to allow your local Water Treatment Plant meet their local standards.