What May be Okay to Sell, May NOT be Compliant to Use- Evacuation Line Cleaners; Part 1

The EPA Regulation has had many manufacturers of infection control products on their toes. From amalgam separators to evacuation line cleaners, some companies should be making drastic changes to their products to meet the minimum standards of the EPA Regulations and Local Control Groups. This Three-Part Blog Series will be discussing why you can still purchase harsh and non-compliant evacuation line cleaners, how to determine what is safe and compliant plus highlighting some underhanded tricks used by manufacturers to make their product seem compliant.

 

New Regulations

Dental Professionals have to understand; in the past, evacuation line cleaners were not regulated. They could be made of almost any substance and be advertised as safe for dental staff, patients, the environment, and equipment. The truth is, some of the more common evacuation line cleaners on the market today are incredibly harsh and have not only been damaging your equipment and suction lines, but they have also been releasing mercury from your amalgam separator by dissolving the solid material into a soluble form.

Since the release of the EPA Regulation on July 14th, 2017, it has been understood that Dental Practices are not allowed to use any evacuation line cleaner outside of the pH range of 6-8. It has been found by during an independent study that water which is too acidic or too alkaline will dissolve mercury amalgam into a soluble form faster than if it were to be sitting in neutral water (Image 1). Studies like this are what prompted the EPA to include evacuation line cleaners in their Regulation.

Below are excerpts from the EPA Regulation Final Rule:

“The rule also requires dental dischargers to adopt two BMPs, one which prohibits the discharge of waste (”or scrap”), and the other which prohibits the use of line cleaners that may lead to the dissolution of solid mercury when cleaning chair-side traps and vacuum lines.” 27156 Federal Register / Vol. 82, No. 113 / Wednesday, June 14, 2017, / Rules and Regulations

“Oxidizing line cleaners can solubilize bound mercury. If oxidizing cleaners are used to clean dental unit water lines, chair-side traps, or vacuum lines that lead to an amalgam separator, the line cleaners may solubilize any mercury that the separator has captured, resulting in increased mercury discharges. One BMP ensures the efficiency of amalgam separators by prohibiting the use of oxidizing line cleaners including but not limited to, bleach, chlorine, iodine, and peroxide, that have a pH lower than 6 or greater than 8.” F27161 Federal Register / Vol. 82, No. 113 / Wednesday, June 14, 2017 / Rules and Regulations

NOTE: Even before the EPA Regulation, most Water Treatment Plants have had Regulations on the pH levels allowed for industrial discharge. An acceptable release of water into the public waterways is between the pH of 5-9.5, with some Water Treatment Plants going further by banning the use of phosphates. Now that the EPA has passed their Regulations, it has brought the Dental Industry under scrutiny from Water Treatment Plants, as it is understood that some dental practices discharge bleach, chlorine, iodine, peroxide, and phosphate-based products into the waterways. IN SOME US CITIES, IF YOU ARE CAUGHT RELEASING PHOSPHATES INTO THE CITY WATERWAYS, YOU WILL BE CONSIDERED AN INDUSTRIAL USER (IU) AND WILL HAVE TO MEET MUCH STRICTER STANDARDS OF DISCHARGE.

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If Evacuation Line Cleaners are Non-compliant, Why Can I Buy It?

M.A.R.S was recently asked by an online Dental Supply Company, how an evacuation line cleaner can be non-compliant when it is sold by the Large Supply Companies. The answer is quite simple; it is not illegal to supply the product; it only makes the dental practice non-compliant if they use it. If a dental practice is caught using an evacuation line cleaner that does not meet the EPA Regulation or Local Control Group standards, the dental practice will be held responsible, not the company who supplied the cleaner.

There can be a number of reasons why your Dental Supplier is still providing dangerous and non-compliant evacuation line cleaners. The most likely cause is a lack of understanding of the requirements of the EPA Regulation and local standards.Unfortunately, most Supply and Service Companies rely on the knowledge and honesty of their vendors to ensure the products they are providing their clients are compliant and safe. Even though most manufacturers have taken the moral routes of reformulating and correcting their products to ensure they meet or exceed standards, there are still some companies who have chosen to push their non-compliant products.

These dangerous evacuation line cleaners can not only damage the dental practices’ equipment and void manufacturer warranties, but they can also leave a dental practice non-compliant. In some rare cases, harsh evacuation line cleaners can result in an office being shut down or heavily fined.

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Continue to Learn More

Most evacuation line cleaners are used in a dental practice on the recommendation of a Service Technician or Sales Representative. It is great to have a trusting relationship with your Service and Supply Company, but even these trustworthy people can make mistakes. If you are considering a new line cleaner or just reordering your current solution, be sure to read next week’s blog about how to ensure the evacuation line cleaner you are purchasing will meet or exceed the EPA Regulation and your Local Control Group Standards.