“Why,” “Who,” “When,” “What” and “How”; Questions about the EPA Amalgam Separator Regulation: “How” to Guarantee Compliance Part 2

 

The last segment of this Blog Series is a continuation of our ““How” to Guarantee Compliance with the EPA Amalgam Separator Regulation. In our previous blog, we discussed how Dental Practices without amalgam separators could choose the right system to ensure their compliance. This blog is focused on those Dental Practices who already have an amalgam separator, but may not be compliant. There are Dental Practices who are in areas of the United States who already require amalgam separators or decided to be proactive and install an amalgam separator early. These Dental Professionals may think they are compliant when the 2020 deadline hits. The truth is, there have been surveys completed by major cities in North America who have found that 70% of amalgam separators are non-compliant.

Studies Find ISO tested Amalgam Separators Fail

A 2002 study completed by the Royal College of Dental Surgeons of Ontario had concluded that ISO tested amalgam separators cannot meet city standards once the amalgam separators are used in clinical applications. The efficiency of these systems drops below the percentage advertised by ISO, as the ISO testing does not take into account actual use of a Dental Practice (p.5, 11-12). Since the RCDSO study, there has been one other documented independent study completed on amalgam separators. This study, by Purves Environmental, had found;

“Under the proposed EPA Guidelines for separators, the problem of mercury entering the environment will not be solved. The separator in office #7 [the M.A.R.S LibertyBOSS] is the only unit that is capable of removing both solid and dissolved mercury from the environment. Their design provides the highest removal rate under normal operating parameters and treats both the total and dissolved mercury.” (2014 p. 5)

Simple Suggestions to Remain Compliant with the EPA Amalgam Separator Regulation

If you currently have an amalgam separator and you believe you are compliant, please read the rest of this blog to be certain your Practice is protected. The following are suggestions to improve the chance that your current amalgam separator is found compliant by your Local Control Group.

1) Know the Manufacturer Maintenance Requirements

All amalgam separators have different maintenance needs; the trick is to learn which amalgam separator has the least required maintenance. If you have an amalgam separator that has been sold to you by a service company, you most likely have a filter type amalgam separator. These are the most common systems in American, as service companies stand to make the most profit on the regular servicing of these systems.

If you have a filter based amalgam separator, you would most likely be required to inspect these systems once a week, because they are known to clog. Unfortunately, you cannot rely on your service

provider to complete this maintenance for you. Most Service Technicians lack the training on amalgam separators, and for them to maintain your filter based amalgam separator correctly, they would have to be in your office on a weekly basis.

For tips on the maintenance of the most common amalgam separators in North America, please watch the M.A.R.S Preventative Maintenance Videos.

NOTE: If you find that your current amalgam separator has been neglected and your system is on overflow. It is often more economical to replace the entire system at this point. Refer to our previous blog ”How” to Guarantee Compliance Part 1 to learn what to look for in a new amalgam separator.

2) Keep up with Maintenance/ Inspection Logs

As mentioned above, there are amalgam separators that require regular maintenance and weekly inspections. According to the EPA, you must keep weekly records on the required maintenance and inspection of your amalgam separator. These logs will be necessary to remain on record for three years.

3) Contact your Local Control Group

Do not be afraid to contact your Local Control Group to inquire about their standards and expectations. Despite what many might think, they are not out to get Dental Practices. Most Local Control Groups are happy to give you any resource you need to become compliant. The reason Local Control Groups have to require amalgam separators in Dental Practices is because amalgam separators are currently the best technology to remove total mercury (solid and soluble) out of our waterways. Because most Local Control Groups cannot meet their required mercury discharge limits, they do have to ensure all members discharging into their waterways are compliant. As long as Dental Practices continue to work with their Local Control Groups, they will remain friendly and assist you in becoming compliant.

With that being said, there has been some Dental Practice who have been confrontational with their Local Control Group; this resulted in an uneasy relationship. This course of action is not recommended as an Environmental Protection Specialist from the EPA Water Permits Division once told an M.A.R.S representative; Water Treatment is a privilege, not a right. And privileges can be removed if abused.

Though it is highly unlikely that a Dental Practice will be shut down for non-compliance, it is more typical for a Local Control Group to take deterrent measures to encourage compliance. Similar to what was done for the plating industry, many Control Groups are establishing fines for not meeting their discharge standards.

Blog Series Conclusion

Thank you for following the M.A.R.S Blog Series to the end. The goal of this seven segment blog on the EPA Amalgam Separator Regulation was meant to offer Dental Professionals the information they need to guarantee their compliance. Please keep reading M.A.R.S Blogs as we are constantly updating our information as the EPA Regulation and Local Control Groups requirements change. If you have not read the previous blogs in the EPA Amalgam Separator Regulation Blog Series, please click the below links;

Introduction to the EPA Amalgam Separator Regulation Compliance Blog Series

“Why” Dental Practices Require Amalgam Separators

“Who” Will be Regulating and Implementing the Amalgam Separator Regulation

“”When” Dental Practice is expected to Comply

“What” is expected from Dental Practices

“How” to Guarantee Compliance Part 1”