“Why,” “Who,” “When,” “What” and “How”; Questions about the EPA Amalgam Separator Regulation: “What” Are the Expectations of Dental Practices

Thank you for following the M.A.R.S Blog Series on the EPA Amalgam Separator Regulation. You may have already read the first four blogs of this series; “Introduction to the EPA Amalgam Separator 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

The fifth blog of this series will be discussing what will be expected from Dental Practice when they are asked to act by their Local Control Group’s BMPs.

As you may have read in the “Who” portion of our Blog Series, it is the responsibility of the Local Control Groups to create, implement and regulate BMPs for dental practices. Each Local Control Group expectations and standards can be different, as each Local Control Group have different criteria to meet. What is known for sure is the EPA Regulation is the starting point or “bare minimum” requirements set by the EPA. It is entirely up to the Local Control Groups to decide to supersede the EPA Regulation or to follow the EPA set conditions. Many Control Groups find the EPA Regulation to be inadequate, which would mean they would most likely opt to create higher standards in their BMPs. Many of these Control Groups are looking to include the capture of soluble mercury, as mentioned in our “Why” blog of this series, it is a known issue for Water Treatment Plants.

EPA Amalgam Separator Regulation Ohio Flow Chart

The EPA Requirements Flow Chart, released by the Ohio EPA, will give the Dental Professional an easy layout of what is expected by the EPA Regulation. Below you can see the flow chart for the requirements of the EPA Regulation along with a quick explanation for each requirement.

EPA Amalgam Separator

Maintenance/Inspection Logs As M.A.R.S followers would have read in our blog EPA Amalgam Separator Regulation: Circulating Misinformation about Amalgam Separator Requirements- Part 2 “Change Annually”, some amalgam separator manufacturers have been confusing the dental industry with wrong information about the required maintenance of amalgam separators. Some Dental Professionals may have heard the EPA Amalgam Separator Regulation requires amalgam separators to be changed annually, this is untrue. Amalgam separators are required by the EPA Amalgam Separator Regulation to be maintained to manufacturer specifications. In addition to the rule on maintenance, if your amalgam separator requires weekly inspections, like filter based amalgam separators, it may be mandatory to keep weekly logs of the examinations on record for up to three years. The extra required maintenance will need further training requirements and add another task to Dental Staff’s already hectic workload. If your Local Control Group requires logs on maintenance and inspections, you may want to consider a NO maintenance amalgam separator, like the M.A.R.S LibertyBOSS.

Soluble Mercury

Soluble mercury is one of the largest concerns for Water Treatment Plants, as they currently lack the technology to capture soluble mercury. There are only limited options for those Water Treatment Plants who cannot meet their discharge limits set by the EPA. As mentioned in the “Why” segment of this Blog Series, the best available solution for Local Control Groups is to capture the total mercury (solid and soluble) at the source, which is Dental Practices.

Unfortunately, for Local Control Groups and Dental Practices, most ISO tested amalgam separators cannot capture soluble mercury. ISO 11143:2008 is an outdated testing standard for amalgam separators, as it only tests for solids mercury in non-clinical applications. In a study completed by the Royal College of Dental Surgeons of Ontario, they had found that most amalgam separators cannot meet city standards as they do not capture their advertised ISO separation percentage (pg. 5, 11-12).

Only when ISO amalgam separators are tested at the EPA Standard 245.7, do the actual efficiencies, or inefficiencies of the amalgam separators are found. During an Ohio based independent study done by Purves Environmental, it was concluded;

“A visual examination of the water from each of the separators demonstrated that the discharge of the water was cloudy with particulate. The difference in the total to dissolved mercury content strongly demonstrates that not only do the separators not remove all mercury but a significant quantity of dissolved mercury is discharged to the environment. 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.” (Purves, W. Pg. 5)

LibertyBOSS 2017-1

The Purves Study shows that most ISO amalgam separators will create and release more soluble mercury than they capture. According to this independent study, if a control group requires soluble mercury, only one amalgam separator is considered to be Best Available Technology, the M.A.R.S LibertyBOSS. To learn more about how to ensure compliance with the EPA Regulation and your Local Control Groups, please see the last two segments of our Blog Series. These last sections will be discussing “How” to Guarantee Compliance.

Resources

1. Ohio EPA- http://epa.ohio.gov/Portals/35/pretreatment/AmalgamFlowChart.pdf EPA Mercury Pollution Prevention Study, 2017, p. 1.

2. Watson P, Adegbembo A & Lugowski S – A Study of the Fate of Mercury from the Placement and Removal Of Dental Amalgam Restorations Final Report Part 1: Removal of Dental Amalgam Restorations 2002; p. 5; 11-12

3. Purves W. Dental Separator Study 2014; p. 5