Thank you for following the M.A.R.S Blog Series on the EPA Amalgam Separator Regulation. You may have already read the first two Blogs of this series “Introduction to the EPA Amalgam Separator Compliance Blog Series” and ““Why” Dental Practices Require Amalgam Separators.” The third Blog of this series will be discussing who will be responsible for regulating Dental Practices on their mercury discharge limits.
If you have been following any of our previous M.A.R.S Blogs, we have mentioned in the past; the EPA cannot regulate compliance for every Dental Practice in the United States. The EPA’s inability to regulate Dental Practices is why this responsibility has been passed on to your Local Control Groups, such as Privately/Publicly Owned Treatment Works. It is the responsibility of these Control Groups to create, implement and regulate Best Management Practices for Dental Practices.
The Issue with Creating New BMPs
The unfortunate effect of passing the responsibility to Local Control Groups, there isn’t a way of knowing their standards, as each region’s requirements can be different. There are four ways of categorizing the Local Control Groups, based on their knowledge and preparation for the EPA Amalgam Separator Regulation.
This type of Control Groups is typically in the South East of the United States. Many of these States and Local Control Groups are not focusing on creating or enforcing BMPs of their own anytime soon. It would be more likely that this category of Control Groups would follow the EPA Amalgam Separator Regulation’s “bare minimum” requirements. The South East of the United States does not typically have an issue with mercury discharge as their Water Treatment Plants usually serve a large area. Serving a large population allows for enough dilution from the general public to help the Water Treatment Plants meet their mercury discharge limits.
Control Groups in this category are typically in the South West of the United States. These Control Groups have the intent of creating BMPs, but currently weighing their options on what standards to set and how to implement them. This group may or may not enforce the EPA Amalgam Separator Regulation until 2020, depending on how quickly they can create and implement their BMPs.
The third type is in the North East of the United States. These States already have their own EPA limits to meet and are currently rolling out their BMPs to Dental Practices. Local Control Groups will most likely be the responsible party for regulating Dental Practices in these States. Soluble mercury is a noted issue for this part of the United States and will probably be a part of many of the Local Control Group’s BMPs.
These Control Groups are in the North West in the United States. Their regulations have already be implemented for some time and act as a starting point for Control groups in categories two and three. As technology improves and more studies and information are published about mercury pollution, category four BMPs will most likely adapt to the changing discharge limits.
These classifications are a generalization, and there are exceptions for each category. It is best when researching for amalgam separators to contact your Local Control Groups to be sure you have an understanding who will be regulating your Dental Practice. To learn when these Local Control Groups may be expecting to be releasing their BMPs, please see our next Blog ““When” Dental Practice is scheduled to Comply.”