What you Need to Know to Comply with the EPA Dental Rule

What you Need to Know to Comply with the EPA Dental Rule

On July 14th, 2017 the EPA Dental Rule (Regulation) was released, requiring Dental Practices to have an ISO 11143 amalgam separator, use of a non-oxidizing evacuation line cleaner with the pH range of 6-8, as well as properly disposal of the dental waste. The amalgam separator will need to be maintained to manufacturer’s specifications (i.e., if you were to install a filter type amalgam separator, their manual requires weekly maintenance to check for clogging and overfilling). For simple understanding about the requirements of compliance, please review the following EPA Regulation Flowchart.

The EPA Dental Rule has passed on the responsibility of implementing and enforcing Best Management Practices to your Local Control Group, such as Privately/Publicly Owned Treatment Works (POTWs). In 2015, the EPA took away the POTWs ability to dilute water to meet their mercury discharge allowances. Currently, many POTWs have an issue with soluble mercury, a pollutant that can only be captured at the source polluter, Dental Practices. EPA Regulation was created to give your local POTW the power to enforce BMPs if they deem your mercury discharge too high.

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POTW Regulation

M.A.R.S has a close working relationship with many POTWs across the country. According to a number of them, the large Dental Groups will be first to be targeted in their mercury discharge testing. In states like Ohio, they will be looking for your soluble mercury discharge. Should the local POTW deem your discharge too high, your offices will be forced to follow their Best Management Practices (BMPs). What this could mean for your Practices is, the POTWs could regulate you by setting fines, creating stricter local standards and regulations or selling pollution permits, to name a few options.

The History Behind the Pollution

The Cause

In 2014, studies were released, providing evidence that the highest source of soluble mercury pollution is from dental practices. 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 under water/liquids it creates soluble/dissolved mercury at a high rate. Soluble mercury discharge is a significant concern to POTWs.

The Issue with ISO 11143

All amalgam separators are required to be ISO 11143 certified, which only tests for solid mercury. Unfortunately, the technology and standards of ISO testing on amalgam separators have not been updated to meet the current requirements of the POTWs who will be setting and verifying the discharge limits. Generally, amalgam separators work on the principle of sedimentation, capturing any material heavier than water. The issue with this method is when mercury amalgam is submerged in water it is released into its soluble form. This means these types of amalgam separators will generate and release soluble mercury, making it harder to meet the POTW discharge limits. The M.A.R.S LibertyBOSS goes one step further by adding an extra-large media bed to capture soluble mercury.

pH levels (2)

The LibertyBOSS has been independently tested, at EPA Standard 245.7, to be the only amalgam separator to capture soluble mercury. This is one of the ways the M.A.R.S LibertyBOSS differs from any ISO tested amalgam separator. Our process makes the LibertyBOSS not only the most Environmentally Friendly amalgam separator but the Best Available Technology in the industry.

Purves Study (1)

Amalgam Separator Service Life

Dental Professionals have a misunderstanding on the service life of amalgam separators, assuming that the systems only capture mercury. Amalgam separators are based on sedimentation, meaning any material heavier than water will be captured by an amalgam separator. By far, the largest contributor to filling an amalgam separator is prophy paste from your hygienists.

no maintenance

Many amalgam separator manufacturers use a generic service life for a 1-10 chair clinic “every 12 months or when it is full, whichever comes first.” A service life schedule that is not specific nor accurate. M.A.R.S provides guaranteed service lives for the LibertyBOSS, based on the size of a clinic. On average, the LibertyBOSS has a service life six times longer than any amalgam separator on the market.

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