Thank you for following us to Part Three of our blog series on Reviewing M.A.R.S’ EPA Regulation Flowchart. Our first two segments were on the Compliance Dates and Installation Deadlines.
Today, we will be discussing Compliance Reports and the time frame in which you are required to submit and resubmit the forms to your regulators.
If you follow M.A.R.S and our blog series, you will know that the EPA will not be regulating Dental Practices, rather local regulators like Water Treatment Plants have that responsibility. The new EPA Regulation gives these Water Treatment Plants the power to create and implement their own Best Management Practices for the Dental Professionals in their region. Many of the regulators who will be creating these BMPs, may not be fully confident in their understanding of requirements and the Dental Industry to create and regulate local standards. Due to this fear, many Water Treatment Plants are sending out one-time compliance reports and BMPs to Dental Practices, knowing they will require an update on standards in the future as their understanding of Amalgam Separators and the Dental Industry changes.
For this reason, M.A.R.S doesn’t like the term “One-Time” in the title for the Compliance Report. A better term, used by the City of Toronto, is a “Pollution Prevention Form.” Theses “Compliance Reports” are to be updated anytime the information changes from the original document. The following are examples of when a Compliance Form will need to be resubmitted;
- The Dental Practice adds or removes chairs, Doctors, or Hygienists; this information can affect the service life and maintenance requirements of your amalgam separator.
- Transfer of ownership over a Practice is completed.
- Changed the type of your amalgam separator.
Every time this form is completed and submitted to your local regulator, a copy should be kept in your records for as long as your own the practice.
Up Next – Compliant Amalgam Separators and Record Keeping
On Friday’s release, we will be discussing Part 1 of Compliance Amalgam Separators and Record Keeping. According to a survey completed in a major North American City, 70% of Dental Practices with an amalgam separator are non-compliant. The next two segments will help illustrate what is needed to ensure the compliance of your office and amalgam separator.