Thank you for following the M.A.R.S Blog Series on the EPA Amalgam Separator Regulation. You may have already read the first three Blogs of this series “Introduction to the EPA Amalgam Separator Compliance Blog Series,” “Why” Dental Practices Require Amalgam Separators and “Who” Will Be Regulating and Implementing the Amalgam Separator Regulation. The fourth Blog of this series will be discussing when Dental Practices will be expected to comply with the EPA Amalgam Separator Regulation.
The EPA Regulation has set a cut-off date for compliance to be July 2020. By this date, every Dental Practice will be required to have an amalgam separator. There are some exceptions to this rule;
1) If you open a new clinic after July 14th, 2017 you must have an amalgam separator installed within 90 days of opening.
2) Your Local Control Group’s BMPs may require you to install an amalgam separator sooner than 2020.
Get Ahead of the EPA Amalgam Separator Regulation Requirements
If you decide to install an amalgam separator earlier than required by your Local Control Group, you may want to consider the following. As mentioned in the “Who” portion of this Blog Series, many Local Control Groups have not set their BMPs, meaning you may not have a way of knowing if the amalgam separator you purchased will meet your local standards. There has been a term called “Grandfathering” floating around the Dental Industry regarding amalgam separators. According to this misinformation, this rule will allow you to keep your existing amalgam separator for ten years or until it needs replacing. The truth is, many Dental Professionals miss the rest of the EPA Regulation that states a Local Control Group can require you to find Best Available Technology if your current amalgam separator does not meet their standards. You can read more about this topic in the M.A.R.S Blog EPA Amalgam Separator Regulation: Circulating Misinformation about Amalgam Separator Requirements – Part 1 “Grandfathering”.
If you still feel installing an amalgam separator as soon as possible is the right thing for your Practice, be sure the system you purchase comes with a Written Guarantee of Compliance from the manufacturer. A Written Guarantee of Compliance, should state; if your system does not meet current or future standards of your Local Control Group, the manufacturer of your amalgam separator will make the appropriate changes to the system to ensure your compliance. For more information ensuring your compliance, please see the M.A.R.S Blog Guarantee of Compliance – The “ONE” Simple Rule that Will Save You Money When Investing in an Amalgam Separator.
Final Deadlines for the EPA Amalgam Separator Regulation
The final deadlines for required compliance, in most cases, will come with ample notice. Where a Dental Practice might be surprised by a Local Control Group with a quick call to action is if your practice, with or without an amalgam separator, has been tested not to meet local standards. If you are found polluting mercury, you could be required to comply within ten days of notice. In the next blog of this series, we will be discussing ““What” the expectations are for Dental Practices.” Our next blog will assist Dental Professionals in understanding what is to be expected so that they can purchase an amalgam separator accordingly.