The Thing about Dental Amalgamator
On December 15, 2016, the EPA signed off on a final rule promulgating technology-based pretreatment standards under the Clean Water Act to control discharges of mercury and other metals into publicly owned treatment works (POTWs) from dental practices4. These new standards require dental practices that place or remove dental amalgam to control mercury discharges into POTWs through the use of an amalgam separator, which the EPA has identified as the best available technology to effectively capture dental amalgam before it reaches the wastewater, at an approximate average annual cost of $800 per office.
The EPA developed a regulation based on a separation and continual maintenance model that achieves a 95.0% total reduction of total mercury from amalgam process wastewater.
Compliance with the pretreatment standard for new and existing offices will be met by completing the following tasks:
Install and properly maintain an amalgam separator that is ISO 11143 certified to meet at least 95.0% reduction of total mercury
Implement the following Best Management Practices to prevent mercury discharges that may bypass the amalgam separator:
Properly collect and recycle “scrap” amalgam waste including chairside traps, vacuum pump filters, spent amalgam capsules and extracted teeth containing amalgam (e.g., use a PureWay Amalgam Recycling System)
Clean chairside traps using only non-bleach or non-chlorine cleaners
All dental offices that place or remove amalgam are now required to implement an amalgam collection, separation and recycling program. However, the EPA has identified exemptions to the new standards if less than 5% of activity involves amalgam. Exempted practices include:
Mobile dental units
Dental offices where the practice “consists only” of the following specialties:
Oral and Maxillofacial Radiology
Oral and Maxillofacial Surgery
It is understood that a number of dental offices may already have an amalgam separator in place, whether to comply with existing state or local amalgam regulations, or because they voluntarily installed an amalgam separator. According to the new EPA ruling, dental offices with existing amalgam separators will not be penalized as long as the separator is certified to remove 95% of total mercury. The EPA will not require existing separators that still have a remaining useful life to be retrofitted with a new separator, because of the additional costs incurred by dental facilities that proactively installed an amalgam separator ahead of the EPA’s proposed requirements, and because of the additional solid waste that would be generated by disposing of the existing separators.
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