G ove r n men t Re lat ions
REMINDER: EPA Amalgam Separator Mandate
The compliance date for the EPA amalgam separator mandate
is approaching. If you do not yet have a separator installed in
your office, you will want to do so soon. If you are unsure as to
whether you are required to install a separator in your office,
please use the flow chart below to determine whether or not
you are exempt.
On July 14, 2017, the EPA final rule on amalgam separators went
into effect. The rule mandates that dental offices must install,
maintain and monitor a compliant amalgam separator. The
compliance date for most dental offices will be July 14, 2020.
Newly purchased or constructed practices are subject to the rule
immediately, and must comply within 90 days of taking
ownership.
Offices that had a separator installed prior to July 14, 2017
must continue to operate their existing separator for its lifetime
or until July 14, 2027, whichever comes first, as long as the
office complies with the other rule requirements.
Dental practices will be required to submit a one-time
compliance report and retain a copy of the filed report for the
lifetime of the practice ownership. Dental practices that are
exempt from the rule due to specialty, mobile units or offices
with private septic systems do not need to file these reports.
One-time compliance reports must be submitted to your
Control Authority. In Pennsylvania, the Control Authority will
either be the local publicly owned treatment works (POTW)
or the EPA regional office, depending on whether your local
POTW has an EPA approved pretreatment program. You may
have already been contacted by your local POTW, but if you are
uncertain as to your Control Authority is, please contact your
local POTW or the Philadelphia EPA regional office.
Your Control Authority will also determine the form used to
submit your report.
According to the rule, offices with amalgam separators are also
required to comply with the following in office procedures:
4) Maintain separators by replacing amalgam retaining
cartridges, separator canisters or units as directed by the
manufacturer, or annually, whichever comes first.
5) Do not discharge waste amalgam from chair-side traps,
screens, vacuum pump filters, dental tools, cuspidors, or
collection devices to a POTW. In other words, no flushing
waste down the drain.
6) Do not use oxidizing, acidic cleaners when flushing
dental unit water lines, chair-side traps and vacuum
lines. Therefore, do not use bleach, chlorine, iodine or
peroxide cleaning agents that have a pH of lower than
6 or higher than 8.
7) Install the separator unit so that it receives all amalgam
process wastewater and that it is sized to incorporate all
wastewater that may pass through it.
In addition, dental practices must retain any records of the
following for a three-year time period (with the exception of
the One-Time Compliance Report that must be retained for the
duration of ownership of the practice):
1) Any reports filed.
2) A visual inspection log – Including documentation of
the date, person(s) conducting the inspection, the
results of each inspection and a summary of follow-up
actions, if needed.
3) Documentation of any repair or replacement- Including
the date, person(s) making the repair/replacement, a
description of the repair/replacement and documentation
of amalgam retaining container replacement (including
date).
4) Disposal records- Including all dates that collected
dental amalgam is picked up or shipped for proper
disposal, and the name of the permitted or licensed
treatment, storage or disposal facility receiving the
amalgam retaining containers.
1) Monitor the separator according to manufacturer’s
guidelines. 5) Manufacturer’s current operating manual for the device
in place.
2) Inspect installed separators at least once a month to
ensure proper operation and maintenance of the
separator. PDA endorses PureLife’s ECO II amalgam separator through PDA’s
Endorsed Vendor Program. This separator is compliant with ISO
11143 Standard and is available at member-exclusive pricing.
To learn more, visit http://www.pdais.com/endorsed-vendors/
amalgam-separators/ or call (877) 777-3303 to take advantage
of this PDA member-only offer.
3) Replace/Repair any malfunctioning separators according
to manufacturer instructions within 10 business days of
discovering the defect.
JU LY/AU G U ST 2019 | P EN N SYLVAN IA DEN TAL JOURNAL
11