The EPA Administrator, Gina McCarthy, signed the final rule on December 15, 2016, and the EPA is submitting it for publication in the Federal Register (FR).  The new rule will require private and public sector dental offices, with the exception of some specialties, to comply.  The compliance date is 30 days after publication in the Federal Register.

  • Learn how the EPA regulations affect your practice
  • Understand what you must do in order for your office to be in compliance with the law
  • The onus is on you and your staff to make sure your practice properly recycles dental amalgam waste and handle the necessary reporting

The new regulations purpose is to ensure that dentists properly collect and recycle ALL amalgam waste they generate during the placement or removal of amalgam restorations in order to contain mercury at its source. The new regulations emphasize compliance, documentation AND enforcement. Previous mandatory programs (in some states) emphasized only equipment purchases and did not provide for inspection of offices or mandate other types of enforcement. These new regulations are more exhaustive because their emphasis is on demanding both compliance with proper recycling and documentation as well as establishing mechanisms to inspect those offices suspected of non-compliance.

What the regulations mean for your office:

  1. The regulations apply to anyone who either places or removes dental amalgam.
  2. Included are permanent and temporary dental offices, hospitals, schools, clinics, mobile units and facilities owned by federal, state or local governments.
  3. The regulation requires the installation, maintenance, monitoring, and recycling of an amalgam separator in addition to requiring compliance with ADA Best Management Practices (BMP’s) regarding the recycling of “scrap amalgam” (excess mix or carvings, empty capsules from pre-capsulated alloy, extracted teeth containing amalgam, in -line disposable traps and Evac-u-Traps from wet-vac systems).

Amalgam Separators must:

  1. Be ISO 11143:2008 certified to operate at a minimum of 95% efficiency.
  2. Be inspected at least monthly for proper operation.
  3. Be properly sized to incorporate all the wastewater that may pass through it.
  4. Have canisters, cartridges or units changed when full, as recommended by the manufacturer, or annually, whichever comes first.
  5. Be properly maintained so unprocessed wastewater cannot bypass the system and enter a drain.

Scrap amalgam handling, collection and recycling:

  1. Must include all items considered to be “scrap amalgam” (previously listed).
  2. Requires the use of non-chlorinated line cleaners in the pH range of 6 to 8.
  3. This waste must never be placed in with regular trash or bio-hazardous (red bag) waste.

Monitoring, reporting and record keeping:

Monitoring and enforcement will be conducted by your local wastewater treatment facilities (POTW’s). Dentists who do not comply will be categorized as Significant Industrial Users (SIU), which are highly regulated waste generators. Being considered an SIU entails much higher regulatory costs, which you will want to avoid.

To maintain compliance, the office must certify that:

  • It has installed and is properly maintaining, inspecting, and recycling an amalgam separator meeting the ISO certification standard previously noted.
  • It adheres to all BMP’s and recycles all scrap amalgam.
  • It maintains a written log of monthly separator inspections, as well as all notes related to the unit’s servicing.
    • Canisters, cartridges, or separator units are being recycled at least annually.

Failure to comply with the above may result in your practice being classified as a Significant Industrial User (SIU).

EARLY ADOPTION

According to the EPA website, the rule takes effect 30 days after it appears on the Federal Register, which is expected in January 2017.  The compliance date is 36 months from the effective date of the rule.  

Being an early adopter can afford the office a number of benefits:

  • Lower cost of equipment and other waste management cost savings for the office
  • Recognition that you are contributing to the local community
  • Training staff immediately on this issue to insure future compliance
  • Free CE Course: “Public Health, the Environment and Dentistry: From Policy to Clinical Practice”– (Retail value $ 399)
    • This 8 CE credit course is the leading educational tool for compliance with environmental regulations effecting the dental profession. It is free for any Kerr customer.

COMPLIANCE


The single most important aspect is to insure your office does not get classified as a Significant Industrial User.  Non-compliance can lead to your practice being considered a Significant Industrial User, which is a very cost prohibitive classification that should be avoided at all cost.

Simply purchasing a piece of equipment, such as an amalgam separator, from your dental supplier does NOT achieve compliance.

Compliance = Equipment, Annual Recycling, Documentation, Ongoing Training
Equipment
Annual Recycling
Documentation
Ongoing Training

Environmental Dentistry

An Effortless Way for Dental Practices to Protect the Environment

My dental practice’s experience

By: Gary Radz, DDS

As a long-term practicing dentist, I have been continually mindful of the potential impacts dentistry can have on the environment. It is for this reason that I have been steadfast in my commitment to properly handling and disposing of all amalgam waste generated at my practice. I have been utilizing an amalgam separator since 2011 and have consequently prevented 2.3 lbs. of mercury from entering the local wastewater system. When it comes to a substance as harmful and toxic as mercury, every bit counts. A single pound of mercury is enough to contaminate a 22 acre lake to the point where fish consumption should be carefully monitored. With the proximity of Cherry Creek and the South Platte River to the Denver area, it is vital to the health of these aquatic systems that mercury is prevented from reaching their depths.

The harm posed by this substance has prompted the U.S. Environmental Protection Agency to propose effluent guidelines for dental discharges of amalgam, which it did on September 25, 2014. Prior to this, the Denver Metro Area imposed guidelines for best management practices for amalgam waste. The efforts I have put in over the years already prepared me for the Denver guidelines and even though the EPA regulations are much more stringent than in Denver, I am already equipped to be in compliance with the rule when it is finalized. Over the years, my waste management needs have been addressed through Dental Recycling North America, Inc. Although several companies sell amalgam separators, none tackle the issue as successfully as DRNA does. DRNA’s understanding of the regulatory landscape, its annual recycling services, and provision of compliance documentation ensures that all regulatory matters are adequately addressed.  I have had the DRNA system in my office for 5 years now. It's simple, turnkey and affordable. They do all the heavy lifting and will get you into compliance with minimal effort on your end. I feel this one is a no brainer.

About Gary M. Radz, DDS

Dr. Gary Radz maintains a private practice,Cosmetic Dentistry of Colorado, in downtown Denver. His full time general practice focuses on cosmetic dentistry.

Dr. Radz is a graduate and former chief resident of both AEGD and GPR residency programs. He has completed and been an associate clinical instructor for several post-graduate dental education institutions.

Over the course of the last fourteen years Dr. Radz has lectured internationally, teaching the materials and techniques used in cosmetic dentistry. 

Evac-u-Trap Recycling


Tips for properly recycling amalgam waste at your office

The Evac-u-Trap is a disposable canister, lid, mesh filter and gasket designed to replace the present canister and filter in your central vacuum pump. To remove this canister, screw on the lid and segregate with your contact amalgam for recycling. The infectious material is sealed in the canister where it cannot spill or contaminate the workplace. Nothing needs to be cleaned and you can be assured that you have minimized all contact with infectious material.

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About Kerr Dental

For 125 years, Kerr has been serving the comprehensive needs of the entire dental care community in pursuit of enhancing oral health. Individual Kerr brands are encompassed within the Kerr Restoratives, Kerr Endodontics, Kerr Rotary, and Kerr TotalCare product lines. By providing best-in-class*, patient-based solutions, we believe that in partnership with those we serve: together, we’re more.

Solutions

Why DRNA is your best choice to be in compliance at the most economical cost:

  • This is a waste management issue, not simply purchasing equipment
  • The rule requires annual recycling and providing environmental officials various documentation
  • DRNA does all this for the office on an ongoing basis
  • It’s equipment cost are significantly less than its main competitor, which is sold by dental dealers
  • It locks in its recycling cost over several years so NO ESCALATING COST like others on the market who seek to raise their recycling cost annually
  • DRNA is the dental office’s NO COST environmental compliance partner and will interface with local environmental officials on your behalf if needed.

These are a few examples of major dental institutions which have sought a complete compliance solution versus simply purchasing a piece of equipment.

Compliance Report


As part of the EPA regulation, offices will need to submit various written documentation to the regulatory authorities. This can be an ever changing process in terms of what documentation is required. For example, the current rule states monthly inspections in order to be in compliance.

DRNA provides monthly updates as well as assisting in all required documentation whether it be monthly, quarterly, or annually to the appropriate regulatory authorities.  For all Kerr customers whom become customers of DRNA, the annual service fee of $399.00 is waived

To sign up for this service, click here.

Free CE Course

Public Health, the Environment and Dentistry:

From Policy to Clinical Practice

A clinician’s guide to understanding:

  1. The impact of environment on human health
  2. Environmental policy and the rationale for regulatory development
  3. Dentistry’s role in environmental public health
  4. How to develop and implement compliance policies and procedures for the practice By: Alfred Frost, III, MS (Epidemiology), DDS, MBA

If you are a Kerr customer, click here to receive your free course

Request additional information


If you are interested in learning more about how DRNA can keep your office in compliance with the new EPA regulations or are interested in receiving any updates, including information on future webinars hosted by DRNA, please fill out the information box below and a DRNA representative will get in touch with you: