The American Dental Association is focusing on the importance of capturing ALL amalgam waste at dental practices so that no mercury ends up in the public wastewater process. To help make that happen, dental practices must:
- Install an accredited amalgam separator that meets ANSI/ADA 108-2009 or ISO 11143 standards;
- Capture amalgam from chair-side traps, vacuum pump filters, dental tools, cuspidors, or collection containers;
- Flush any water line that discharges into a wastewater facility with an evacuation cleaner that has a pH between 6 and 8.
Document steps being taken by the dental practice to comply with the rule.
Drilling into the rule even further, each accredited amalgam separators must:
- Remove 95 percent of amalgam that flows through it;
- Be the appropriate size to accommodate the maximum discharge rate of facility;
- Be operated and maintained according to the manufacturer’s operating manual, including replacing collection container cartridges on a regularly scheduled basis.
Amalgam reporting and record keeping
As far as record keeping, files must be kept for three years in either a physical or electronic form. Inspections of all amalgam separators must take place on a regular basis, with the paper or electronic copy showing date and name of the person conducting the inspection. When amalgam waste is being collected, records must be retained that demonstrate it is being sent for proper disposal in accordance with 40 CFR 261.5(g)(3), with the name of the permitted or licensed treatment, storage or disposal facility receiving the amalgam retaining containers. In addition, documents must be kept if any repair is done on the any amalgam separator at the practice, with the name and date of the person doing the work, as well as a description repair or replacement and make or model number.
Finally, for reporting, existing dental dischargers must provide a one-time compliance report to their control authority no later than three years and 90 days effective date, (aka May 14, 2020). New dental practices must provide a one-time compliance report to their control authority no later than 90 days following the introduction of wastewater into a publicly owned treatment works (POTW). Those purchasing another dental practice must fill out a compliance report within 90 days from the transfer of ownership of the practice.
Don’t delay getting your dental office into amalgam compliance
Dental amalgam discharged to POTWs has contributed to a significant portion of mercury in our waterways. By regulating dental amalgam management, this new rule is anticipated to reduce that quantity more effectively than previous volunteer efforts. Dental dischargers have until July 14, 2020 to come fully into compliance.
Already have an amalgam program in place? Make sure you check to see that your dental office is in compliance with the new federal guidelines. Also know that the federal guidelines are a minimum, and your local or state guidelines may be even more stringent.
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About the writers:
Chris Wall is General Manager North America for medentex LLC, specializing in the professional and compliant disposal and recycling of dental waste. James Fitzpatrick is CEO of Madison Environmental Resourcing Inc., (MERI), a medical waste disposal company which offers mendentex’s amalgam disposal mailback kits.
