Environment & Radiation

Amalgam separators, wastewater permits, regulated waste management, and radiation safety.

Final EPA rule prohibits 'sewering' of pharmaceutical hazardous waste
Health care facilities that produce pharmaceutical hazardous waste are required to properly manage the disposal of that waste according to the Environmental Protection Agency. Among other provisions, the EPA’s finalized rule issued in July prohibits facilities from pouring pharmaceutical hazardous waste down sink drains or toilets, a practice known as “sewering.”
Resources can help practices get ahead of amalgam separator requirement
Most dental facilities that have not installed an amalgam separator to comply with a rule published in June 2017 by the Environmental Protection Agency must install an amalgam separator by July 14, 2020. CDA Practice Support’s resource “Amalgam Separator Requirement — Q&A” was recently updated to reflect recent developments and can assist members with compliance.
'Failure to produce patient records' among most cited violations, says dental board
Maintaining its focus on consumer safety, the Dental Board of California has issued an increasing number of citations in recent years. As noted in its 2018 Sunset Review Report to the California Legislature, citations increased by 36 percent in each of the previous four fiscal years. Two of the five most commonly cited violations according to the report are (1) Failure to produce patient records and (2) Failure to follow infection-control guidelines.
Proposition 65 notice requirement takes effect in August
No later than Aug. 30, 2018, dental practices that employ 10 or more employees must post at the entrance of the office the new Proposition 65 warning notice, unless the practice chooses instead to provide a warning with an informed consent form. The form must be signed by the patient prior to exposure to the chemicals regulated by Proposition 65.
Updated Legal Reference Guide for California Dentists features all-CDA content
In their day-to-day practice, dentists and their teams must know and comply with federal, state and local laws — from the layered requirements of federal and state employment laws to the dentistry-specific California Dental Practice Act to local laws that enforce building codes. A first resource for dentists to help them navigate these laws is the Legal Reference Guide for California Dentists, updated and published in January by the CDA Practice Support experts.
Current registrations and safety certificates required of X-ray machine owners, operators
With the recent increase in X-ray machine registration fees, CDA reminds members to ensure their registrations are up to date. CDA Regulatory Compliance Analyst Teresa Pichay cites recent calls from dentists who were surprised to receive past-due bills for registration fees dating as far back as eight years, and she cautions dentists that “not receiving a bill does not exempt a facility with X-ray equipment from paying the registration fees.”
Check the dates on your required poster set
As a member benefit, CDA Practice Support offers an easy-to-display poster set that contains all the latest health, safety and employee rights information practice owners need to post to comply with state and federal agency regulations.
Updated amalgam separator Q&A addresses tenant-landlord responsibility
Dentists who share a building with other dental practices are contacting CDA Practice Support to inquire about their obligations under the Environmental Protection Agency’s amalgam separator requirement, which took effect July 14, 2017. The amalgam separator is designed to remove mercury and other metals entering the waste stream from dental practices.
X-ray machine registration and other fees to increase Sept. 1
Radiologic Health Branch fees are due to increase 26.76 percent Sept. 1, 2017, under the Budget Act of 2016, Chapter 23, in accordance with California Health and Safety Code section 100425. Five fee types are increasing, including registration of reportable sources of radiation renewal and certification in radiologic technology or nuclear medicine technology application.
EPA rule requiring amalgam separators takes effect July 14
Following a six-month delay, the Environmental Protection Agency on June 14 published a final rule under the Clean Water Act to control the discharge of mercury and other metals entering the waste stream from dental practices. The rule regulates dental practices that place or remove amalgam.
Proposition 65 resource updated for member compliance
Well ahead of the compliance deadline, CDA has updated its Proposition 65 resources to include the dental-specific notice that many dental practices (as well as dental schools and laboratories) will need to post at the entrance of the dental office by Aug. 30, 2018, unless the practice chooses instead to provide a warning with an informed consent form to be signed by the patient prior to exposure.
Presidential order freezes amalgam separator rule
The Environmental Protection Agency’s anticipated rule requiring that dental practices install amalgam separators and implement best practices to control the discharge of mercury and other metals entering the waste stream has been delayed following the Trump administration’s freeze on all proposed or pending federal regulations.
FDA bans use of powdered gloves in health care
Dentists, physicians and other health care professionals will no longer be allowed to use powdered gloves when treating patients, per a rule finalized Dec. 16 by the U.S. Food and Drug Administration. The rule was first proposed in March 2016 and takes effect Jan. 18.
'Are you in compliance' with 2016 laws and regulations?
From displaying California's Whistleblower Protection notice to registering with CURES 2.0, dental practices were to comply with 12 laws and regulations that took effect in 2016. Presented here are summaries of these new laws and regulations along with explanations of what dentists must do to comply with them.
EPA issues final rule: Amalgam separators required

The administrator for the Environmental Protection Agency has signed off on a final rule under the Clean Water Act to control the discharge of mercury and other metals entering the waste stream from dental practices. The rule will regulate dental practices that place or remove amalgam. The effective date of the rule is 30 days after the rule is published in the Federal Register.

EPA's final rule on amalgam separators expected soon
The Environmental Protection Agency in October 2014 issued a draft rule under the Clean Water Act to control the discharge of mercury and other metals entering the waste stream from dental practices. The final rule, which may become effective as early as December 2016, will regulate dental practices that place or remove amalgam.
Proposition 65 notice requirements revised
The California EPA’s Office of Environmental Health Hazard Assessment has adopted a regulation revising the notices that dental practices are required to post under Proposition 65, known as the Safe Drinking Water and Toxic Enforcement Act. The regulation takes effect in 2018.
Top trending CDA Practice Support resources
Here are the top-five trending CDA Practice Support resources in the categories of practice management, employment practices, dental benefit plans and regulatory compliance.
Dentists required to post BPA notice
Bisphenol A (BPA), a chemical present during the application of some composite fillings and sealants, has been added to the Proposition 65 list of chemicals known to the state of California to cause cancer or reproductive toxicity.
ADA, CDA ask for changes in amalgam separator rule
The ADA and CDA are advocating for the U.S. Environmental Protection Agency (EPA) to revise its proposed rule, which, if adopted, would call for most dentists to install, operate and maintain amalgam separators. While the proposed rule incorporates many of the important principles required by the ADA for its support of a national standard, neither ADA nor CDA support it in its current form. Each organization submitted comments with their concerns in separate letters to the EPA in February.
CDA offers radiation safety information
A recent article published by Consumer Reports cautions readers about the radiation they receive from diagnostic imaging, noting the effects are cumulative over time and suggesting all those taken may not be necessary. Unfortunately, the article did not attempt to describe the conditions under which longer intervals between dental X-rays is warranted, nor did it discuss the oral conditions for which dental X-rays aid diagnosis.
New radiation machine fees, forms required
As 2015 begins, there are new fees and forms dentists should be aware of regarding the use of radiation machines. Annual radiation machine registration fees went up from $79 to $93 as of Jan. 1. In addition, new forms are available from the California Department of Public Health to report the discontinuance of use and when a dentist is no longer in possession of any functional radiation machine.
EPA rule: dentists must cut amalgam discharge
The U.S. Environmental Protection Agency (EPA) has released new proposed standards to cut discharges of dental amalgam to the environment under the Clean Water Act. The proposed rule would require all affected dentists to control mercury discharges to Publicly Owned Treatment Works (POTWs). Specifically, it would require them to cut their dental amalgam discharges to a level using amalgam separators and the use of other "Best Management Practices," according to an EPA statement.
CDA’s updated radiation safety guide now available
To ensure compliance with state radiation regulations, dental practices, clinics and dental educational programs should obtain the recently updated Radiation Safety in Dental Practice.
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