08/12/2019

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. A facility is exempt if it certifies it does not place dental amalgam and does not remove amalgam except in limited circumstances or if it is one of six exempt dental specialties.

The EPA’s rule is intended to reduce the discharge of mercury from dental offices into publicly owned treatment works, which discharge treated wastewater to rivers, lakes, bays and the ocean. Amalgam separators capture this mercury prior to discharge into sewers and allow it to be recycled or properly disposed.

To effectively capture mercury, the amalgam separator must be compliant with either the American National Standards Institute (ANSI) American National Standard/American Dental Association (ADA) Specification 108 for Amalgam Separators (2009) With Technical Addendum (2011) or the International Organization for Standardization (ISO) 11143 Standard (2008) or subsequent versions as long as that version requires amalgam separators to achieve at least a 95% removal efficiency. Regular inspection and maintenance in accordance with the manufacturer’s instructions is required.

The EPA rule requires dental facilities to collect all waste amalgam, including amalgam in chairside traps, screens, vacuum pump filters, instruments or collection devices, and prohibits the use of line cleaners that have a pH lower than 6 or greater than 8, are acidic or contain oxidizers. California has additional amalgam waste management requirements.

CDA Practice Support in June 2017 published the resource “Amalgam Separator Requirement — Q&A” (CDA login required) to assist members with compliance and updated the resource in October 2018 to reflect more recent developments. The resource covers in detail questions about compliance dates and expectations, specifications, documentation and record-keeping requirements, including a requirement that facilities submit to their local sanitation agency a one-time compliance report. A sample “Amalgam Separator Inspection and Maintenance Log” is available at cda.org/practicesupport.

ECO II amalgam separator

CDA worked with PureLife Dental, a CDA Endorsed Program, to help make complying with the EPA’s requirement easier and more affordable. PureLife’s ECO II amalgam separator is compliant and available to members for only $99 per unit with a discounted one-year replacement cartridge and disposal service agreement. To learn more, visit cda.org/amalgam.

CDA will remind dentists about the July 2020 compliance deadline as it nears. Dentists should keep in mind the availability of technicians to install the equipment. Dental facilities that had installed properly functioning amalgam separators prior to June 14, 2017, are required to replace their separators by June 14, 2027.

For more details, read “Amalgam Separator Requirement – Q&A” available in the CDA Practice Support Resource Library.



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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.

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.

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