The EPA Amalgam Separator Ruling and What It Means for Your Practice

June 2019

In December 2016, the Environmental Protection Agency (EPA) issued a final rule requiring that most dental offices nationwide install amalgam separators by July 14, 2020. The ruling requires that a practice partake in two best management practices:

• Collect and recycle scrap amalgam
• Clean the chairside traps with non-bleach or non-chlorine cleanser so as not to release mercury¹

The EPA Ruling

On July 14, 2020, dental practices in the United States that either place or remove amalgam will be required to have an amalgam separator installed in their businesses. This will be a game-changing day for the dental industry, and time is of the essence to meet the deadline for installing an amalgam separator, as well as to prepare your practice and team for that day.

There have been speculation, rumors, and miscommunication about what this means, what is required, and when it must happen, so let's set the facts straight.

First, a quick history lesson and an explanation as to why there may be some confusion regarding the rule. In 2013, representatives from the United States and 106 other countries signed an international treaty called the Minimata Convention², which was designed to protect human and environmental health from toxic mercury emissions. Other initiatives specified in the convention to support its mission include controlling mercury air emissions in the mining, energy, and manufacturing industries, as well as implementing measures to reduce mercury in consumer products, such as batteries, switches, lights, cosmetics, and pesticides. Requiring that dental practices install amalgam separators is a small but significant piece of a comprehensive global initiative.

To support the Minimata Convention, in December of 2016, the EPA issued a final rule requiring dental practices to install amalgam separators. Several days later the current administration froze all new or pending regulations, including the just-passed rule on amalgam separators.

However, in June of 2017, the final rule passed once again, setting the July 14, 2020, compliance date in motion. This allowed a phase-in period for existing dental practices while requiring new dental practices that discharge amalgam in any capacity to comply immediately with the rule.

According to an article published by the American Dental Association, "The final rule closely follows the ADA's best management practices for amalgam waste, including:

• requiring the use of separators;
• prohibiting providers from flushing waste amalgam, such as from traps or filters, down a drain; and
• prohibiting the use of bleach or chlorine-containing cleaners that may lead to the dissolution of solid mercury when cleaning chair-side traps and vacuum lines³."

Amalgam Waste Defined

American National Standards Institute/American Dental Association (ANSI/ADA) Standard No. 109 defines amalgam waste as including amalgam (scrap), chairside trap filters containing amalgam vacuum pump filters containing amalgam, saliva ejectors if used in dental procedures involving amalgam, used amalgam capsules, extracted teeth with amalgam restorations, and waste items that are contaminated with amalgam.⁴

Amalgam Separators: How They Work

Quite simply, an amalgam separator is a mercury collection device that sits "inline" between the operatory and vacuum pump—typically in the equipment room. Dental wastewater flows through the vacuum line and passes through the amalgam separator where teeth fragments, dental amalgam and mercury are separated and collected. The filtered water continues to flow through while heavy waste and sediment is stored.

Choosing an Amalgam Separator to Meet Compliance

Choose the amalgam separator that best fits with your practice by speaking with colleagues, researching online, and reading the products section below. Before choosing an amalgam separator it's important to know the requirements laid out in the EPA ruling.

• Amalgam separators must be installed and working properly by July 14, 2020.
• The ruling calls for amalgam separators with at least a 95% removal efficiency, however dental facilities may be subject to additional or more stringent state or local requirements than those in the rule.
• Compliance is required, and enforcement will be managed by the EPA or local water authority.
• Practices that fall under the ruling must submit a one-time compliance report certifying compliance by October 12, 2020 to their local authority.
• As part of the ruling, practices must also comply with reporting requirements and maintain and make available for inspection certain records documenting compliance.
• As of July 14, 2017, new dental offices which discharge dental amalgam must comply immediately with the standards in this rule.
• In the ruling, “new practices” includes established practices that experience a change of ownership.
• All practices, except the following, are required to comply:
• oral pathology,
• oral and maxillofacial radiology,
• oral and maxillofacial surgery,
• orthodontics,
• periodontics,
• prosthodontics, and
• mobile units⁵

Installation

Installation requirements differ by municipality. Some municipalities require that installation be done by licensed plumbers. In others, installation may be done by a Henry Schein Service professional. It's important to know that an incorrect installation may result in the amalgam separator working improperly or a void of the warranty.

Recycling

Beyond purchasing and installing a separator, practices must commit to a recycling program to comply. Many manufacturers offer a recycling program as part of the purchase of the collection containers, resulting in a seamless process for dental facilities.

Amalgam Separators to Consider

There are several solutions for dental practices to become compliant with this upcoming deadline. Here is a brief overview of three of the top amalgam separators available.

Air Techniques Acadia®

With a translucent container that enables dental professionals to view its cyclonic separation of fluids, Acadia supports up to 10 operatories and delivers a 98.6% amalgam separation. An inlet filter ensures a smooth continuous filtration process, and all particles larger than 5mm are filtered out, never clogging or causing a loss of suction.

A visual fill line lets dental professionals know when the filter should be replaced. Typically changed on an annual basis, the three-stage filter twists on and off, helping to make replacement as simple as possible. A recycle kit provides a prepaid shipping package and recycling certificate.

Additionally, Acadia Alert automatically monitors the practice's system and activates an audible alarm along with visual LED indicators when the filter reaches approximately 90% capacity. Acadia Alert can be installed in any operatory, providing real-time notifications. This system requires no additional electricity and is powered by the practice's vacuum's 24V control circuit. Acadia Alert can also be integrated with the Vacuum Remote Switch and Vacuum Equalizer from Air Techniques. There is a 2-year full system warranty from the date of installation.

Crosstex™ Syclone™

The Syclone Amalgam Separator from Crosstex features cutting-edge cyclonic action that contributes to a highly efficient process that results in more than 99% amalgam separation.

Among the benefits of this product are a 2-year warranty on the system and one-year warranty on the canister. Additionally, there are no moving parts within the system, reducing the potential for leaks and/or failures. There is also a parallel plumbing option to support dental practices with more than 10 chairs. The canister volume of the Crosstex Syclone is 1500 ml; substantially larger than other canisters on the market. The benefit of this added volume is that the canister replacement occurs less frequently.

Replacing the canister is simple for dental team members. New canisters are purchased through Henry Schein. Meanwhile, the canister which needs to be replaced has a UPS shipping label generated for it by a team member, who is helped through their personalized Crosstex DocHub account. The customer prints and attaches the label to the box that the new canister comes in and is packed per the provided guide. The team member ships the box to a third-party recycling facility and a certificate is generated and sent digitally to the practice.

Solmetex NXT Hg5® Series

The NXT Hg5 series of Amalgam Separators from Solmetex are available in three sizes and have a wide array of features and solutions that can benefit dental practices and result in 99% amalgam separation.

The NXT Hg5 features a new compact design, now with an internal manifold, which may be a viable option for practices where space is an issue, as the mini is design for tight spaces and the high volume for larger practices. Additionally, custom designs are also an option for large practices with unique floor plans. All the NXT Hg5 amalgam separators are functional with all wet and dry vacuums, are made in the USA, are shipped in environmentally friendly, 100% recyclable packaging, and feature a 2-year warranty.

• Most practices have found the standard NXT Hg5 Amalgam Separator, which is appropriate for offices which have between 1–10 chairs, to be a good choice for their needs.
• For practices featuring 1–4 chairs, Solmetex offers the NXT Hg5 mini Amalgam Separator, specifically designed for tight spaces, like under a sink. Like the NXT Hg5 standard size, it can be either floor or wall mounted.
• Practices with 11–20 chairs can benefit from the NXT Hg5 High Volume Amalgam Separator, which also comes with a wall mount bracket.

A simple mail-back recycling program is included in the cost of the replacement NXT Hg5 Collection Container, along with Certificates of Compliance which are available online 24/7 at solmetex.com.

Amalgam Separators: Comparison Chart

So there we have it; an overview of the EPA ruling and what's required of dental practices to comply, as well as three product lines that offer out-of-the-box compliance. Please reach out to your Henry Schein representative to help determine the best product fit for your practice.