Alfred L. Frost III, DDS, MS
On July 14, 2017, the Environmental Protection Agency (EPA) issued a final rule regarding the handling, recycling, and disposal of amalgam. The EPA issued the rule under the Clean Water Act, and it applies to discharges of amalgam pollutants into publicly owned treatment works (POTWs) by dental practices. This article will discuss key aspects of the rule that will impact dental practices.
Amalgam waste contains mercury, a persistent, bioaccumulative pollutant with neurotoxic effects on humans. The mercury in dental amalgam is a highly concentrated form that is easy to collect and recycle. Dental offices are the main source of mercury discharges to POTWs.1
Under the EPA’s new regulations, dentists who place or remove amalgam must collect and recycle the waste generated. The regulations emphasize compliance, documentation, and enforcement.
In some states, previous mandatory programs emphasized only equipment purchases, did not provide for inspection of offices, or mandate enforcement. However, the EPA’s new rule is more stringent. It demands proper recycling and documentation. It also establishes inspection mechanisms for offices suspected of noncompliance.
The rule applies to anyone who either places or removes amalgam in these settings: permanent and temporary dental offices, hospitals, schools, clinics, mobile units, and facilities owned by federal, state, or local governments.
The rule also requires the installation, maintenance, monitoring, and recycling of an amalgam separator, in addition to compliance with American Dental Association (ADA) Best Management Practices (BMPs) regarding the recycling of “scrap amalgam.” This includes excess mix or carvings, empty capsules from precapsulated alloy, extracted teeth containing amalgam, in-line disposable traps, and vacuum traps from wet-vac systems.2
Amalgam separators must conform to the following standards:
- 2008 ISO 11143–certified to operate at a minimum of 99% efficiency
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