Understanding the EPA’s Proposed Amalgam Separator Rule

UPDATE: The EPA’s final rule (July 14, 2017) “requires dental offices to use amalgam separators and best management practices recommended by the American Dental Association (ADA).”

UPDATE: The 2016 EPA Dental Effluent Guidelines were pulled from The Office of The Federal Register; and, though signed, will not be published at this time. Therefore, this rule WILL NOT go into effect. However, many states have state level laws requiring the installation of amalgam separators in their state’s Dental Offices. These state level laws will be unaffected by the withdraw of the EPA rule and remain in full force and effect. If there are any further changes related to this rule, we will be sure to update this blog accordingly.

In September 2014, the Environmental Protection Agency (EPA) proposed a new rule regarding dental amalgam. This regulation would require all existing and new dental practices to use amalgam separators to prevent amalgam from discharging into publicly owned treatment works (POTWs).

Amalgam is a mixture of metals consisting of liquid mercury and a powdered alloy composed of tin, copper, and silver. Elemental mercury reacts with and binds together with the alloy particles to form an amalgam. Amalgam restorations are often referred to as “silver fillings.”

Mercury is released into dental offices’ wastewater when dentists either place or remove amalgam fillings. “Studies have shown that dental offices are the largest source of mercury discharges to POTWs, contributing about half of the mercury received by POTWs.” Mercury is converted to methylmercury and builds up in fish and shellfish. When consumed, methylmercury is highly toxic, especially to fetuses, infants and children.

Under this regulation, dentists would have to decrease their amalgam discharge “to a level achievable through the use of the best available technology (amalgam separators) and the use of Best Management Practices.” Many states have enacted rules requiring separators over the last few years. Therefore, if dental offices already have amalgam separators “that do not meet the proposed amalgam removal efficiency,” they would remain in compliance while the separator was still functioning.

Once an office has installed a compliant amalgam separator, it’s important to manage the separator and collected mercury through a compliant recycling program. Utilizing Sharps Compliance’s 5-gallon Dental Amalgam Recycling System, which provides collection and shipment for recycling through UPS, cannot only help comply with the new regulations but can assure your mercury is safely and properly recycled.

The EPA has delayed the release of the final rule twice. In May 2016, they postponed the regulation’s final release until this December in order to have time to review all of the comments they received for the proposal.