Proposed Dental
Category
Required BMP’s to
include Amalgam
Separators
AL Dubé
National Sales Manager
SolmeteX, a division of
Layne Christensen
Dentists
Going Green?
US EPA announces the promulgation
of a rule for the reduction of mercury
discharge from dental facilities, Sept
27, 2010.
What does it mean?
Best Management Practices (BMP’s) for
dental offices
Installation of amalgam separators
What are Dental BMP’s
Dental amalgam capsules
Chair-side Traps
Vacuum pump filters
Liquid mercury
Amalgam Separator
AMALGAM SEPARATORS
Glorified solids collectors placed on dental
vacuum lines
Nothing new
10 states
many municipalities have requirements
P2 device
Amalgam separators
Separate liquids and solids from the air in
vacuum line, decant the liquid, keep the
solids.
ISO requires 95% solid capture
US sold separators < 99% capture rate
Since EPA Announcement
ADA
Conference calls
ECOS – QuickSilver Caucus
Discussions with Stake Holders
EPA visit Dec 2010
Meetings
US EPA Headquarters
Region 1 Conference
All 6 States have state regulation
Region 8 Conference
POTW Open Forum
NACWA Conference
“WE GET IT”
Time Table
October 2011 “Proposed Rule”
October 2012 “Final Rule”
Drop Dead BMP / amalgam separator
installation date.
ADA Proclamation:
The American Dental Association
delegation unanimously approve 9 criteria
related to US EPA rule making, Oct 2010.
An ADA representative at the 2011 NACWA
meeting in St Louis proclaimed ADA would
not challenge the EPA’s Dental rule
provided all “9 criteria” were met.
ADA Principles Summary
1.
2.
3.
4.
BMP’s, ISO Certified amalgam separators
or equally efficient separators. (Dental
Schools)
A grandfather provision for existing
separator installations
exempt facilities with only de-minimis
amounts of amalgam
Sufficient length of implementation for
compliance
Continued
5.
6.
7.
8.
9.
Opportunity to fix or repair without a
notice of violation
Minimize administrative burden, selfcertification etc.
No numerical limit set by a local publicly
owned treatment works (POTW)
No waste water monitoring at dental
facility
Compliance with the rule means
compliance with the Clean Water Act
unless a more stringent local limit is
needed.
US EPA Thinking Ahead?
US EPA understands the potential
burden and impact a national
rule would have on both the
States and local POTW’s
IS This Possible?
US EPA 2011 NACWA conference slide
“WE GET IT”
What does it mean?
What would you like to see?
Categorical Standards
Minimize impact on POTW’s and States
Minimize inspections
Minimize costs to States and or POTW’s
Some Challenges:
Clean Water Act: Categorical Standard?
Minimize the impact on state and local
programs
How to keep track, maintain, inspect, verify,
etc…..
What criteria will systems have to meet and
how to verify them.
The Dental Rule will be the
largest single group to be
regulated
Roughly 122,000 facilities
Currently approximately 35 – 40 K installs in
the US
Challenge example
ISO
←
alarm
Type 1,2,3,4
Type 1,3,4 required to have
alarm signal on collection
container (5.3)
(on AWS not container)
Sold as an option
Speculation:
Similarities to current State regulation
Require all dentists that place or remove
amalgam to install an amalgam separator
Best Management Practices (BMP’s)
ADA Management of amalgam wastes
to include required installation of amalgam
separators
Best Management Practice includes scrap
amalgam similar to current state amalgam
separator regulations
More Speculation
BMP’s
A list of do’s and don’ts for amalgam
scraps
ISO 11143 Standard / ANSI Standard
Enforcement of the standard?
List of approved separators?
Grandfather for existing separator
installation.
More Speculation
Certification in some form by dentists
(probably electronic)
Tracking of dental offices for maintenance
Inspections in some form
Who knows?
Only those writing the Rule
Likelihood?
Pretty good chance
There are too many unknowns
Wait and see what the proposal offers
Some realities: FAIL
Dental Voluntary programs have not
worked.
Seattle King County 25 system in 8 years
ADA Memorandum of Understanding
Voluntary programs in states
Local voluntary programs
Mandatory Programs
Mandatory Programs dramatically increase the
number of systems and volume of reduction in
mercury levels.
Region 1 States with regulation 98 – 99%
compliance with mandatory programs
Enforcement is the key to mandatory programs
CT, 25% non compliant
NY 40 – 50% non compliant
Suggestions
The word from EPA meetings:
Start to define the dental facilities discharges
Visit a dental facility, utility room to understand
what you are looking for.
Establish protocols for possible inspections
EPA Region 1 has developed a check list
inspection sheet.
Amalgam separator sales
How Amalgam Separators work
How Separators Work part 2
In
Separation cavity
Collection cavity
Out
Dental Vacuum
Dental office Flow
Is not positive pressure
Many times chairs and vacuum on the
same floor, therefore a trap situation
Flow only flows when high speed suction is
open
Dental Vacuum Reality
Vacuum Reality
Questions
AL Dubé
National Sales Manager, Dental Division
SolmeteX, a division of Layne Christensen
50 Bearfoot Road
Northborough, MA 01532
508-397-9725
adube@solmetex.com