Q&A from Our Compliance Team

Q: Why do I need an amalgam separator when I haven’t placed amalgam fillings in years?

A: Do you still remove amalgam fillings? Anything that comes in contact with amalgam need to be recycled. EPA regulation now states that in addition to an amalgam separator for wet amalgam waste, practices must now recycle dry amalgam waste such as chair-side traps, vacuum filters, contact & non-contact amalgam, amalgam capsules and teeth with amalgam in a container labeled “Amalgam Waste”.

Q: How long do I have to install an amalgam separator?

A: A new practice has 90 days to install a certified ISO 11143:2008 certified amalgam separator; an existing practice has 3 years (until July 14, 2020) to install an amalgam separator; and an existing practice who currently has an amalgam separator installed that does NOT meet the EPA requirements, has 10 years to install an upgraded, certified amalgam separator.

Q: What practices are NOT required to install an amalgam separator?

A: The new rule applies to dental offices, dental schools and clinics that discharge water to a POTW. However, the regulation does not apply to mobile units or offices that do not place or remove amalgam, the following specialties need only to submit certification:

• Oral pathology
• Oral and maxillofacial radiology
• Oral and maxillofacial surgery
• Orthodontics
• Periodontics
• Prosthodontics

Q: What are some things I should think about when deciding upon which amalgam separator to purchase?

A: 1. How many chairs in my practice? How many chairs can be serviced by one unit?
2. Is space a constraint when choosing an installation location?
3. Does your office have a wet ring or dry vacuum system?
4. Does the amalgam separator include a recycling program?
5. If so, how do I access my certificates of compliance and/or manage my compliance paperwork?
6. Can office staff manage the separator maintenance or does it require outside services from a vendor?
7. What is the cost to maintain the unit?
8. Does the purchase of a separator require a contract for maintenance?