With heightened safety concerns, we wanted to look at an area of dentistry that will require every dental office, with few exceptions, to install an amalgam separator or equivalent device by July 2020. A few municipalities are extending this deadline to work around the current Covid19 dental office closings.
When the EPA reinstated the Amalgam Separator Ruling in 2017, the goal was to ensure dental amalgam waste is captured and recycled properly. It is an “environmental ruling” to ensure mercury contained in dental amalgam does not enter the air, water, and land.
The EPA also set up Best Management Practices (BMP) a set of guidelines as to how you should collect the amalgam waste, dispose of, recycle, and what cleaners with high PH couldn’t be used. Again, all designed for the environmental protection.
However, the ruling overlooks a focus on Safety, specific to Dental Patients and Dental Professionals. Current amalgam collection risks include exposure of toxic materials, leaking, backflow and clogging. Initially, the EPA approved only traditional ISO amalgam separators. They are designed to collect amalgam waste for extensive periods of time in a bucket style collection system. Most often they are found in utility rooms near the vacuum. They require cleaning or changing every few months or years.
For safety purposes, keeping the removed amalgam around the office for extensive time periods seems counter-intuitive. Shouldn’t the goal be to remove amalgam when its removed? Not in 30 days, 6 months or 2 years. Contrary to belief, dental amalgam, when removed does not flow to the amalgam separator. Instead, particles collect in your valves, trap, vacuum lines and eventually the separator. Research shows an average of 68% of the amalgam sits in the chairside trap. The amalgam separator receives the remaining amalgam waste. Best Management Practices requires collection and recycling of the chairside trap amalgam waste along with the separator.
We believe when amalgam is removed from a patient it should be immediately captured and placed out of harm’s way. It should also not enter the chair lines, trap or vacuum. When the EPA revisited the original ruling and added the equivalent device section to the final ruling it allows for this. The EPA made room for new technologies, they will be advanced, safer, more efficient, and will collect sooner rather than later. Most states recognize the EPA Equivalent Device Ruling found in 441.30(a)(2) of the final ruling.
At some point, the dental market will reopen. When this occurs, safety should be the #1 priority. We owe it to our community to insure safer protocols, especially those with loopholes.
To learn about your office risk, ask how often are the lines flushed? How often are the evacuation valves properly cleaned? How often is the chairside trap emptied? Are patients instructed to close around saliva ejectors? The CDC and countless research state when patients close around a suction device, 1 in 4 likely receive backflow. All of these pertain to safety and should be prioritized for every patient, not once a day.
If you have a traditional amalgam separator, make sure protective equipment is provided for the employee designated to clean the separator. OSHA recommends a respirator, utility gloves and face shield and because of splatter PPE is suggested.
Or, maybe it’s time to consider a safer system in the Equivalent Device category. These devices are safer, more efficient, single-use, recyclable and are used when your removing amalgam. And no longer will amalgam enter the valves, lines and trap.
Finally, urge your local and state legislators to not only focus on the environment, but also move in the direction of safer solutions.