CRITICALRegulatoryTier 1
You Stopped Placing Amalgam. Your Patients Still Have Them.
Summary & scoring by The Bell Brief (Dr. Jennifer Bell) using the Drill-Down Protocol (Drill-Down Score) — not the original publisher.
Why it matters for dental
EPA rules still require amalgam separators, neutral-pH line cleaners, and dedicated waste handling for any practice that removes amalgam, even if it stopped placing it. Practice owners and DSOs must verify equipment and documentation to avoid enforcement.
Key points
- 01EPA Dental Effluent Guidelines (40 CFR Part 441) apply to offices that place or remove amalgam; the exemption for non-placing offices covers only limited emergency or unplanned removals.
- 02Amalgam separators installed before June 14, 2017, meet certification and sizing requirements only until replaced or until June 14, 2027, whichever occurs first.
- 03Oxidizing or acidic vacuum line cleaners (pH below 6 or above 8) are prohibited because they can release captured mercury back into wastewater.
- 04Each subject practice must file a One-Time Compliance Report with its Control Authority and retain inspection records for at least three years.
Who should care
OwnerDSO
Read the original on Dentistry Today
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