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Amalgam separator inquiry generates tripartite response

Grand Rapids, Mich.—Dr. Paul Rockwell received a “Dear Dentist(s)” letter from the City of Grand Rapids Environmental Services Department Sept. 11 “advising your office of this regulation and the responsibility to install amalgam separators.”

As punctuated and referenced, the letter began: “Michigan Public Act 503 of 2008 Section 333.16631 that took effect Jan. 13, 2009 requires that ‘On or before December 31, 2013, a dentist described in subsection (1) shall install or have installed and use on each wastewater drain in the dentist’s office that is used to discharge dental amalgam a separator that has an efficiency of 95% or more as determined through testing in accordance with standards published by the international organization for standardization in ISO 11143:2008 “Dental Equipment – Amalgam separators”.

Dr. Rockwell’s office manager/wife called the Association for guidance, setting in motion a tripartite response and a “thank you for the references on amalgam separators” from Nancy Rockwell. “Since we lease space in a commercial building, the (ADA) Professional Product Review section on Practical Issues for Purchasing, Installing and Maintaining Dental Amalgam Separators provides essential information not otherwise available,” she said in an e-mail response. “Your efforts in communicating such information is extremely valuable to those of us attempting compliance.”

The Michigan Dental Association advised Dr. Rockwell that MDA Services has negotiated discounts on amalgam separators for MDA member dentists. The Michigan Department of Environmental Quality awarded a $94,500 grant to the MDA to assist Michigan dentists with the installation of separators up to $300 per installed separator, according to the MDA Services website. Separators must be purchased after Jan. 13, 2011 and the grant program runs through June 2013 or until the funds are exhausted. Hospitals, state facilities and universities are not eligible.

The state amalgam separator law does not apply to oral and maxillofacial surgeons, oral and maxillofacial radiologists, oral pathologists, orthodontists, periodontists or dentists providing services in a dental school or through a local health department, the MDA Services website says. The application for dental amalgam separator reimbursement advises, “Installation of a dental amalgam separator is one step towards environmental compliance. For more information contact the Michigan Dental Association.”

At the federal level, the U.S. Environmental Protection Agency in 2010 announced its intention to issue a national pretreatment rule applicable to wastewater discharges from dental offices, which would constitute a national separator requirement. The EPA has indicated intent to issue a proposed rule in the next two years.

As directed by the 2010 ADA House of Delegates, the American Dental Association has engaged EPA in rulemaking negotiations. The ADA supports a national requirement if it includes certain common-sense provisions. Among issues addressed with the EPA are need for a “grandfather clause” so that early adapters and dentists in states that already require separators will be deemed to be in compliance with a national regulation.

Association policy encourages dental offices to follow Best Management Practices for Amalgam Waste and other voluntary efforts to reduce discharges of used amalgam into dental office wastewater.