The Compliance Divas Podcast
Our podcast covers current topics such as infection prevention and control, OSHA and HIPAA compliance for dentistry. We discuss the latest regulatory information, answer frequently asked questions and give suggestions for dental practices to make compliance easy and sustainable. The Compliance Divas are a trusted source for consistent, accurate information based upon current guidelines, standards, science, and recommendations.
The Compliance Divas Podcast
#210 When It Comes to Amalgam Waste Are You Compliant?
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If your dental office places or removes amalgam and discharges wastewater to a municipal sewage system, you are required to have an amalgam separator that meets EPA standards, follow best management practices, and comply with reporting requirements. Learn what is required, how to comply, and a potential alternative to traditional amalgam separators, with special guest, Charles McCary from Dove Dental.
Resources:
- EPA FAQs on Amalgam Waste https://bit.ly/3HfjiQz
- ADA Best Management Practices for Amalgam https://bit.ly/3UELVts
- Dove Dental http://www.dovedentalproducts.com/
- Capt-all from Dove Dental http://www.dovedentalproducts.com/collections/capt-all-handheld-amalgam-capture-device
Welcome. I'm Leslie Cannum. I'm Mary Gavoni.
SPEAKER_02I'm Linda Harvey. I'm Olivia Wan. And together we are the Compliance Divas.
SPEAKER_01Welcome to the Compliance Divas Podcast. This is Leslie Cannon, and I'll be your moderator for this very special podcast that we have today. At the Compliant Divas, we bring clarity and simplicity to compliance by navigating regulatory compliance to keep you on course. You can subscribe to the Compliance Divas podcast through your favorite podcast app, or you can go to our website, thecompliancedeivas.com. Resources that we mentioned during our podcast today can be found on the compliancedevas.com website. Resources that we mentioned during our podcast can be found in the show notes. And we'd love it if you would send questions to us at support at the compliancedevas.com. So let's get right down to our very interesting podcast today. Back in July of 2020, there was an EPA final rule that applies to all dental offices with very few exceptions. It is a rule that required dental offices to have an amalgam separator if they place or remove amalgams. This created a little bit of a hardship for folks that didn't have it, or folks that said, well, we don't place very many amalgams, or in fact, we've done away with amalgam altogether. Why do we need to do this? Well, it's an EPA final rule, and we have a very special guest, Charles McCary, who is going to tell us all about why we need to capture amalgam and make sure that it doesn't put us in a position of being non-compliant. Here at the Compliance Divas, we want to make sure that our clients are safe, that patients are safe, and that they're compliant. So when it comes to amalgam waste, are you compliant? Welcome, Charles. Thank you very much for joining us today. And I'd like you to just give us a little bit of information about yourself. We've known you for many years at the Compliant Divisive through various different dental meetings and particularly our beloved Association for Dental Safety, formerly known as OSAP. Tell us a little bit about yourself.
SPEAKER_00Oh well, thank you for having me. I'm I love talking about our product. So, as I mentioned before, I've been into business for like 40 years of dental. So I was involved with uh like managing uh a region for an independent company. And I noticed uh some things when I'd send a service tech out. Many times they'd come back and say, Oh, what was the problem? And they said, Well, the amalgam separator was clogged up, then it shut their suction down. And I said, Oh, really? Yeah, okay. Well, glad we took care of that. But maybe we should start checking these amalgam separators, which have by the way, they've been around for more than 2020. They've been, it's about a 30-year technology. So, what a lot of people don't understand is an amalgam separator captures everything solid that comes through the dental vacuum system, not just amalgam. So they mostly fill up with profit paste. So, as you might understand, if you have two or three hygienists, they're gonna fill up pretty quickly. And we notice that because we sell profit paste too when I was involved with that. And uh an office would buy five or six boxes of new pro you know a month, so that's being captured somewhere. And anyway, what we found is I said, Why don't you start checking these amalgam separators for our clients? And they said, Okay. So what they would say is, you know what? 90% of them are already overfilled. And we noticed another thing, there's a bucket in the equipment room that you're supposed to put chair side traps in. There's never any traps in them. So where are the chairs? Where's that that amalgam? So the EPA did their own research, and uh they they claimed, which I would think everybody would believe, that 70% of the amalgam is captured in a chair side trap. And so what do they do with it? Usually some offices rinse it out in the sink and reuse it, some throw it into the regular trash, and then even worse, someone says, Oh, yeah, I'll throw it in a biohazard container. So that either goes to the landfill or is incinerated. So that's where we sit. I thought to myself, there's gotta be another way, there's gotta be a better way. And so what we've developed is a way where it's captured at the source, which is called port of source technology. And I learned this from actually the water authority people in my hometown. They said we always prefer capturing at the point of source, any kind of toxic material. So I know I rambled on there. Does that answer your question?
SPEAKER_01It sure does. And you know, the point that you make about overfilled amalgam separators, uh, I conduct a lot of on-site training and in office uh audits and inspections for compliance. And you're right that the amalgam separators are overfilled. I don't think that they uh realize that because it's just like you said, it's not point of use. It's it's out of sight, out of mind. And and I have asked many times team members, what are you doing with those chairside traps? And you were exactly right. They were either rinsing them and reusing them to, I guess, be uh economical or frugal, or they were throwing them in the trash and they're not knowing that that they're in violation and could get cited for this. And it's harmful for the environment as well. Mary, you had some questions. Would you just go ahead and take over the microphone and fire away?
SPEAKER_03Absolutely. Again, Charles, welcome and thank you for joining us. And I think you may have started to answer my questions already. Um, I love your story about why you came up with this technology because of the efficiency and the need to capture the amalgam at the source. I see, just like Leslie shared and you shared, all kinds of practices that are just tossing the traps out in the trash, or putting them in the sharps container with the biohazard waste, which is the worst thing they can do, or rinsing the scrap down the sink. And the job that everybody hates the most is, of course, having to change the filter of the cartridge in the amalgam separator. They'll put it off forever because they don't want to touch it. And there are some states, I know I'm originally from Michigan, and in Michigan, they require a weekly monitoring of the amalgam separator. They've had an amalgam separator rule in place since 2013. So some of those people now are coming up on their grandfather date that they're gonna have to replace their separator or use something else that keeps them in compliance. And I'm sure they're not the only ones. I think Vermont was one of the first states that required amalgam separators, if I remember correctly. So the biggest question we have, and I know that you can reassure us on this, is CAPDAL approved by the EPA to be in compliance with that Clean Water Act?
SPEAKER_00Yes, it is. Um, I actually went to Washington several years ago and met with the EPA, and I've sort of educated them on the technology that is available because they don't, they're not in dentistry. They know that you're supposed to brush and floss, but that's about all they know about dentistry. So, and they were, yeah, they were great. And and I want to say one thing. You know, if an office uses amalgam separators properly, they work. But you're right, it's even on the IFUs, say to check it weekly, right? And then you're supposed to see there's a fill line, it's about halfway up that cartridge. And of course they have to get a flashlight and shine it through the backside so you can see it because it's pretty cloudy. But I want to say that if they have an amalgam separator and they follow the instructions of use and they recycle the chair side traps when they should, probably weekly, at least weekly, that it'll work great. So, what the EPA did is we're called an equivalent device. So we have to meet the standards, and we are tested with the same material that original amalgam separators or traditional amalgam separators are tested with. It's this material we have to buy from Germany that has the proper you know particle distribution, and it's quite expensive, but we have to get that and run these tests, and you have to capture over 95%. And we're at like 98.7%. Um, but keep in mind it's captured at the source because it's only per patient, only when you're using uh when you're involved in amalgam, do you use our product, which is easy to know. You either look in the chart or you look in the mouth and you say, okay, I need a captal tip. So another thing that we've prevented, and we have we've done independent studies to prove this, is that it completely eliminates dissolved mercury. Because as a as the amalgam sits in chair side traps over the years, it's dissolved. I mean, well, I say over the years, sometimes they're it literally their chairside traps are years old before they're changed. But they usually don't change them until their suction starts dropping, and they say, Something's wrong here. We've gone out many times when they say we lost suction, and it's but we have to change the chair side trap. So y'all know this, right? So you know, offices say don't use any bleach when you're cleaning the vacuum lines, which is a good policy, right? Anything acidic. But what does a dentist use every day? Phosphoric acid, acetones, even the clean water, the water disinfectants are acidic. A lot of them are citric acid. So there's chemicals going through the vacuum lines all day long, every day. And it's dissolving the amalgam, and it's dissolving, leaching out the mercury that's in the amalgam, sitting in the chair side traps and in the vacuum lines, and sometimes even in the amalgam separators, if they're not changed.
SPEAKER_03So even though we may think we're doing this really good job of using the amalgam separators, we're not completely protecting the environment unless we're using this kind of a device. And it is just to clarify, because I'm sure that there will be people out there that think that they can get more than one patient use out of a captal device, that it is one patient use, and you use it when you are removing amalgam. And I also like the feature that it also has a backflow prevention device on it. Right, it does help cross-contamination.
SPEAKER_00Yeah. And that's a good point because when it's in a captal tip is encapsulated. And from what I think an OSHA standpoint is you don't expose the assistants, because they're usually the one that changes the chair cell traps, right? And they're usually the one that has to go back there and change that filter, unless they call a service company, which a lot of them do, which is a big expense. But they're exposing themselves to this mercury that is it is you're y'all scientist, and you know that you know it's elemental mercury is not that dangerous. I'm not ever saying mercury in your mouth is dangerous, you should remove it. But when it's removed to the environment, it changes. It changes from elemental to methyl mercury, and that's what you find in fish, and that's what. So if unbeknownst to an assistant, she doesn't use eye protection, she's changing chair subtraps, they stick, you know, usually they have to pull on them with some pliers, and then it plops out and it get in their eyes. It could get, you know, they could be exposed to it. I don't know if that's a legitimate concern, but I I think it is.
SPEAKER_03Absolutely it is. I can guarantee you that there will be a number of assistants who are in charge of changing those traps or changing the filter on the amalgam separator that have not been trained, do not understand, don't read the IFUs to know what kind of PPE they should be wearing. They may wear gloves when they're removing the suction traps, but probably not respiratory protection, probably not eye protection. So that's a great point that you make, Charles, and thank you for bringing that up.
SPEAKER_00Okay.
SPEAKER_01Olivia, you had a question for Charles.
SPEAKER_02Yeah, first of all, Charles, we appreciate always seeing you at the conferences and getting our education updated with the information you bring to the table. And I agree with you that these amalgam separators are effective, they work. But what we've seen is when we go on site, nine times out of ten, we're taking photographs of the amalgam separator showing that it's exceeded the fill line. Now, one of the things that Linda Harvey and I had been talking about was the plastic. You know, what about with the cap doll device? What is your suggestion? Or what happens to the plastic for especially our practices that are adhering to an environment environmentally friendly environment?
SPEAKER_00That's a great question. I'm glad you brought it up. Because one thing, uh the carbon footprint with uh capital is a lot less, too, because we're only shipping what we, you know, amalgam, the the material we're trying to capture, right? Where a lot of the other companies are shipping amalgam, water, profit paste, and everything else. That's one point. There's a lot of plastic involved with that and a lot of extra shipping cost because of weight. But when we get those capital tips, we have a container that holds 75 tips, which is about a six-month supply for most dentists who don't place amalgams and just remove them. When we get them back, we have a system that cracks them open and gets the filter part out. You know, human hair is 100 microns thick, so that's how far down we capture. So we take that filter, we throw it into another container, and we take the plastic and send it back to our injection molding company to have it reused. So nothing ever goes to the landfill. And um we take the contaminated inner filters to uh a recycling center that's like fortuitously, it's only like 60 miles up the road from us. That's the same recycling mercury recycling center that all the amalgam separator companies use, or most of them use. And I know that's a big concern these days, is microplastics.
SPEAKER_02Thanks for clearing that up and helping us understand the process after it's utilized. So that's great to know. Thank you.
SPEAKER_00Yeah, thank you.
SPEAKER_01Charles, you know, it is so interesting to me how you break this down to these small, I guess you could say, components of suction that we never think about. We think about keeping a clear field in the patient's mouth. That's a dental assistant's job is to make sure the dentist can uh perform their job well. And uh when you're using the suction, you don't think about the various different chemicals that go through the citric acid that you mentioned that breaks down, and you don't think about how it affects what's in the amalgam separator or or other materials that have been used that uh during the dental procedures. So we appreciate you bringing that to our attention. I am again really excited about the fact that this is an equivalent device to an amalgam separator. It's certainly going to help dental practices be able to continue on with their productivity without having to have those emergency situations of an amalgam separator getting clogged up. And I especially love that you said it's 98.7% is what is being captured right there at ChairSight, right at point of views. And you know, I think I was maybe under the impression in the past that every time you see a patient, you would be putting your cap doll on. But from what I learned today, you only use the cap doll when you know you're going to be facing an amalgam that you're uh prepping a tooth, maybe an existing amalgam or you're placing an amalgam. So you don't need it for every patient. You could use your your regular high-velocity evacuator. And it your earth-friendly position of preserving the environment is so important to so many people today. So we're we're making sure that we're getting that mercury from being, I guess you could say, put back into the environment, like with the sharps containers, when when they go to incinerate that, that's just bringing that mercury right back to us with the world. We need to protect our earth. And and I think that's at the heart of many people today is that let's try to have less waste, less plastic, and do things where we're going to be more earth-friendly. I'm so excited about this. I want to find out is there a way that someone could just try a capdoll device without having to commit to buying a whole box of it?
SPEAKER_00Yes, we we we've worked that out. I mean, when we're at trade shows and such, we we hand them out like candy. Yes, like, but like I said again, you know, they they should have some type of way if they use it in the patient's mouth. A lot of them, they want to, a lot of them did to they just want to make sure it's got good suction, and they'll just put it on and slurp up, you know, water out of a cup to see how well it suctions, which to help them understand that it you don't lose much suction, hardly any. We've had a few cases where the doctors, their vacuum is so poor that they notice a difference. But very, very infrequently does that happen. And we always just tell we send them a little gauge that they could check their vacuum with without the capital, so they'll know, you know, it's probably time for another suction pump in this office. But uh, and also when we're talking about the equivalent device, I want to make it clear too that there are some municipalities that have uh different requirements than what the EPA has. We we follow what the EPA recommends or what we EPA has established as far as our modality. But there are some municipalities that have stricter, like in New York, which we're working on that, they want 99%. The EPA says you got to get over 95%. So our argument always is with yeah, we're getting 90 over 95 percent, we're not getting 99 yet, but we're getting all the amalgam instead of the 35 percent that finally makes it to the amalgam, to the equipment room. So that's our argument. But that that's uh over 90 percent of um states and municipalities are just follow the EPA's guidelines.
SPEAKER_03Mary, give us your thoughts on that. Well, thank you for bringing that last point up, Charles, because it it's of course always the responsibility of the practice owner to make sure that they're compliant with not only federal rules, but any local or state rules. And I think again, I'll use Michigan as an example because their amalgam separator rule is actually written in the Board of Dentistry rules. So they need to make sure that if they want to use Capdol, that it would be considered by those rules as an equivalent device. So we always have to follow whatever the local rules are, but most states do follow the federal EPA rules. Right.
SPEAKER_00And it's real simple. Every dentist is supposed to fill out a one-time compliance report. And one state so told us that maybe 10% of the dentists knew that. If they're not sure, all they have to do is could go to their environmental authorities that has to do with water, ask for a one-time compliance report. And if it says on there amalgam separator or equivalent device, then it's good to use capdog.
SPEAKER_03That's we can put some of those resources. Charles, I'm sorry for interrupting you. We can put some of those resources in the show notes. So a copy of the one-time report form, and I think that there is a link on the EPA website to go to states to see what the state rules and so forth. Yeah. So we'll put those in the in the resources in the show notes. Yes.
SPEAKER_01And Charles, I want to make sure that our listeners have a chance to visit the capdol website, DoveDental is actually the page that they'll go to to find the capdoll product. But I saw that you have a free sample that people can ask for. And so it's just to actually have that in your hands and really use it and see what it's like. And then remember that even if you do have an amalgam separator, you're catching it at the chair side. And that is going to override those chair side traps, which I would argue with New York that many of those chair side traps with the little chunks of amalgam are cloiled into the trash can anyway. So they're better value.
SPEAKER_00Exactly. We're working with them. And we're also working with the uh with the ADA. We're getting an ANSI uh um certification too. We'll have it pretty soon. Uh, we've been working with the ADA with on their um uh uh equipment division because it's it's in the equipment part, so we're on that. So we have a meeting every couple of months.
SPEAKER_01And everybody should have a copy of best management practices for amalgam in their office, because I think people are surprised when I say that you can't rinse these amalgam traps at Chair site and uh you you can't throw the amalgam in the trash, and then they say, well, we'll just put it in the sharps container, and they don't. So we'll make sure that we provide a copy of that, and we're thrilled to know that you are going to be moving forward, pushing the crusade forward, and we'll be following that as we go along. And and we thank you so much for joining us today. And what we'd like to do is close our program by reminding our listeners that we bring clarity and simplified simplicity to compliance by navigating regulatory compliance to keep you on course and bringing folks like Charles in to give us the information and help clarify that is just so helpful. You can submit your questions to support at the compliance divas.com. Look for these resources that we mentioned in the show notes of your podcast. And if you wouldn't mind, leave us a little review while you're there. Thanks so much, everyone, and we're going to sign off for today. Thank you, Charles.
SPEAKER_00Thank you so much for having me.