Here at Isopharm, we have received numerous calls over the past few months through our compliance clinic from concerned practice owners over whether there is a need to install amalgam separators on dirty sinks and washer-disinfectors from January 2019.
This has been a concern for many as there was no clear guidance to whether this was a requirement or how the New EU Regulations had been interpreted by some.
We have been advising all our customers with concerns to hold off investing a considerable amount of capital into amalgam separators for dirty sinks and washer-disinfectors until the situation could be clarified.
New EU Regulations stated that:
‘From 1 January 2019, operators of dental facilities in which dental amalgam is used or dental amalgam fillings or teeth containing such fillings are removed, shall ensure that their facilities are equipped with amalgam separators for the retention and collection of amalgam particles, including those contained in used water. (EU)2017/852’
‘If a practice uses or removes amalgam, the chair must be fitted with an amalgam separator, which is designed to remove amalgam waste particles from the waste water and should be of ISO standard 11143:2008.’
With the introduction of HTM 07 – 01 it was advised that:
All dental practices should have (an) amalgam separator(s) installed. These should be of an appropriate ISO standard and fitted in such a way that they capture any amalgam contained in wastewaters.
With this in mind, we had advised that all practices ensure they have robust risk assessments in place to ensure that the amount of amalgam particles possibly going down a dirty sink or through a washer-disinfector and entering our public sewer system would be negligible.
British Dental Association view:
On the 21st December, the British Dental Association after discussions with the British Dental Industry Association released an update on their view of the situation and stated:
‘It is the BDA’s view that separators on these areas are not necessary.’
In relation to this issue, practices may wish to consider the following:
- If you do decide to have a filter box placed under your dirty sink and/or washer disinfector, ensure it is changed at appropriate intervals. This frequency will vary from practice to practice.
- Ensure any excess amalgam is disposed of safely chairside. For example, dispose of excess amalgam in carriers or dappens dishes either down the spittoon (which will then be separated by the amalgam separator on your suction unit) or placed directly into the amalgam waste container.
- Ensure you are adhering to other appropriate controls around amalgam usage eg high volume aspiration and encapsulated amalgam only.
- Ensure you keep a log book for your amalgam separator(s) which demonstrates adherence to correct maintenance, inspection and disposal.