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
#95 Understanding Hazardous Waste in Your Office
Use Left/Right to seek, Home/End to jump to start or end. Hold shift to jump forward or backward.
As we all know, there is heightened awareness around water safety. This not only includes water used during patient care, but also how that same water is discharged into waste water streams. This podcast addresses specific requirements for dental practices related amalgam waste in your office.
State Compliance Report: https://solmetex.com/compliance-reports/
Solmetex: https://solmetex.com/solmetex-product-series/
EPA Regulation 4 Components:
https://solmetex.com/wp-content/uploads/2022/06/EPA-Reg-Flyer_0622.pdf
Welcome.
SPEAKER_04I'm Leslie Cannum. I'm Mary Gavoni.
SPEAKER_02I'm Linda Harvey. I'm Olivia Wan, and together we are the Compliance Divas.
SPEAKER_03Welcome to the Compliance Divas Podcast. This is Linda Harvey, and I will be your moderator for today's podcast. As we all know, there's heightened awareness around water safety. And this not only includes water used during patient care, but also how that same water is discharged into the wastewater systems. This podcast addresses specific requirements for dental practices related to amalgam waste in your office. Please remember that the Compliance Divas bring clarity and simplicity to compliance by navigating the regulatory world to keep you on course. All the resources that we mentioned in today's podcast will be available in the show notes as well as on our website, thecompliancedivas.com. We invite you to subscribe to our podcast at your favorite podcast channel or through our website, thecompliancedevas.com. And any questions that you may have can be submitted to support at thecompliancedivas.com. Today the divas are pleased to be welcoming Solmetex as our podcast guest. You may already be familiar with the Solmetex company through their gold standard amalgam separation device. This device is in over 80,000 offices in the United States. What you may not know about Solmetex is that in their quest to become the solution provider for end-to-end water safety, they searched out other companies with leading market products in their category. And as a result, Solmetix has acquired the Drive Shield Modern Evacuation and Isolation System, as well as the Sterocell Company. Because they are all focused on water flow throughout the office. With the Silmetics model of hassle-free collection container replacement and recycling, they are on a mission to do the same thing for your water safety as well. So I'd like to welcome Brian Brigentheim, who is the Director of Sales for the East Coast. Brian, pleasure to have you today.
SPEAKER_00Pleasure to be here.
SPEAKER_03So we're excited to be speaking about this topic because it is a hot topic and it's one that's been has changed over the years as well. And I've been thrilled to watch Silmetrics as you all have grown and just really evolved in this whole process of bringing better solutions and best in class solutions to help dental offices provide the safest dental visit through the quality of the water. So I'd like to call on Olivia Diva first to talk about maybe some compliance pieces with the law. Olivia, what questions might you have there?
SPEAKER_02Hi, Brian. Thanks for being on this episode. So I'm looking at the EPA's website and they published these guidelines. And of course, as I advocate to clients, don't get tricked up with the word guideline because the dental office category is a regulation codified at 40 CFR part 441. So, Brian, can you help enlighten us on what are the key components of this law that you can share with our listeners?
SPEAKER_00Absolutely. And I know you know there's sometimes some confusion in that people consider this an amalgam separation law. And really what's involved is um handling all amalgam waste in the office, both dry and wet. Um, so really the the the four key components are every office, with the exception of a few specialties, needs to have an ISO-certified amalgam separator. Um, they need to be using a solution for dry waste, which would be our scrap buckets. Um, they need to be using a evacuation line cleaner that has a neutral pH. And the old state regulations used to consider that of a pH between six and ten. When the federal government finally passed their mandate in 2017, they actually tightened that threshold up, and the acceptable threshold is now only between six and eight. And then the fourth component is that offices must maintain records for a minimum of three years, showing that they've been compliant and with their recycling records.
SPEAKER_02Thanks for that information. That's a good brief overview, and I'm sure that our listeners will want to add this information to their compliance checklist.
SPEAKER_03Olivia, that's a great idea. I think it's for them to add these items to their compliance checklist is really important. Um, at that point, I'd like to call on Mary to talk about some of the other aspects. One of those, Mary, is the scrap amalgam buckets. What thoughts do you have on that with Brian?
SPEAKER_01Absolutely. And thank you so much, Brian, for being here with us today. Um, I think that it's very important what you mentioned earlier about the two types of amalgam waste, the wet waste and the dry waste. Um, I still encounter many folks in practices that are simply taking their disposable suction traps and either throwing the suction trap away in the regular trash, or what's probably even worse, if they didn't have their amalgam separator in place, they're cleaning it out and dumping it down the sink. So um I think that all of the practices need to be very cognizant of what they're doing with that scrap amalgam. And many people say, well, we don't place amalgam, so we don't have any, but you're certainly removing amalgam. So you're going to have some accumulating in those disposable suction traps. And I'd love to hear any special um feedback or trip tips that you have for us on that, Brian.
SPEAKER_00Absolutely. And you know, even worse than throwing it in the garbage or just rinsing it out is people sometimes will throw that into biohazard, and biohazard gets incinerated. Um, and effectively what that what's happening there is that we're releasing mercury vapor into the environment. Um there are, as a guideline, there are five things that need to go in those scrap buckets. The first two only apply to offices that are placing amalgams, and that's empty uh capsules and any scrap amalgam that's not placed into the mouth. Um, besides that, then you have your chair side traps, you have the evacue traps on wet ring suctions. And the fifth item is the one that really kind of makes people scratch their head, and that's extracted teeth. If there's an amalgam in them, it has to go in a recyclement bucket. A jar of bleach is not an acceptable way to dispose of it, um, nor is throwing it in the trash or in biomass. They need to be the buckets need to be recycled at least once a year as well, just like the collection containers on the amalgam separators are. Uh, we definitely find that there are a lot of offices that don't know what to do with those buckets or know how to recycle the dry amount of waste properly. We walked into offices where we see the amalgam separator sitting on top of the bucket instead of being mounted to the wall. Um, you know, for a while, we included a one and a quarter gallon bucket with every new separator system. And we we scrapped that about a year and a half ago uh as we realized that they just weren't getting returned with the regularity that we needed to see.
SPEAKER_01Thanks for that clarification, Brian. And I'm so glad you mentioned about the um empty capsules because many of those go in the trash. I think more people have uh a reasonable understanding about extracted teeth that they cannot go in the sharps container because of the incineration, but they don't understand that there may be trace mercury still left behind in that um empty amalgam capsule. So that's a very, very important point. Thank you so much.
SPEAKER_03I'd like to circle back with the suction traps and chair side. Do you think that the delhygienist has to worry about it as much as the doctor side does?
SPEAKER_00Um, probably not have to worry about it as much, but I would say just for the sake of uniformity within the office and keeping the protocols the same, I would I would say that the the best measure would be to dispose of those traps the same way as the operatories.
SPEAKER_03That's nice because it keeps one system the same for everybody. So I think that's a good idea. And I've noticed over the years, and just helping offices to make that distinction about what goes in the different waste, pharmaceutical waste, even, versus biomedical waste and then the hazardous waste, that sometimes the offices will tell me that their biomedical waste pickup folks don't check what's in their containers or their red bags. And so I'd like to remind our listeners that legally and ethically, we need to be putting all these waste into the right proper canisters and disposal methods because as many of us have become more environmentally conscious, and sometimes our listeners and our audiences, Brian, will say to us, how can we recycle more? How can we have so much waste in dentistry? And certainly this is a big way that we can impact the environment. And I think that's a really big piece. So I just wanted to mention that. Mary, what thoughts did you have?
SPEAKER_01I'm so glad that you brought that up about um disposal, because when someone in an office signs the manifest when that material is picked up, or if it happens to be shipped, because some states will allow that. What you're saying is that you attest to the fact that this is appropriately segregated and packaged the way it is supposed to be disposed of. So that makes that practice liable if they're incorrectly segregating information or materials in that.
SPEAKER_03Thank you for bringing that point back around, Mary. Absolutely. Absolutely.
SPEAKER_00And I'll add in terms of amalgam waste specifically, yeah, the the office is absolutely liable. Um, we use the phrase all the time for cradle to grave. And so, you know, with the system we've designed and even being able to ship back those collection containers, we're really the only company that has been certified by UPS in all 50 states to ship um hazardous material via common carrier.
SPEAKER_03You're getting thumbs up from all the divas right now. That is really important information to know. So that's that's great. Thank you very much.
SPEAKER_02Awesome.
SPEAKER_03So, Leslie, what what can we talk about? Um, I know Solmetics has a portal and you're really big on a lot of education, as we all are. So, would you like to ask Brian some questions about the portal and discuss that feature of Sometics?
SPEAKER_04Yes, Linda, as a former dental assistant, I find that keeping track of all of these compliance issues can certainly uh bugger up your day, especially if you have a busy dental practice where you're you've got patients in and out, you've got to try and work emergencies in, you've got instruments you have to process. And I have seen that Silmetics has a portal that can make this easier for people to keep track of key compliance elements. Brian, could you walk us through how that compliance portal makes it easy for officers to stay in compliance with EPA's dental rules that we heard about?
SPEAKER_00Absolutely. And I would say that the you know best practices still would include printing out your recycling records and keeping them in a binder with the rest of your compliance records. However, if the office doesn't do that, they can log into they can log into the Soul Medics website 247-365 and be able to access uh their recycling records from the time they began recycling up through the present. When an office sends in their collection container uh for recycling, within about 10 days, that recycling record will then be on uh on our website in the compliance center. And like I said, the offices can access that anytime.
SPEAKER_04Is there some kind of a certificate that they get once they have sent in their uh recycled container?
SPEAKER_00Yes, it's it's a certificate of recycling. Um it exists for both wet waste from the amalgam separator and the dry waste that should be disposed of in the scrap buckets as well.
SPEAKER_04That is amazing because I think for both for uh reminding yourself to be able to get these containers back in within the year period or when they're full, but also uh being able to access it right online. So many dental practices are trying to go paperless. So, of course, downloading it to a three-ring binder never hurts, if especially if you had EPA, walk in the door and want to see what you're doing. I know we have in California, sometimes the water agencies will visit dental offices and they want to check and find out what they're doing to uh protect the effort that is going out of their office. And so that would be handy to be able to log in quickly and show compliance. Is there anything else that would be helpful for our listeners to know about the portal when it comes to shipping those containers?
SPEAKER_00So, to answer that question, Leslie, um, when when an office receives a new collection container, it comes with a cap that they use to cap off the old container. There's a code on there, they go onto the website and they can just print off their shipping label from the website right then. And within 10 days uh after they've shipped that old container out or the scrap bucket, their recycling records are already logged into the compliance center. So it's super easy for them.
SPEAKER_04That does sound super easy. And you know, while you were talking, I was looking at the Silmetics website. There's even a video that gives instructions on what you do to actually remove the old separator, how to cap it off, how to log that number on the cap. That's easy peasy. And uh anything we can do to make the life easier for the dental team members who are already quite impacted with what they do every day to serve their patients certainly is a big win.
SPEAKER_00We we've we've really tried to make it as easy as possible. And um, you know, the videos absolutely help as well. And we, you know, we've we've always taken pride in the fact that we are a true turnkey solution when it comes to this.
SPEAKER_03I think that's fabulous. Um I think Mary would like to ask a follow-up question on that, Brian.
SPEAKER_01Actually, I want to thank Brian for what he mentioned earlier about being able to um download or print off your um certificate of recycling. This is something that I encounter with practices I consult with all the time, that they do not understand that cradle to grave clause that you mentioned before, that they must have documentation of when and how their waste was disposed of because they are still liable or responsible for it, even if it's not in their possession, until it has been recycled or or destroyed. So that's a very important thing. And I encounter some companies that don't, they they poo-poo that, they tell people, oh, you don't have to worry about it. We take care of all that. But as we all know, in it with any of these government agencies, the assumption is if you don't have something in writing documented that it wasn't done. So thank you, Brian, for bringing that up. Absolutely.
SPEAKER_04Leslie, would you like to follow up on that, yes? I'm really excited about not only the certificate, but the portal, because I think that a lot of times we rely on somebody else to take care of the essentials in a dental practice. And I was in a practice recently where they said, well, we have a guy that takes care of uh taking our amalgam separator. I went back and looked at their amalgam separator, and its installation date was October 5th of 2021. So they clearly didn't have a guy come in in 2022 or 2023 at all to remove that. And it's I'm excited that this is something that, well, to put it bluntly, I want to make the recommendation for all dental practices to go take a look at their amalgam separator upon hearing this podcast and just check to make sure that they have been sending out on time as they're supposed to comply with the law.
SPEAKER_03Oh, Brian, I'm super excited about that. I have to jump in here. Can I share the trip, the tick, the tip, pardon me, that or trick that you shared with me years ago about the flashlight?
SPEAKER_00Sure.
SPEAKER_03Now our listeners will be wondering what I'm speaking about. So to make to determine whether the canister is full or not, when you go into the pump room, you need to have a flashlight. Um, position yourself so you can turn the light out, maybe have a colleague with you so you don't get shut in the door or locked in there. But you want to look at the uh suction in the canister when the pump is off. And with the flashlight, now you can really determine how full is the canister. Because when the pump is on, the water's circulating through there and it's going to always look full, but you can't tell. So for clients and for our listeners today that are wondering, thinking, oh, I can just use this once a year. I don't have to worry about it. It's on autopilot, not necessarily so, depending on the size and volume of the practice. So, so Brian, would you add to that? Did I miss anything?
SPEAKER_00No, you you pretty much nailed it. Um, we've we've always suggested that you do it first thing on a Monday morning before you start up the vacuum system. That way it has a chance to settle over the weekend. Um, and yes, start with uh take a flashlight and start at the bottom of the collection container and work your way up. When once you start seeing light passing through to the other side, you know that that's the sediment mark. Um, you know, in a perfect world, you'd be able to just take a quick look at it any old time. But obviously the longer the container is on the separator, the darker and murkier it's gonna get. So it gets harder when later in the life of that container, um, it gets harder to see really where that delineation is.
SPEAKER_03That's perfect. And I think that's just something small. Uh many offices try to delegate this to their technicians and whatnot, but I think we they need to know and understand this piece too, so they can follow up and as Leslie said, not just assume we have some guy that's going to do it, but making sure that it's done because ultimately, as we said before, it's the responsibility of the practice, and particularly the doctor, from cradle to grave.
SPEAKER_00And I've always suggested that one person in the office is responsible, consistently responsible to check and maintain that. Um, so whether that's the doctor, whether that's an assistant or a hygienist, you know, it's the problem becomes sometimes with just staff turnover, that it's one of those things that ends up kind of falling through the gaps over time. Our salespeople or dealer technicians even will walk into utility rooms all the time and see overflow containers because it's just whoever used to do it isn't there anymore and nobody's taken a look at it since then.
SPEAKER_03Well, I think this is a good tip for our listeners, Brian, because they can add this to their checklist. Many of them have a daily, weekly, or monthly checklist that they have somewhere in the office. And even if you have a team where you have not had any turnover, please go add this to the checklist now if you have not, don't have it on there already. And likewise, any team should add this to the checklist so that way there's some hope that this information gets transmitted from former team members or leaving team members to the new team members and make it easier to maintain compliance, because I know all of us, divas, have had a situation where someone has walked in from a federal or state or even a county agency and they want to see the records. Whereas so many folks in dentistry, Brian, get pigeonholed on OSHA and worried about OSHA compliance. And that's a big piece of what we do for safety, all of us in dentistry, um, us as consultants with the divas, and then all of our teams and the doctors' responsibilities. But there are other areas of compliance. This is a very key area. Brian, can you think of anything that we've that we've missed? Did we talk about the specialties that might be exempt? We're talking about everybody that has to do this. Maybe we should hit on that piece.
SPEAKER_00Certainly. And you know, the the one specialty that um makes the most sense to be exempt is orthodontists. Um, they're not they're not cutting at all, right? So that's that's the natural one. Um, the other exemptions are peria, prostodontis, and oral surgery as well. Um, oral surgeons should still be using amalgamus scrap buckets for extracted teeth for sure. Um, beyond that, you know, they are not required to have an amalgam separator in place, but they are still required to follow the other best management practices.
SPEAKER_03Brian, can you think of anything else that we want to circle back um to remind our listeners or recap the requirements for record keeping? And maybe our divas might have some final questions as well.
SPEAKER_00Um I'd like to just give a little attention to our evacuation line cleaner, Power Scrub, um, because that is the neutral pH evacuation line cleaner is one of the requirements of the of this uh regulation. Um we we launched PowerScrub a few years ago. It was really such a natural fit for us that it's likely something we should have done years earlier. Um, it is a true neutral pH of seven, and it's microbial formulation as opposed to concentrated enzymes or a chemical. Um, so what what it does effectively is it releases bacteria that then multiply by the millions and eat away at all organic material in the lines. Um, because of the way it works, it also tends to help settle the waste in the collection container a little bit better than most line cleaners out there. So they should be getting a little bit longer life out of their container without having to change it out quite as soon. Um, you know, there's there's a lot of line cleaners on the market that make the lines slippery, but don't necessarily do a really good job of scrubbing the actual lines. And that's fine if the lines are clean already. But for offices that haven't traditionally done a good job taking care of their vacuum lines, they're they're not introducing any sort of product that's going to eliminate the debris that's presently there. And we really believe that we have the best evacuation line cleaner in the market because of it. Additionally, one of the really interesting things about this uh solution, which is actually a mix of six different strains of bacteria, is it has the uh transformative property to it where it actually can take methylmercury and make it non-toxic. So it turns uh a toxic mercury into an inert substance.
SPEAKER_03That's quite impressive. I think many times um this is something that goes on autopilot in a dental practice. What are we using? Let's grab a product, we buy something that's on sale, or we just use something because we've always used it. But to recognize that to use a proper product, be compliant is really important. And I remember us having that conversation years ago, Brian, when you first came on with Solmetics, you were educating me about the pH and how to read this. And for a long time, we were helping clients look at the safety data sheet, looking at the pH of the product, but it wasn't you know explicitly listed on the container. And so this is like the the really the go-to product. And isn't there something that Solmetics offers if your clients are using the Power Scrub Vacuum Line Cleaner?
SPEAKER_00We do. Uh, our NXT HG5 amalgam separators are warranted for two years. If they're using Power Scrub, we extend the warranty to five years instead.
SPEAKER_03That's pretty awesome. It makes it uh pretty much a no-brainer to go to look at that and use it and just really protect the equipment all the way around because if you're protecting the amalgam separator, you're helping to protect the pump and it's just all those investments that keep the practice running smoothly.
SPEAKER_00Absolutely.
SPEAKER_03Well, Brian, it's been a pleasure having you on our podcast today. We're so thrilled to go into detail about these important requirements for offices, and we invite our listeners to probably listen to this podcast more than once to take away all the different aspects of compliance with the different amalgam waste separation and just the whole aspect of from cradle to grave and becoming familiar with all those, especially for any of our listeners who are new to dentistry. All the resources that we mentioned in today's podcast will be found in the show notes as well as on our website. And we thank you for tuning in to the Compliance Divas because we bring clarity and simplicity by navigating the regulatory compliance world to keep you on course. We invite you to subscribe to our podcast either through your favorite podcast channel or on our website, thecompliancedevas.com. And any resources, as I just mentioned, will be in the show notes or on our website. And if you have any questions, please feel free to submit them to support at the compliancedivas.com. And we look forward to seeing you next time.