Regulation (EU) 2017/852 on mercury, Article 10 (retained in UK law); Hazardous Waste (England and Wales) Regulations 2005; Environmental Protection Act 1990, section 34 (duty of care)
Amalgam separators: maintenance and waste requirements
Dental amalgam contains mercury. To stop it entering the sewer, dental facilities where amalgam is used or amalgam fillings are removed must be fitted with amalgam separators. The requirement comes from the EU Mercury Regulation, which continues to apply in Great Britain as retained law: separators have been required since 1 January 2019, and all separators in use must provide a retention level of at least 95 per cent. Separators are maintained according to the manufacturer's instructions to keep that level of retention.
In plain English
Dental amalgam contains mercury. To stop it entering the sewer, dental facilities where amalgam is used or amalgam fillings are removed must be fitted with amalgam separators. The requirement comes from the EU Mercury Regulation, which continues to apply in Great Britain as retained law: separators have been required since 1 January 2019, and all separators in use must provide a retention level of at least 95 per cent. Separators are maintained according to the manufacturer's instructions to keep that level of retention.
Collected amalgam waste is hazardous waste. It must be stored safely, handed to an authorised waste carrier and consigned under the hazardous waste rules, with the paperwork kept. The practice's duty of care for its waste applies from the moment the waste is produced until it is finally disposed of.
Dynamo Dental installs, services and repairs amalgam separators as part of suction work. Waste collection and consignment are arranged by the practice with a licensed waste contractor.
Who does what
Your responsibility as the provider
- Having a suitable amalgam separator on every suction line that can carry amalgam, and keeping it working
- Maintaining the separator to the manufacturer's instructions, including replacing containers or elements when full or at the interval specified
- Storing amalgam waste in the containers the waste contractor specifies, away from patients and staff
- Using a registered waste carrier and an authorised disposal or recovery site, and keeping consignment notes for the period the regulations require
- Managing the other amalgam waste streams (capsules, chairside traps, extracted teeth with amalgam) under the same rules
- Checking the Environment Agency's current guidance on hazardous waste producer duties
What Dynamo Dental delivers directly
Dynamo Dental installs, services and repairs amalgam separators as part of suction work. The arrangement for any container replaced during a visit is agreed with the practice beforehand, because transporting hazardous waste needs an authorised carrier.
- Installing amalgam separators in suction systems, in the position and orientation the manufacturer specifies, and commissioning them
- Servicing separators: replacing containers, filters or centrifuge elements as the manufacturer's schedule sets out, and checking alarms and level indicators
- Repairing separators and the suction pipework and traps around them
- Recording each container change, element replacement and alarm event against the asset, with the next due date
- Explaining how the separator on your system works and what its alarm means
Verified specialist competence, or a specialist partner
- Collection, transport and disposal of amalgam waste: a registered waste carrier and an authorised disposal or recovery facility, under a contract with the practice
- Hazardous waste consignment paperwork: the practice and its waste contractor
- Guidance on clinical waste streams more widely (HTM 07-01): the practice's waste lead
- Questions about trade effluent or discharge to sewer: the water company
Outside our scope
- Transporting or disposing of amalgam waste, or acting as a waste carrier
- Completing or holding the practice's consignment notes
- Certifying that a separator or the practice complies with the mercury or waste regulations
- Advice on amalgam use in clinical practice
Questions
Questions on this topic
How often does the amalgam separator container need changing?
It depends on the separator's design and the practice's amalgam workload. The manufacturer specifies a maximum interval, and most separators signal when the container is nearly full. We record each change and the next due date on the asset register. Do not run past a full-container alarm, because retention drops.
Can Dynamo Dental take the full container away?
Amalgam waste is hazardous waste and must be transported by a registered carrier and consigned with the proper paperwork. The arrangement for the replaced container is agreed with the practice before the visit; the practice's waste contractor normally collects it. We do not act as a waste carrier.
Other topics
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 15 (Premises and equipment)CQC Regulation 15: premises and equipment
- Health and Social Care Act 2008; Health and Social Care Act 2008 (Regulated Activities) Regulations 2014Health and Social Care Act 2008: regulated activity and equipment
- Provision and Use of Work Equipment Regulations 1998 (SI 1998/2306)PUWER 1998: Provision and Use of Work Equipment Regulations
- Pressure Systems Safety Regulations 2000 (SI 2000/128)PSSR 2000: Pressure Systems Safety Regulations and dental compressors
- Pressure Systems Safety Regulations 2000, Regulations 8 and 9 (written scheme of examination; examination in accordance with the written scheme)Written Schemes of Examination for dental compressors
- Electricity at Work Regulations 1989 (SI 1989/635)Electricity at Work Regulations 1989 and dental equipment
Not sure what records you should have?
The Practice Engineering Survey establishes what exists and what is missing, without claiming to be an audit.
- 07915 527 907
- info@dynamodental.co.uk
- WhatsApp us
- Monday to Friday, 8am to 6pm