MEMORANDUM

TO: Carey Johnston, EPA/EAD 

Damon Highsmith, EPA/EAD 

FROM: Meghan Camp, ERG 

DATE: 23 March 2011

SUBJECT: Dental Recycling North America, Inc. (DRNA) Meeting Minutes for 19 

January 2011 

On 19 January 2011, EPA met with Marc Sussman and Dr. Alfred Frost of DRNA 

Dentalcare Waste Management to discuss amalgam separator technologies. Discussion topics 

included: 

 Introductions; 

 Background on DRNA Amalgam Separators and Services, including: 

 Separation Technologies; 

 ISO Standard and EPA/ETV Standard; 

 Maintenance and Recycling; and 

 Regulatory Considerations. 

Attachment 1 lists the meeting participants. 

Introductions 

Dental Recycling North America, Inc. (DRNA) provides waste management services to 

dental facilities including amalgam separator equipment, recycling services, amalgam disposal, 

sharps and medical waste disposal, x-ray waste recycling and disposal, and pharmaceutical waste 

disposal. Some of DRNA’s main areas of business include servicing facilities for military, 

veterans’ affairs, and community centers. 

Mr. Sussman provided background information on DRNA’s philosophy regarding the 

dental amalgam issue, which DRNA views as a waste management issue. DRNA handles dental 

waste, including but not limited to amalgam, with a focus on recycling and providing dentists 

with a solution for regulatory compliance. He stated that there is a common misunderstanding 

among dentists, who often believe that simply installing an amalgam separator is enough to 

comply with state or local requirements. Mr. Sussman asserted that proper maintenance and 

recycling is equally important to the separator equipment because an amalgam separator will not 

function if it is not maintained. Purchasing and installing an amalgam separator is only the start 

of the process. 
 Memorandum 

23 March 2011 

Page 2 of 5 

Background on DRNA Amalgam Separators and Services 

Prior to the meeting, EPA sent Mr. Sussman and Dr. Frost a list of questions for 

discussion. The following summarizes information that Mr. Sussman and Dr. Frost provided in 

response to these questions. 

Please describe the technology-basis of your separator models.

DRNA sells two amalgam separator lines: 

 ISO-certified amalgam separators, including BU5 (<8 chairs), BU10 (up to 8 

chairs), and BU30 (up to 20 chairs); and 

 EPA-ETV certified amalgam separators, including MRU10 (up to 8 chairs) and 

MRU30 (up to 20 chairs). 

The BU models use sedimentation to remove 99.9 percent of solids. The MRU models 

use the same sedimentation technology as the BU models for solids removal, but also include a 

sorbent column to remove soluble mercury. Overall removal for the MRU models is greater than 

99.9 percent of solids and soluble mercury. DRNA is one of the only companies to develop an 

EPA-ETV certified amalgam separator model. Mr. Sussman stated that there is not much of a 

market for the MRU models with the exception of military facilities. 

What are the allowable flow rates and capacities of your various models? What is the basis upon 

which a separator is determined to be appropriate? Anticipated flow? Anticipated amount of 

amalgam? Other?

Amalgam separators are sized based on the number of chairs at the dental practice. 

DRNA’s BU and MRU models are designed to accommodate < 8 chairs or 8-20 chairs. Large 

facilities can install multiple amalgam separators in series. For example a Louisville, KY dental 

school with 130 chairs uses 15 separators in series. 

How are your separator efficiencies measured (ANSI, ISO, other)? Do you have any issues with 

the prevalent test protocols (ANSI, ISO, Other)?

DRNA’s BU line is certified using ISO 11143. Mr. Sussman provided some clarification 

on ISO certification. ISO certification means that the amalgam separator model was certified to a 

standard at the time that it was tested in a lab. It does not guarantee that the purchased unit will 

operate at 95 percent efficiency in the field. In addition, the ISO-certification assumes proper 

maintenance and change-out of the unit. 

DRNA’s amalgam separators undergo an annual audit to address any new modifications 

made to the units. DRNA uses a U.S.-based lab, NSF, to perform its ISO certification tests and 

annual audits. Once per year, NSF conducts an audit to ensure that the amalgam separator that 

they tested is the same as the units that DRNA sells on the market. NSF verifies that the list of 

amalgam separator manufacturers is the same and that the unit components are the same. 
 Memorandum 

23 March 2011 

Page 3 of 5 

DRNA’s MRU line is certified to the EPA/ETV standard. This standard was developed 

starting in 2000 in response to POTW concerns regarding mercury levels. The goal of the 

standard was to develop a technology that would achieve a mercury concentration of 2 ppb. 

Where within the dental facility, are your separators usually installed? What type of wastewater 

goes through your separators?

The amalgam separators are installed next to the vacuum pump, just upstream of the 

pump. The separator connects to the suction line. Wastewater enters the separator, which uses a 

sedimentation technology to remove particles from the wastewater. The solid debris collects in 

the separator while the treated wastewater flows out of the separator to the vacuum pump. The 

unit also uses a 6 volt pump, which removes residual water from the sedimentation chamber once 

per night. 

On a day to day basis, what needs to be done to efficiently operate and maintain these systems? 

Who typically performs maintenance? The dentist or a third party?

Dentists need to change their separator unit every 12 months. After 10 months, DRNA 

sends a new canister to the facility requesting that the dentist change the canister within 2 months 

of receipt. The dentist then sends the full canister back to DRNA, who transfers the canister to a 

U.S. recycling facility, where the canister is recycled and resin is burned. 

Mr. Sussman stated that 100 percent of DRNA’s customers recycle their canisters at the 

12-month frequency. Because DRNA is providing compliance as a service, and because most of 

DRNA’s customers are located in regulated areas, DRNA has developed mechanisms for 

ensuring that customers recycle canisters on time. DRNA will send reminder post cards and 

conduct follow-up phone calls to remind dentists when it is time to change their canister. To 

demonstrate compliance, DRNA provides recycling documents to dentists indicating that waste 

was received and sent to a recycling facility, and the approximate weight of waste. Mr. Sussman 

stated that it is about a one month delay between when the dentist sends the full cartridge to 

when DRNA provides the recycling documentation to the dentist. In addition, Mr. Sussman 

noted that DRNA’s recycling services are not limited to amalgam separators. DRNA also 

manages chair-side and medical waste for its customers. 

DRNA also uses their recycling service to track the amount of mercury removed from 

dental wastewater. When a full canister arrives at a recycling facility, the recycling facility 

weighs the canister and determines the percent of the solids weight that is dental amalgam. Then, 

assuming 50 percent of amalgam is mercury, DRNA determines the amount of mercury collected 

per facility per year. Using their recycling tracking data, DRNA estimates that 0.5 to 1 pounds of 

mercury are discharged by each dental facility per year. 

 Although change-out services are available to dentists, Mr. Sussman stated that most 

dentists change the amalgam separator themselves. Change-out is very simple and dentists do not 

come in contact with the waste material. 
 Memorandum 

23 March 2011 

Page 4 of 5 

Regulatory Considerations 

Mr. Sussman and Dr. Frost discussed some regulatory considerations if EPA were to 

select amalgam separators as the technology basis for the Dental Amalgam Effluent Guideline. 

Scrap amalgam. Dr. Frost asserted that regulations need to clearly distinguish between 

amalgam separators and scrap amalgam disposal requirements. Amalgam separators and scrap 

amalgam are two separate issues and both need to be addressed. The way that some State 

requirements are written, they promote the misnomer that simply installing an amalgam 

separator is enough to address the dental amalgam issue. However, it is equally important that 

dentists properly dispose of scrap amalgam. 

Exemptions. Dr. Frost stated that several state programs exempt denture makers and 

endodontists, claiming that they do not remove amalgam. According to Dr. Frost, dentists in 

these practices do remove amalgam and should not be exempted. Oral surgeons and 

periodontists likely do not need to install amalgam separators, but should follow scrap amalgam 

BMPs. Dr. Frost stated that orthodontists can likely be exempted from both amalgam separator 

and scrap amalgam requirements. 
Attachment 1 

Table A-1. List of Meeting Participants

Name Affiliation Phone Email 

Alfred Frost DRNA 716-207-9081 afrost@drna.com 

Marc Sussman DRNA 800-360-1001 mmsussman@drna.com 

Chrystal Beasley US EPA 202-564-0904 beasley.chrystal@epa.gov 

Leslie Darman US EPA 202-564-5452 darman.leslie@epa.gov 

Erik Helm US EPA 202-566-1049 helm.erik@epa.gov 

Damon Highsmith US EPA 202-566-2504 highsmith.damon@epa.gov 

Samantha Lewis US EPA 202-566-1058 lewis.samantha@epa.gov 

Jan Matuszko US EPA 202-566-1035 matuszko.jan@epa.gov 

Jan Pickrel US EPA 202-564-7904 pickrel.jan@epa.gov 

Meghan Camp ERG 703-633-1684 meghan.camp@erg.com