ADA Press Release
ADA Testifies Before House Sub-Committee on Voluntary Efforts to Protect the Environment from Mercury
Mr. Walsh’s comments:
Testimony of William Walsh
On Behalf of the American Dental Association
Before the Subcommittee on Domestic Policy
House Committee on Oversight and Government Reform
July 8, 2008
Thank you for the opportunity to speak with you today. I am William Walsh, Pepper Hamilton LLP, outside counsel for the American Dental Association on amalgam wastewater issues. I have represented the ADA on these issues since 2001.
The ADA is the world’s largest and oldest dental association, representing more than 156,000 dentists nationwide.
The ADA has issued and continually updates as appropriate its "best management practices" for handling waste amalgam. These BMPs call for the use of standard control methods, recycling of collected amalgam, and, since last fall, the use of amalgam separators.
Even without separators, dentists capture in their offices approximately 80 percent of the waste amalgam, with almost all of the remaining 20 percent captured by water treatment plants before the wastewater is discharged to surface water. In other words, 99 percent of the amalgam is already captured prior to discharge from the POTW. Adding a separator allows the capture of that additional amalgam waste in the dental office, instead of at the wastewater treatment plant.
The ADA has devoted substantial time and resources to promoting its best management practices. For example:
- In 2001, the ADA commissioned an independent study of how much mercury might enter surface waters from amalgam wastewater discharges.
- The ADA evaluated the effectiveness and cost of amalgam separators (including contributing to the development of the International Standards Organization (ISO) standard for testing separators.
- In 2003, the ADA proposed to the EPA Office of Water to initiate a voluntary amalgam wastewater reduction program in partnership with EPA.
- The ADA proposed to EPA and participated in developing a standard for recycling amalgam waste.
- The ADA has conducted a comprehensive outreach and education program for dentists and dental societies, including:
- Numerous seminars for dentists and dental societies;
- Articles in the ADA News, the peer-reviewed Journal of the American Dental Association, and ADA Professional Product Review;
- Partnering with the EPA to produce and distribute BMP brochures and videos to 43,000 dentists in the Great Lakes region in 2005.
Several factors favor these ongoing efforts:
First, dentistry’s goals comport exactly with those of government—to minimize dentistry’s discharge of amalgam waste.
Second, dentists, as health professionals, will respond to scientific evidence and cooperative approaches. Some early efforts were not successful because of lack of understanding on both sides. But the ADA and dentistry have learned from past experience. They have calibrated their approach, and voluntary, cooperative partnerships have succeeded in subsequent efforts.
Third, according to a 1997 report to Congress by EPA, dentistry contributes less than one percent of the total mercury found in our lakes and streams—0.4 percent of the mercury in surface waters.
Fourth, mandating separators would require a costly inspection and enforcement apparatus, given that some 100,000 dental offices would need to be regulated.
Fifth, nothing precludes state or local agencies from enacting a mandatory program should voluntary efforts fail. As the testimony submitted in writing by other witnesses clearly shows, determining whether to mandate separators in dental offices is best left to local authorities.
Dentists drink and fish and swim in the same waters as everyone else in their communities and believe that ongoing efforts to encourage the use of BMPs and separators are succeeding and will continue increasingly to succeed.
In closing, dentists have steadily reduced their already minimal contribution to environmental mercury over the past decade. They bring to these efforts the same commitment they bring to providing the best possible oral health care to the American people.
About the American Dental Association
The not-for-profit ADA is the nation's largest dental association, representing 157,000 dentist members. The premier source of oral health information, the ADA has advocated for the public's health and promoted the art and science of dentistry since 1859. The ADA's state-of-the-art research facilities develop and test dental products and materials that have advanced the practice of dentistry and made the patient experience more positive. The ADA Seal of Acceptance long has been a valuable and respected guide to consumer dental care products. The monthly The Journal of the American Dental Association (JADA) is the ADA's flagship publication and the best-read scientific journal in dentistry. For more information about the ADA, visit www.ada.org. For more information on oral health, including prevention, care and treatment of dental disease, visit the ADA’s consumer website www.MouthHealthy.org.