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ADA, EPA agreement promotes amalgam best management practices

Washington—The Environmental Protection Agency, the American Dental Association and a national wastewater treatment organization have signed an agreement to promote voluntary use of the ADA's best management practices for handling amalgam waste.

"The purpose of this MOU (memorandum of understanding) is to promote the use of BMPs (best management practices) adopted by the ADA by dentists, thereby increasing recycling and reducing the discharge of amalgam into POTWs (publicly owned treatment works) from dental offices that currently handle amalgam wastewater," says the document signed Dec. 29, 2008, and announced by the EPA at year's end. The full MOU document is available on ADA.org. Dr. John S. Findley signed the document as president of the American Dental Association.

"It is the intent of the signatories that the Voluntary Dental Amalgam Discharge Reduction Program will demonstrate a significant increase in the use of amalgam separators within a reasonable period of time in order to progress toward achieving the goal of this MOU," the document says.

The Association updated its voluntary BMPs in 2007 to include the purchase and proper use of amalgam separators. This information and related resources are posted at www.ada.org/goto/amalgambmp. The updated BMPs for amalgam waste also are attached to the memorandum of understanding. ADA members may request a free copy of the best management practices by calling the ADA via the toll free number, Ext.2878.

Well before EPA's assistant administrator for water, Benjamin H. Grumbles, affixed his signature to the agreement, the EPA had publicly declared support for the Association's voluntary approach even as a congressional staff called for "a mandatory program wherein dental clinics are required to install amalgam separators" (ADA News Today, Sept. 24, 2008, EPA backs voluntary approach on amalgam separators).

The three-party MOU says that "the dental community, including ADA and state and local dental associations, has taken action to reduce amalgam wastewater discharges to POTWs." The agreement cites ADA outreach and education efforts to reduce amalgam discharges and Association contributions to the development of separator standards.

"While there has been progress in reducing mercury levels in the environment from all sources, the signatories to this MOU believe that additional voluntary efforts to reduce the amount of amalgam being discharged from dental offices into POTWs are appropriate and would promote recycling and expedite such reductions," says the MOU. "A collaborative effort by EPA, ADA and NACWA (National Association of Clean Water Agencies, whose president signed) will help build awareness and the importance of prevention at the local, state, tribal, and national levels."

As an initial step under the agreement, the ADA intends to prepare a baseline report within six months estimating current levels of amalgam separator use. As an interim goal, the Association intends to establish a tracking system and report within three years on progress in increasing the percentage of participating dentists.

ADA will continue and expand programs "to raise awareness and provide training, outreach, and implementation resources to dentists and other members of the dental team, and where possible, dental students, on the benefits of following the ADA BMPs and the proper ongoing operation and maintenance of the ADA BMPs. This effort includes working with EPA and NACWA in developing seminars, continuing dental education courses and web-based compliance assessment information," the MOU declares.

The goal of the voluntary discharge reduction plan as described by the MOU is to have dental offices following the ADA best management practices, which include installation and proper maintenance of an amalgam separator and recycling of all amalgam waste collected in dental offices. But the MOU imposes no requirements on dental offices or wastewater treatment facilities beyond what existing laws and regulations require. Nor does the MOU prohibit EPA, state or tribal establishment of mandatory separator programs.

The focus of the voluntary program is on dentists who use or remove dental amalgam, says the MOU. Some states and POTWs have excluded certain dental practices from discharge reduction programs because they discharge little or no amalgam waste, such as orthodontists, periodontists, oral and maxillofacial surgeons or radiologists, or oral pathologists. The ADA supports those exemptions.

EPA, state and tribal attempts to reduce mercury discharge from dental facilities have produced a mix of mandatory and voluntary programs across the country, according to the MOU.

The EPA announcement and the agreement are posted at www.epa.gov/guide/dental .