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EPA backs Association’s voluntary waste management practices

Washington—The Environmental Protection Agency continues to support ADA's voluntary best management practices for amalgam waste, the agency said in a public notice. The ADA actively promotes BMPs with American dentists that include use of amalgam separators.

"EPA is again not identifying dental facilities for an effluent guidelines rulemaking in this notice at this time," said the Dec. 28, 2009, Federal Register notice. The EPA also reasserted its "broad discretion" for national regulation if necessary under the Clean Water Act. A national standard, if promulgated, would likely mandate amalgam separators.

ADA President Ron Tankersley commended the EPA statement. "For now, the agency has agreed not to mandate separators, but if they don't see enough progress on dentists' voluntary efforts to follow best management practices, a mandate will come back to haunt us. I urge our members to download and implement ADA's best management practices for amalgam waste. Let's show the EPA that dentists are committed to protecting the environment and that we can do this on our own," Dr. Tankersley said.

The EPA announcement reaffirmed an earlier agency decision (ADA News Today Jan. 12, 2009, ADA, EPA agreement, and June 29, ADA cites commitment to best management practices) based largely on dentistry's voluntary efforts to implement BMPs that include the use of amalgam separators. The notice also indicates the EPA will continue to focus on this area and voluntary dental office use of separators.

The Association updated its voluntary BMPs in 2007 to include the purchase and proper use of amalgam separators.

The EPA said it has contacted dental offices and other health care facilities "to learn about their unused pharmaceutical disposal practices" and will consider best practices for waste management.

The EPA said it "estimates that hospitals and long-term care facilities have the greatest amounts of unused pharmaceuticals as compared with other health care sectors (e.g. dentist, retail pharmacies)."

The Association offered written comments to EPA in November 2008 explaining that dental offices play a minor role in this issue. The Association will continue to monitor EPA actions on waste pharmaceuticals.