A M E R I C A N   D E N T A L   A S S O C I A T I O N

Georgia Dental Association

Central  District  Dental Society


 Amalgam BMP





 

From: Holliday Dental [mailto:teeth@mindspring.com]
Sent: Monday, May 19, 2008 1:21 PM
To: connie@msdental.org
Cc: Mark Ritz
Subject: BMP for amalgam

 

http://www.msdental.org
Executive Director - Connie F. Lane

Dear Ms Lane,

I am a member of the Georgia Dental Association. 

I have been asked by Dr Mark Ritz to work on BMP (best management practices) for amalgam waste in Georgia.  He suggested that I contact you, because we understand that MSDental has an active program. 

Do you have any webpages or documents about your program that you can email to us?

Thank-you,
- Lindsay Holliday, DMD.




http://www.msdental.org/cms/images/stories/Amalgam%20BMPs%202008.pdf

From: "Tamra Shepherd" <office@msdental.org>
To: "'Holliday Dental'" <teeth@mindspring.com>
Subject: RE: BMP for amalgam
7-16-08

Amalgam Waste - ADA Best Management Practices  
Dental Amalgam Waste 
   Dental amalgam waste can be recycled to help prevent the release of mercury to the environment.  Following the simple suggestions outlined in this document will help protect the environment.
   Concern about the effects of mercury in the environment has increased over the years.  Mercury in the environment is bioaccumulative, which means that it can build up in fish and cause health problems in humans and other animals that eat fish.  Many state health professionals recommend limiting fish consumption, especially for children and pregnant women.

Mercury is a naturally occurring metal; however, about half of the mercury released to the environment comes from human activity.  Of that amount, 53% is emitted from combustion of fuels for energy production and 34% is from the combustion of waste.  Sources associated with manufacturers and consumers make up the remaining 13%, with dentistry contributing less than one%. 

   Some mercury released into the air eventually collects in the waterways, where it enters the food chain.  As a precautionary measure, U.S. regulators typically assume that all or most of the mercury released into the air or surface water may accumulate in fish.  As of 2000, the U.S. EPA lists more than 43,971 miles (covering 3,426,244 acres) of rivers and streams in the U.S. as “impaired” because of the presence of mercury.

   Although mercury in the form of dental amalgam is very stable, amalgam should not be disposed of in the garbage, infectious waste “red bag,” or sharps container.  Amalgam also should  not be rinsed down the drain.  These cautions are important because some communities incinerate municipal garbage, medical waste, and sludge from wastewater treatment plants.  If amalgam waste ends up in one of these incinerated waste streams, the mercury can be released to the environment due to the extremely high temperatures used in the incineration process.  Increasingly, local communities are enacting restrictions on the incineration of wastes containing mercury. 

   The good news is that amalgam waste, kept separate from other waste, can be safely recycled.  The mercury can be recovered from amalgam wastes through a distillation process and reused in new products.  The ADA strongly recommends recycling as a best management practice for dental offices.
The following information demonstrates how to manage and recycle dental amalgam waste to help protect the environment.


Types of Amalgam Wastes

·         Non-contact amalgam (scrap) is excess mix leftover at the end of a dental procedure.  Many recyclers will buy this clean scrap.
·         Contact amalgam is amalgam that has been in contact with the patient.  Examples are extracted teeth with amalgam restorations, carving scrap collected at chair side, and amalgam captured by chair side traps, filters, or screens.
·         Chair side traps capture amalgam waste during amalgam placement or removal procedures (traps from dental units dedicated strictly to hygiene may be placed in the regular garbage).
·         Vacuum pump filters or traps contain amalgam sludge and water.  Some recyclers will accept whole filters, while others will require special handling of this material.
·         Amalgam sludge is the mixture of liquid and solid material collected within vacuum pump filters or other amalgam capture devices.
·         Empty amalgam capsules are the individually dosed containers left over after mixing precapsulated dental amalgam. 

   The ADA recommends against the use of bulk elemental mercury, also referred to as liquid or raw mercury, for use in the dental office.  Since 1984, the ADA has recommended use of precapsulated amalgam alloy.

   If you still have bulk elemental mercury in the office, you should recycle it.  Check with a licensed recycler to determine whether they will accept bulk mercury.  Do not pour bulk elemental mercury waste in the garbage, red bag or down the drain. You also should check with your state regulatory agency and municipality to find out if a bulk mercury collection program is available.  Such bulk mercury collection programs provide an easy way to dispose of bulk mercury.


Steps for Recycling Amalgam Waste

1.       Amalgam waste may be mixed with body fluids, such as saliva, or other potentially infectious material, so use personal protective equipment such as utility gloves, masks, and protective eyewear when handling it.

2.       Contact an amalgam waste recycler about any special requirements that may exist in your area for collecting, storing and transporting amalgam waste.
If you need to find a recycler, check with your city, county or local waste authority to see whether they have an amalgam waste recycling program.

3.       Store amalgam waste in a covered plastic container labeled “Amalgam for Recycling” or as directed by your recycler.
   Consider keeping different types (e.g., contact and non-contact) of amalgam wastes in separate container—talk to your recycler about any advantages in doing so.


Questions to Ask Your Amalgam Waste Recycler

Below is a list of questions you may want to ask your amalgam waste recycler.  Note that not all recycling companies accept every type of amalgam waste, and the services offered by recyclers vary widely.  The ADA recommends that you contact a recycler before recovering amalgam and ask about any specific handling instructions the recycler may have. Importantly, select a reputable company that complies with applicable federal and state law and provides adequate indemnification for its acts and omissions.

Ask Your Recycler …

·     What kind of amalgam waste do you accept?
·     Do your services include pick up of amalgam waste from dental offices? If not, can amalgam waste be shipped to you?
·     Do you provide packaging for storage, pick up or shipping of amalgam waste?
·     If packaging is not provided, how should the waste be packaged?
·     What types of waste can be packaged together?
·     Do you accept whole filters from the vacuum pump for recycling?
·     Is disinfection required for amalgam waste?
·     How much do your services cost? 
·     Do you pay for clean non-contact amalgam (scrap)?
·     Do you accept extracted teeth with amalgam restorations?
·     Does your company have an EPA or applicable state license?
·     Does the company use the proper forms required by the EPA and state agencies?


Reference Information from the Mississippi Department of Environmental Quality  
(I will try to send this reference page in a separate email.)

Dr. Holliday, I hope some of this information can be of use to your research.

Regards,
Tamra Shepherd

Communications Director

 

http://www.msdental.org/ 

The information in this email is confidential and maybe legally privileged. It is intended solely for the addressee. Access to this email by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or any action taken or omitted to be taken in reliance on it, is prohibited and may be unlawful.

 


From: Holliday Dental [mailto:teeth@mindspring.com]
Sent: Wednesday, July 16, 2008 3:31 PM
To: office@msdental.org
Subject: BMP for amalgam

 

Tamra,
Please email me any info that you can.
Thanks,
- Lindsay Holliday, DMD


 








 
From: "Mark Ritz" <msritz@alltel.net>
To: <teeth@mindspring.com>
Cc: "'Martha Phillips'" <phillips@gadental.org>,
        "'Nelda Greene'" <greene@gadental.org>
Subject: RE: Yesterday's Congressional Hearing on Amalgam/Wastewater
Date: Tue, 15 Jul 2008 09:43

Hi Lindsay!

You may find the below article interesting.

Have you had a chance to research the history of BMP issues in other areas
of the country? (FYI, I have attached the contact information we discussed
in May).

Mark

 

From: Martha Phillips [mailto:phillips@gadental.org]
Sent: Monday, July 14, 2008 2:09 PM
To: Brian Hall (Brian Hall); hbyron@bellsouth.net; rdrdds@gmail.com; Donna
Moses (Donna Moses); Dr. Jack Bickford; Ed Green; griff217@yahoo.com;
hcookone@aol.com; harmolar@alltel.net; Jimmy Cline; Jimmy Talbot (Jimmy
Talbot); Mark Ritz (Mark Ritz); Mike Rogers (Mike Rogers); Nelson Conger;
weinmandmd@aol.com; Robert B. Moss, Jr.; tyivey@bellsouth.net; Andy Allgood
(Andy Allgood); Hank Goble; hgs0409@aol.com; jfhdds@windstream.net; Ron
Smiley; Ty Ivey; bgreenway@mindspring.com; drcwolff@bellsouth.net; Doug
Torbush; drjoed@etcmail.com; Jim Hall; jaybo2th@aol.com; percydds@yahoo.com;
Marie Schweinebraten; Marshall Mann; Mike Vernon (Mike Vernon);
ptragerdds@bellsouth.net; Timothy Fussell; Tom Broderick;
fieldortho@gmail.com
Subject: FW: Yesterday's Congressional Hearing on Amalgam/Wastewater

 

Please see the following information provided by the ADA on recent
Congressional Hearings on Amalgam and wastewater issues.

 

Martha S. Phillips, Executive Director

Georgia Dental Association

7000 Peachtree Dunwoody Road NW, Bldg 17, Suite 200, Atlanta, GA 30328

phillips@gadental.org


 

 

This message originates from the Georgia Dental Association.  It contains
information which may be confidential or privileged and is intended only for
the individual or entity named above.  It is prohibited for anyone else to
disclose, copy, distribute, or use the contents of this message.  All
personal messages are the express views of the sender, which are not to be
attributed to the Georgia Dental Association, and may not be copied or
distributed without this disclaimer.  If you received this message in error,
please notify me immediately at phillips@gadental.org   (404) 636-7553.

 

Please find below a recap of yesterday's hearing on amalgam and the
environment.

ADA witness William Walsh (our outside legal counsel on amalgam wastewater
issues) faced a long series of hostile questions yesterday during a hearing
titled "Assessing State and Local Regulations to Reduce Dental Mercury
Emission," held by the House Committee on Oversight and Government Reform's
Subcommittee on Domestic Policy.  Mr. Walsh was very effective in staying on
point that state and local authorities ought to be free to choose voluntary
separator programs over mandates.

As is common in these hearings, the few House members present branched off
into amalgam safety as well. Representatives  Dennis Kucinich (D-OH), Dan
Burton (R-IN) and Diane Watson (D-CA) were the only members present during
the hearing. Attendance in the gallery was also less than for past hearings.
There were several individuals seated at the press table, none of whom who
stayed for the entire hearing, and we have not received any press inquiries
as of this time. One reporter present was from Associated Press. We provided
her with our statement and she wrote a story which is reprinted below.

Mr. Walsh was part of the first panel of witnesses before the Subcommittee.
Also testifying were Michael Bender (an anti-mercury activist), Dr. Richard
Fisher (a "mercury-free" dentist and former president of the IAOMT, an
anti-amalgam group), and Curt McCormick, a former EPA official upset that
his efforts to mandate separators throughout EPA Region 8 were thwarted by
ADA's efforts. Clearly, the decks were stacked. Virtually all of the
questioning of the witnesses was directed at Mr. Walsh. The Representatives
either did not understand or did not care that dentistry's contribution of
mercury to lakes and streams represent less than 1% of the total. It was
enough, according to them, that mercury is toxic and dentistry contributes a
large proportion of the mercury in the sewers.

Mr. McCormick testified at length about his efforts to mandate separators
through a "guidance" document in EPA Region 8. His written testimony
suggested that ADA's efforts to defeat his efforts may have been improper.
However, in his oral statement he emphasized that ADA had done nothing
improper but was "surprisingly" effective in lobbying EPA headquarters.
Despite this focus of his testimony, the Subcommittee did not invite EPA to
testify and, in fact, EPA headquarters was unaware of the hearing until we
informed them of it. The subcommittee also failed to invite the National
Association of Clean Water Agencies to testify, despite their obvious
interest in the subject matter.

All three representatives insisted that voluntary programs do not
work--dentists will not install separators unless forced to do so--and some
form of mandate should be used. The Chairman also chastised the ADA saying
that his observation is that the ADA is holding onto voluntary standards
"for dear life" when this was an issue about neurotoxins. He even questioned
whether the ADA had taken its position based on product liability or some
sort of class action suit. It is quite possible that one or more of them
will introduce legislation calling for mandatory separators nationwide.

 In any case, Chairman Kucinich promised that the subcommittee would
continue its work on this topic.
 The second panel included three witnesses who work for public water
programs representing areas that had gone from attempting voluntary programs
for dental separators to mandatory and a manufacturer of separators.
Continuing the discussion of whether POTWs could prevent dental mercury in
sludge from going into surface water, Kucinich asked a witness what the cost
would be to accomplish that. She seemed confused by the question but then
answered it would take tens of millions of dollars - even if the equipment
was available. Without being asked, Dr. Marc Smith, from the Massachusetts
Department of Environmental Protection, stated that he disagreed with the
ADA's assertion that a mandatory standard would create a burdensome
regulation. he stated that it has been easy for them in their state because
they check on dentists electronically.

 In conclusion, Rep. Burton said to all panelists that he deduced from their
testimony that the ADA lawyer is not correct in stating that a voluntary
program would work. At first, no one supported him, then Dr. Smith stated,
"There's no evidence of that [i.e. to support the ADA position] ." In short,
the hearing was as hostile to our interests as is possible, but Mr. Walsh
ably represented our views on the science, the law and public policy.

AP Story:
Dental industry gets an earful on mercury
The Associated Press July 8, 2009
By Libby Quaid
WASHINGTON (AP) - People trust dentists with their health. Some members of
Congress are more skeptical.
The dental industry, asked to testify Tuesday about pollution from mercury
in tooth fillings, found itself under attack from lawmakers who blame
mercury for everything from autism in children to skin discoloration.

The hearing was about whether dentists should be required to install
"separator" equipment to keep pieces of fillings from getting into public
wastewater. Currently, dentists in nine states are required to use
separators.

The American Dental Association, before its spokesman testified, faced
deeply personal diatribes from Reps. Dan Burton, R-Ind., and Diane E.
Watson, D-Calif.

Burton began by saying he'd had a cap replaced, and a silver filling
removed, over the weekend, and that he worried as he swished the water in
his dentist's office about where his filling would go.

Then Burton talked about his grandson, saying the child became autistic not
long after receiving nine vaccination shots, seven of them containing
mercury. While such theories have been rejected in mainstream medicine,
Burton has held several hearings on it in the past. Mercury has not been in
childhood vaccines since 2001.

"Mercury should not be ingested into the human body in any way," he said.
Watson had her own issues. She blamed mercury fillings she got as a
9-year-old for allergies, headaches, darker and splotchy skin and trouble
remembering people's names. She talked to researchers who thought she had
mercury poisoning.

"I had to go to Mexico - I asked my own dentist about it, and he stuffed
something in my mouth and wouldn't even discuss it," Watson said.

Mercury makes up as much as 54% of silver fillings, also called dental
amalgam.
Last month, the government warned for the first time that silver dental
fillings and the mercury they contain may pose a safety concern for pregnant
women and young children. The Food and Drug Administration posted the
precaution on its website to settle a lawsuit.

The ADA spokesman, William J. Walsh, seemed taken aback by the focus on
mercury poisoning. He said his profession already acknowledges that dental
fillings are the biggest single contributor to mercury in wastewater.

But his organization opposes a mandatory requirement for separators, which
can cost anywhere from $750 to nearly $3,000 to install, according to
Burton. Walsh said dentists have worked hard to keep filling pieces from
getting into wastewater and today manage to keep about 80% from leaving
their offices.

"Dentists drink and fish and swim in the same waters as everyone else in
their communities," Walsh said. "They bring to these efforts the same
commitment they bring to providing the best possible oral health care to the
American people."

Polling indicates that people trust dentists to protect their health. A 2006
Gallup poll said people rated dentists as the fifth most trustworthy
professions, after nurses, pharmacists, veterinarians and medical doctors
and well ahead of clergy, journalists, business executives, lawyers, and
politicians.

++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++
+++++++++
BNA Daily Environment Reporter
No. 131
Wednesday, July 9, 2008 Page A-10
ISSN 1521-9402
News

Water Pollution
Dentists Urged to Do More to Prevent
Mercury Pollution From Silver Fillings
More than six tons of toxic mercury used in silver dental fillings are
discharged to wastewater treatment plants in the United States every year,
and the dental industry is not doing enough to eliminate this form of
pollution to protect public health, public interest group representatives
and other witnesses told a subcommittee of the House Committee on Oversight
and Government Reform July 8.

William Walsh, counsel for the American Dental Association (ADA), countered
that dentistry contributes less than 1 percent of the total mercury found in
lakes and streams, and dentists are working to reduce the amount of mercury
pollution they generate by using encapsulated fillings and adopting other
"best management practices."

Richard Fischer, former president of the International Academy of Oral
Medicine & Toxicology, told the Domestic Policy Subcommittee that the dental
profession uses about 40 tons of mercury--a potent neurotoxin--per year to
make silver (or amalgam) fillings.

According to Fischer, 6.5 tons of mercury is discharged to wastewater
treatment plants through the process of placing and removing the fillings,
in large part because chair-side suction units only are able to trap large
particles. In addition, he said people with silver fillings flush mercury
into wastewater through their excrement.

Moreover, he said, wastewater treatment plants are not designed to process
or handle heavy metals such as mercury, which results in the pollutant
accumulating in sewage sludge.

Fischer said devices called amalgam separators can capture 95 percent to 99
percent of the mercury before it leaves dental offices. He added that states
should require dentists to use this equipment because few dentists choose to
do so voluntarily, and places where they are required have seen a 50 percent
reduction in the amount of mercury entering wastewater treatment plants.

He also said the cost of amalgam separators--from a few hundred to a few
thousand dollars--is "reasonable" compared with the cost of most other
dental equipment.

Finally, Fischer said dentists should stop using silver fillings altogether
because of health effects for patients. "To place a mixture containing 50
percent mercury--the most neurotoxic element known on earth--within inches
of a child's brain stem and assume it to be harmless is at best
counterintuitive," he said. "To release this same pollutant into the
environment is irresponsible when simple and available technology exists to
reduce that release by over 95 percent."

Voluntary Programs Not Effective
Michael Bender, director of the Mercury Policy Project, also said amalgam
separators are a "highly cost-effective" way to prevent mercury releases.
For example, he said the cost to remove mercury at a wastewater treatment
plant is $21 million per pound, compared to $1.95 per filling when using an
amalgam separator.

He also said state and local governments should require dentists to use the
equipment.
"The record clearly shows that voluntary programs are not effective at
convincing dentists to install amalgam separators," he said.

He said the ADA "appears" to have blocked initiatives to require the
equipment in California, Wyoming, Michigan, Ohio, Montana, and "likely
elsewhere."

Moreover, Bender said, the dental industry is not curtailing its use of
mercury. He said U.S. dentists were still using 30 tons of the element
annually in 2004, the same amount as was used in 2001.

"Contrary to what we have heard from the dental sector, their mercury
pollution will continue unabated without controls," he said.

ADA Initiatives Called Effective
But Walsh told the committee that dental amalgam is a "safe and effective
option for treating dental decay" based on the "best available science."
Moreover, he said the ADA's voluntary efforts to reduce mercury pollution
are effective and that mandatory controls are unnecessary.

"Despite the very small share of mercury in surface waters from dental
amalgam, America's dentists want to do the right thing and minimize further
their impact on the environment," he said.

According to Walsh, the most effective way to do this is for dentists
voluntarily to adopt the ADA's "best management practices."

For example, he said, dentists no longer keep bottles of liquid mercury in
their offices for mixing their own amalgam. In addition, they now use
amalgam that "encapsulates" the mercury, which "virtually eliminates" spills
in dental offices.

Walsh also said the ADA has promoted recycling of waste amalgam to prevent
mercury from entering the environment and has asked dentists to use
chair-side traps and vacuum-pump filters.

Although the ADA supports the voluntary use of amalgam separators, Walsh
said, mandatory programs are not needed because of "dentistry's record of
voluntarily meeting the highest standards of health and safety." He also
said there is "little incremental difference" in the amount of amalgam
collected and recycled using a voluntary separator program compared to a
mandatory program.

 

By Jeff Kinney

____________________________________________________________________________
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American Dental Association  1111 14th Street, NW  #1200  Washington, DC