Pollution Prevention & Management DentalBMPs

Overview Amalgam in POTW New EPA Guidelines City of Tulsa Dental BMPs

Mercury in the Environment Mercury from amalgam is introduced through surface water discharge, land application of sludge, landfill, or incineration. Dental amalgam is 49% mercury, 35% silver.

Amalgam in POTWs Dental offices account for 50% of mercury in POTWs EPA estimates ~97 million amalgam removals each year.

Amalgam in POTWs EPA estimates that, without separators, dental practices discharge 4.4 tons of mercury to POTWs each year. The 40% of dental offices with amalgam separators discharge approximately 63 pounds of mercury to POTWs each year.

Amalgam in POTWs CWA regulations, Standards for Use and Disposal of Sewerage Sludge.

New EPA Guidelines In 2008, EPA signed a MOU with ADA to establish a Voluntary Dental Amalgam Discharge Reduction Program. New requirements based on mandatory the use of amalgam separators and BMPs consistent with ADA recommendations.

New EPA Guidelines Currently, 12 states, including Louisiana, have implemented mandatory mercury minimization programs. EPA estimates that 40% of dental offices, nation wide, have amalgam separators installed.

New EPA Guidelines To obtain ISO certification, a separator must achieve 95% or greater removal of total mercury. With existing chair and vacuum filters, total mercury removal rates exceed 99%.

New EPA Guidelines EPA considers amalgam separators as a low- cost technology and estimates an average annual cost of $700 per office.

New EPA Guidelines Dentists that certify that they do not install or remove amalgam will be exempt from the proposed rule.

New EPA Guidelines If a facility has an installed separator prior to this proposed rule, and that separator removes slightly less than required, they may continue to use that separator for a period no longer than 10 years.

New EPA Guidelines General Pretreatment Regulations require POTWs to develop Pretreatment Programs to control Industrial Discharges into their sewage collection system.

New EPA Guidelines 40 CFR § Pretreatment Standards for Existing Sources (PSES) (b) (1), scrap amalgam from chair-side traps, screens, vacuum pump filters, dental tools, or collection devises may not be flushed down the drain.

New EPA Guidelines 40 CFR § Pretreatment Standards for Existing Sources (PSES) (c) (4), is inspected at least once per month (c) (6), is regularly maintained by replacing the amalgam retaining cartridge whenever the collection of retained solids reaches manufacturer’s stated design capacity or annually, whichever comes first.

New EPA Guidelines 40 CFR § Discharge monitoring, reporting, and recordkeeping requirements (a) (1), Baseline report must be submitted within 180 days of the effective date of this rule.

New EPA Guidelines 40 CFR § Discharge monitoring, reporting, and recordkeeping requirements (a) (1) (i), Facility name, address, and contact information.

New EPA Guidelines 40 CFR § Discharge monitoring, reporting, and recordkeeping requirements (a) (1) (ii), Description of the operation (a) (2) (ii) (A), Total number of chairs (a) (2) (ii) (B), Number of chairs at which dental amalgam may be present in the resulting wastewater (a) (2) (ii) (C), A description of any existing amalgam separators to include, make, model, and manufacturer recommended frequency of container change.

New EPA Guidelines 40 CFR § Discharge monitoring, reporting, and recordkeeping requirements (a) (2), 90-day compliance report. A final compliance report must be submitted within 90 days after the final compliance date of this rule.

New EPA Guidelines 40 CFR § Discharge monitoring, reporting, and recordkeeping requirements (a) (3), Periodic monitoring report. A periodic report of ongoing compliance must be submitted annually.

New EPA Guidelines 40 CFR § Discharge monitoring, reporting, and recordkeeping requirements (c), Dental dischargers must maintain on site and available for inspection (in either physical or electronic form) the following records for a period of three years from the date they are created:

New EPA Guidelines 40 CFR § Discharge monitoring, reporting, and recordkeeping requirements (c) (1), Baseline report (c) (2), 90-day compliance report (c) (3), Periodic monitoring report (c) (4), Documentation of each visual inspection to ensure that the device is not in bypass mode.

New EPA Guidelines 40 CFR § Discharge monitoring, reporting, and recordkeeping requirements (c) (5), Documentation specifying the date of amalgam retaining cartridge replacement (c) (6), Records indicating the date of amalgam retaining cartridges are sent off site for proper disposal and the shipping address of the facility to which cartridges are sent.

CoT Dental Amalgam Survey

Amalgam Usage Extracted teeth with amalgam filings is amalgam usage.

Amalgam Disposal DO NOT dispose of extracted teeth that contain amalgam restoratives in biohazard containers, red bags, or municipal waste.

Chair-side traps and vacuum pump filters remove approximately 78% of amalgam particles.

Amalgam Collection DO NOT place filters or contents of filters in office trash. Filters or contents from reusable filters should be placed in a container marked, “Contact Amalgam Waste for Recycling”. Source: ADA: Best Management Practices for Amalgam Waste brochure, 2007

Line Cleaners Use non-bleach, non-chlorine line cleaners. This will minimize amalgam dissolution.

CoT Dental Amalgam BMPS

CoT Dental Amalgam Resources