Joint Ventures: Business & Government Reduce Mercury through Innovative Programs: Dentists (amalgam recycling) and Vehicle Manufacturers (switches)

Estimated USA Mercury Reservoirs in Products Total =1968 tons Abstracted from NRDC presentation at ECOS Mercury meeting, 2007

National Vehicle Mercury Switch Recovery Program Launched August 2006, with nine organizations Cooperative effort by auto manufacturers, steelmakers, vehicle dismantlers, vehicle shredders, environmental organizations, the Environmental Council of the States (ECOS) and US EPA Agreement driven in part by “critical mass” of states adopting laws mandating switch recovery by manufacturers and EPA threat of MACT rule application to Electric Arc Furnaces (over 100 in US) States actively promoting program

KEY BENEFITS Environmental: Goal is to recover 90% of mercury switches and reduce tons of mercury emissions annually Business: Maintains economic competitiveness: supports industries that produce, recycle and use scrap metal and replaces patchwork regulation with single, predictable national program Economic: costs far less per pound of mercury than conventional emission controls Regulatory Incentive: Alternative to MACT controls at Electric Arc Furnaces

National Vehicle Mercury Switch Recovery Program The Partners have: Developed and implemented the program in the states States with existing programs and legislation may continue their programs; all other states encouraged to join the NVMSRP rather than create their own state-specific mercury switch removal program Worked together to continuously improve the program ( core team continues to meet)

National Vehicle Mercury Switch Recovery Program Status In it’s first year, more than 635,000 switches were removed from end-of-life vehicles Those switches represent 1,400 pounds of mercury Approximately 5,900 auto recyclers have agreed to remove and recover the switches before sending vehicles to scrap recyclers Those scrap recyclers then send the clean cars to steel mills who make recycled steel

US State Programs to Reduce Mercury Pollution from Dentistry C. Mark Smith Ph.D., M.S.

Amalgam Separator Technologies Screening Filtration Settle & Centrifuge Ion Exchange/capture

NE-ECP Emission Reductions by Sector C. Mark Smith PhD, MS % 98%93% 10%

Phase 1: Initial Voluntary Program  In collaboration with Massachusetts Dental Society (MDS) Encouraged amalgam separator installation Raised awareness but relatively few separators installed Voluntary approach in other states had poor compliance MDS issues: legal authority? TCLP testing? RCRA? Cost?

Phase 2: Dental Mercury Reduction Early Compliance Program – 2003  MassDEP removed RCRA barrier (class A recycling regs)  Asserted legal authority to regulate dental amalgam under general statutory authority  Refused to do TCLP testing but offered opportunity to MDS  Addressed cost issue: multiple vendors and $600-$1,000/yr for capital, O&M  Negotiated with MDS voluntary early compliance program to achieve faster mercury reductions  Established milestones for regulatory program  (Year 1: 50%compliance; Year 2: 75%compliance)

Voluntary Compliance Program ( )  Env Results Program approach (outreach,self-certification,audit, measure results)  On-line self certification: 4 page form  Certified installation of amalgam separator and use of BMPs  Incentives for Early Participation – Permit/compliance fees waived – Up to 5 year grandfathering –Good PR

74% participation during 1 st year of early compliance program (exceeding 50% target) 83% by end of 2 nd year (exceeding 75% target) Regulatory program went into effect 3 rd year for remaining 17% - compliance audits/enforcement underway Mercury levels in sludge down significantly Results

Pre- MA dental initiative 2004: MA dental initiative started MA Dental initiative fully implemented in 2006: 40+% reduction

COMMON ELEMENTS OF SUCCESS Critical mass of state activity Willingness to negotiate, compromise and bring stakeholders to table Built-in business incentives/disincentives Measurable environmental and economic benefits and costs Lawsuits avoided, effective & low cost solutions realized