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Reducing Mercury Pollution in the Environment
Reducing Mercury Pollution in the Environment
Presentation by :
Marc M. SussmanPresident and CEODental Recycling North America, Inc.
To the Western Attorney General's Conference
Sun Valley, Idaho August 4th, 2009
Presentation by :
Marc M. SussmanPresident and CEODental Recycling North America, Inc.
To the Western Attorney General's Conference
Sun Valley, Idaho August 4th, 2009
OverviewOverview
How does mercury make it into our waterways?
Why is it a hazard?
What is being done?
What more can & should be done?
How does mercury make it into our waterways?
Why is it a hazard?
What is being done?
What more can & should be done?
Amalgam Waste: What is It?
Amalgam Waste: What is It?
Amalgam is a mixture of materials used by the dental industry for fillings
Amalgam fillings contain a significant amount of mercury, which does not pose a health threat unless released into the environment
Amalgam is a mixture of materials used by the dental industry for fillings
Amalgam fillings contain a significant amount of mercury, which does not pose a health threat unless released into the environment
How Amalgam is Released into the Environment
How Amalgam is Released into the Environment
Amalgam waste makes its way into the environment by improper discarding of excess amalgam from mixture preparation & removed fillings
For Example...Discarding waste in the dental chair side trapsRinsing residual waste down the sinkDepositing waste in biomedical waste containersPutting amalgam waste in the trash
Amalgam waste makes its way into the environment by improper discarding of excess amalgam from mixture preparation & removed fillings
For Example...Discarding waste in the dental chair side trapsRinsing residual waste down the sinkDepositing waste in biomedical waste containersPutting amalgam waste in the trash
Implications of Improper Disposal
Implications of Improper Disposal
Sewage waste is taken to Publicly Owned Treatment Works (POTWs), where the POTW try to filter mercury out, but it is difficult to do once it has been converted to methylmercury
Impact on POTWs:Imposes extra costs on POTWsPOTW cannot eradicate all mercury content within their sludge
Sewage waste is taken to Publicly Owned Treatment Works (POTWs), where the POTW try to filter mercury out, but it is difficult to do once it has been converted to methylmercury
Impact on POTWs:Imposes extra costs on POTWsPOTW cannot eradicate all mercury content within their sludge
What Happens to Mercury Containing Waste?
What Happens to Mercury Containing Waste?
POTW Sludge Incinerated
Biohazard medical waste Incinerated
Landfill wasteEmits landfill gasesDischarges liquid via leachates that is ultimately processed by POTWs
POTW Sludge Incinerated
Biohazard medical waste Incinerated
Landfill wasteEmits landfill gasesDischarges liquid via leachates that is ultimately processed by POTWs
What Began as Waste Ends Up in Our Food
What Began as Waste Ends Up in Our Food
Waste • Air • Rain • Water • Fish • Humans
Waste from POTW sludge & biomedical waste is incinerated, which volatizes the mercury, releasing it into the atmosphere where it is then captured by rain and delivered into waterways and oceans
Landfill waste may release the mercury into the atmosphere via landfill gases, or may deliver the mercury to POTWs when the landfill produces liquid that is discharged through their leachate system
Waste • Air • Rain • Water • Fish • Humans
Waste from POTW sludge & biomedical waste is incinerated, which volatizes the mercury, releasing it into the atmosphere where it is then captured by rain and delivered into waterways and oceans
Landfill waste may release the mercury into the atmosphere via landfill gases, or may deliver the mercury to POTWs when the landfill produces liquid that is discharged through their leachate system
The ConcernThe Concern
Fish and shellfish bio-accumulate methylmercury in their systems
When sea-life is exposed to methylmercury, it is retained in its system so that its mercury content increases overtime
The levels of methylmercury in fish are typically 100,000 times more than the content in the water where they reside
Fish and shellfish bio-accumulate methylmercury in their systems
When sea-life is exposed to methylmercury, it is retained in its system so that its mercury content increases overtime
The levels of methylmercury in fish are typically 100,000 times more than the content in the water where they reside
Implications
Mercury may be consumed directly by young children when they eat seafood, or it can be passed from the mother's system to her unborn child or through breast-milk
Mercury has the ability to damage the nervous system of young children and unborn children
A Serious Health ConcernA Serious Health Concern
The Federal Drug Administration (FDA) has administered advisories concerning mercury
FDA recommends that women and children should not exceed 12 ounces of most fish and shellfish per week
Some fish (ex. albacore tuna) contain higher levels of mercury and should be limited to only 6 ounces per week
6 ounces is the equivalent to the average amount of tuna in a can
The Federal Drug Administration (FDA) has administered advisories concerning mercury
FDA recommends that women and children should not exceed 12 ounces of most fish and shellfish per week
Some fish (ex. albacore tuna) contain higher levels of mercury and should be limited to only 6 ounces per week
6 ounces is the equivalent to the average amount of tuna in a can
FDA recommends the complete elimination of shark and swordfish for pregnant women
Studies show that at least 16% of women who are pregnant or are at a stage where they may become pregnant have been exposed to excess levels of mercury in their diets
FDA recommends the complete elimination of shark and swordfish for pregnant women
Studies show that at least 16% of women who are pregnant or are at a stage where they may become pregnant have been exposed to excess levels of mercury in their diets
What Can be Done?What Can be Done?
Mercury-containing waste is hard to control once it has been released into sewage systems or other waste management systems
This can be mitigated by implementing programs and equipment that contain the waste before it leaves a facility
Mercury-containing waste is hard to control once it has been released into sewage systems or other waste management systems
This can be mitigated by implementing programs and equipment that contain the waste before it leaves a facility
The Role of the Dental Industry
The Role of the Dental Industry
Based on ADA's Best Management Practices (BMP), it has been determined that dental facilities can eliminate the release of mercury by more than 95% if they install and operate amalgam separators in conjunction with abiding by ADA's Best Management Practices for the collection and recycling of mercury-containing wastes
Based on ADA's Best Management Practices (BMP), it has been determined that dental facilities can eliminate the release of mercury by more than 95% if they install and operate amalgam separators in conjunction with abiding by ADA's Best Management Practices for the collection and recycling of mercury-containing wastes
ADA RecommendationsADA Recommendations
ADA signed a Memorandum of Understanding (MOU) with the Office of Water and the National Association of Clean Water Agencies (NACWA) to establish and monitor the effectiveness of a Voluntary Dental Amalgam Discharge Reduction Program
ADA signed a Memorandum of Understanding (MOU) with the Office of Water and the National Association of Clean Water Agencies (NACWA) to establish and monitor the effectiveness of a Voluntary Dental Amalgam Discharge Reduction Program
Mixed Results from Voluntary Participation
Mixed Results from Voluntary Participation
The voluntary program in King County of Washington State yielded only a 3% participation rate by the dental industry between 1994 and 2000
The low participation rate was in lieu of a rebate subsidy offered to install amalgam separators
Once enforcement was introduced participation rose to 80% by 2003
Results From Voluntary Programs Indicate that Legislation is Necessary
The voluntary program in King County of Washington State yielded only a 3% participation rate by the dental industry between 1994 and 2000
The low participation rate was in lieu of a rebate subsidy offered to install amalgam separators
Once enforcement was introduced participation rose to 80% by 2003
Results From Voluntary Programs Indicate that Legislation is Necessary
New Jersey - An Example for the Country
New Jersey - An Example for the CountryRational for Legislation
Mercury pollution presents high monetary costs to the public as well as high costs on quality of life
The costs of preventing mercury’s release into the environment are incurred by the tax-payer
Dental facilities are releasing mercury into the environment, therefore, dental facilities should treat the cost of proper amalgam disposal and recycling as an operation costs, rather than passing the costs on to the public
Rational for Legislation
Mercury pollution presents high monetary costs to the public as well as high costs on quality of life
The costs of preventing mercury’s release into the environment are incurred by the tax-payer
Dental facilities are releasing mercury into the environment, therefore, dental facilities should treat the cost of proper amalgam disposal and recycling as an operation costs, rather than passing the costs on to the public
New Jersey – A Case in Point
New Jersey – A Case in Point
Recently Passed Legislation
“The most Effective and Efficient way to keep mercury from dental amalgam out of the
environment is for the facilities who release it to effectively collect and recycle their
amalgam wastes in compliance with the proposed new rule”
“…treating mercury at the source is much more feasible and cost effective”
Recently Passed Legislation
“The most Effective and Efficient way to keep mercury from dental amalgam out of the
environment is for the facilities who release it to effectively collect and recycle their
amalgam wastes in compliance with the proposed new rule”
“…treating mercury at the source is much more feasible and cost effective”
Annual Cost AnalysisAnnual Cost Analysis“…treating mercury at the
source is much more feasible and cost effective”
“…the annual cost for treatment of mercury at the POTW would range from 1.28 to 1.98 billion (dollars).”
The NJ Jersey State annual cost at the POTW is at least 474 times greater than the dental facilities!
“…treating mercury at the source is much more feasible and cost effective”
“…the annual cost for treatment of mercury at the POTW would range from 1.28 to 1.98 billion (dollars).”
The NJ Jersey State annual cost at the POTW is at least 474 times greater than the dental facilities!
$0
$200,000,000
$400,000,000
$600,000,000
$800,000,000
$1,000,000,000
$1,200,000,000
$1,400,000,000
Cost
Dental Facilities
NJ State POTW
Annual Cost to Dental Facility vs. Annual Cost to Public
Annual Cost to Dental Facility vs. Annual Cost to Public
When recycled at the dental facility level, the average cost per patient is 0.54¢ to 0.84¢ Recycling at dental facility level will result in 2,550 Lbs of mercury removed and recycled
-Conversely-
Annual costs for treatment of mercury at the POTW would range from 1.28 to 1.98 billion dollars
The NJ Jersey State annual cost at the POTW is at least 474 times than the dental facilities
Cost Overview – In Perspective
Cost Overview – In Perspective
Removal of Mercury will cost the dentist 0.54¢ to 0.84¢ per patient
If a dentist sees 4 patients a day and works 4 days a week that will total between $8.64 - $13.44 per week
Resulting in annual costs for the dentist of $449 to $699
-vs.-
1.28 to 1.98 billion (dollar) in annual costs to local POTWs
Removal of Mercury will cost the dentist 0.54¢ to 0.84¢ per patient
If a dentist sees 4 patients a day and works 4 days a week that will total between $8.64 - $13.44 per week
Resulting in annual costs for the dentist of $449 to $699
-vs.-
1.28 to 1.98 billion (dollar) in annual costs to local POTWs
Regulatory ActionRegulatory Action
Examples of Legislative Measures
State level through the passage of specific legislation:New York State, New Jersey, Connecticut, Maine, Massachusetts, Vermont, New Hampshire, and Oregon have established statewide regulations
Local communities have adopted regulations in Rhode Island, Minnesota, California, Washington and Louisiana
Permits via State Environmental Protection Agency Departments
Examples of Legislative Measures
State level through the passage of specific legislation:New York State, New Jersey, Connecticut, Maine, Massachusetts, Vermont, New Hampshire, and Oregon have established statewide regulations
Local communities have adopted regulations in Rhode Island, Minnesota, California, Washington and Louisiana
Permits via State Environmental Protection Agency Departments
Regulatory Movements and The Attorney General
Regulatory Movements and The Attorney General
There is discussion in the Congress about the role of the EPA in taking a more aggressive stance towards regulating the dental industry
The Next Phase is the Enforcement What is the role of the office of Attorney General? Ensuring that these regulations are enforced
How?By establishing one standard in order for all dental offices/facilities to be treated fairly
There is discussion in the Congress about the role of the EPA in taking a more aggressive stance towards regulating the dental industry
The Next Phase is the Enforcement What is the role of the office of Attorney General? Ensuring that these regulations are enforced
How?By establishing one standard in order for all dental offices/facilities to be treated fairly
Works CitedWorks Cited Courtesy copy of this rule proposal, Environmental Protection,
Environmental Regulation, Division of Water Quality Watershed Permitting Element, Water Pollution Control, Requirements for Indirect Users – Dental Facilities, Proposed New Rules: N.J.A.C. 7:14A-21.12, Proposed Amendments: N.J.A.C. 7:14A-1.2.
Courtesy copy of this rule proposal, Environmental Protection, Environmental Regulation, Division of Water Quality Watershed Permitting Element, Water Pollution Control, Requirements for Indirect Users – Dental Facilities, Proposed New Rules: N.J.A.C. 7:14A-21.12, Proposed Amendments: N.J.A.C. 7:14A-1.2.
