Joint Ventures:

Business & Government Reduce Mercury

through Innovative Programs:

Dentists (amalgam recycling) and Vehicle Manufacturers (switches)

Switches and Relays - 57129%

Lamps - 593%

Thermometers - 412%

Dental Amalgam - 108855%

Thermostats -20911%

Source: EPA 2004 International Mercury Market Study and the Role and Impact of US Environmental Policy.

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 10-12 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 Amalgam Separator TechnologiesTechnologies

• Screening• Filtration• Settle & Centrifuge• Ion Exchange/capture

NE-ECP Emission Reductions by Sector

C. Mark Smith PhD, MS. 2003.

84%

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

10000

MSWCs MWI chloro utilities

po

un

ds

1998

200384%

98%

93%

10%

Phase 1: Initial Voluntary Program - 2001

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 (2003-2005)

Env Results Program approach (outreach,self-certification,audit, measure results)

On-line self certification: 4 page formCertified 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 1st year of early compliance program (exceeding 50% target)

• 83% by end of 2nd year (exceeding 75% target)

• Regulatory program went into effect 3rd year for remaining 17% - compliance audits/enforcement underway

• Mercury levels in sludge down significantly

Results

Yearly Average Mercury levels in MWRA Sludge

0

1

2

3

4

5

02 03 04 05 06

Year

Pa

rts

pe

r m

illio

n (

pp

m)

Pre- MA dental initiative 2004: MA dental initiative

startedMA 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