Promoting Voluntary Efforts to Reduce Dental Mercury Releases to Wastewater Mark McMillan Colorado Department of Public Health and Environment October

Promoting Voluntary Effortsto Reduce Dental Mercury Releases

to Wastewater

Mark McMillanColorado Department of Public Health and Environment

October 29, 2004

Objectives

Why this project, this place?

Project phases

Applying project results statewide

Why this project, this place? March 2002 - Enforcement action against CF&I

Steel (dba Rocky Mountain Steel Mills)

$1,800,000 penalty largely applied to Pueblo-based Supplemental Environmental Projects (SEPs): $500,000: Community-Based Projects

$500,000: Alternative Energy Projects

$500,000: Mercury Removal Projects

($300,000: Civil Penalty)

Why this project, this place?

Mercury Removal Projects: $400,000 – Mercury Switch Removal Project

http://www.cdphe.state.co.us/hm/mercury/mercuryhom.asp

$100,000 – Other Pueblo-Based Mercury Pollution Prevention Projects

Why this project, this place? Interest and support from CDPHE Water

Quality Control Division Hg in surface water can bioaccumulate in fish

tissue, posing risk to wildlife and humans that eat contaminated fish

41 states, including Colorado, have issued fish-advisories due to Hg contamination

POTWs may face increasing challenges meeting new, lowered discharge limits for Hg (due to new EPA standard test method)

Why this project, this place? Dentists are a known source of Hg discharges to

wastewater in Colorado An Evaluation of the Source Impacts and Control of Mercury.

Al Garcia, Littleton-Englewood Wastewater Treatment Plant, 2002.

Dental Hg releases to wastewater can be minimized through best management practices

Pueblo-based pilot project results may be transferable throughout the state

Project funding: $50,000

Project Phases

Phase 1: Dental Survey/Data Collection

Phase 2: Focused Outreach Effort

Phase 3: Measurement of Project Value and Success

Phase 1: Dental Survey/ Data Collection

Survey Purpose: To assess the use of BMP and BAT among Pueblo dentists, and to identify areas for outreach and improvement

Survey results are summarized in:Dental Mercury Pollution PreventionPhase I Summary Report, Tetra Tech EMI Inc., February 2004.


December 2003: Survey mailed to 59 dentists at 51 practices in Pueblo that either use or remove mercury-containing amalgam

Survey Response Rate:

41 out of 59 dentists responded (69%)

40 out of 51 practices responded (78%)

Phase 1: Dental Survey Results

How is Mercury–Containing AmalgamUsed in Your Practice?(59 Pueblo dentists surveyed)

DescriptionNumber

ResponsesPercent of Responses

Pre-capsulated Hg amalgam mixed with water for each new filling 22 52%

Hg is not used in new fillings, but Hg-containing fillings are removed 16 38%

Elemental Hg mixed w/ other constituents for each new filling 4 10%


What Mercury Recovery Equipment is Used in Your Practice?(59 Pueblo dentists surveyed)

DescriptionNumber

ResponsesPercent

ResponsesEquipment Efficiency

Chair-side trap with secondary filter

27 66% 81%

Chair-side trap alone

13 32% 68%

Hg amalgam separator

1 2% >96%

Mercury Amalgam Separators (The Hg5 Mercury Amalgam Separator System by SolmeteX Inc)

Typically designed for in-line installation between the chair-side water drain and vacuum pump.

Removes particles through physical and chemical processes, including: sedimentation, centrifugation, filtration, and ion exchange.

Must be at least 96% efficient to be ISO certified.

Required by law in Maine. Under consideration in seven other states.

Typical cost: $500 - $7,500(Ref. Journal of ADA)


American Dental Association:

“Best Management Practices for Amalgam Waste,” February 2003:

“Amalgam should not be disposed of in the garbage, infectious waste ‘red bag,’ or sharps container…. because some communities incinerate municipal garbage, medical waste, and sludge from wastewater treatment plants.”

ADA strongly recommends recycling as a primary best management practice


How is Mercury–Containing WasteDisposed in Your Practice?

(59 Pueblo dentists surveyed)

Item Disposed Medical Waste

Recycled Trash Other

Scrap amalgam 40% 46% 14% 0%

Empty amalgam capsules

42% 11% 39% 8%

Hg-containing extracted teeth

85% 7.5% 7.5% 0%

Screens 52% 9% 33% 6%

Traps 64% 12% 18% 6%

Filters 66% 10% 17% 7%


Under What Circumstances Would You Install an Amalgam Separator?


CircumstanceNumber


Required by Law 28 46%

Encouraging Statement from ADA

14 23%

Cost below $500 10 17%

No Cost 4 7%

Other 4 7%


How Informed Do You Feel Regarding Hg BMPs and BATs?


How Informed?Number


Highly informed 9 20%

Moderately informed 25 56%

Not well informed 2 4%

Want more information 8 18%


What Type of AssistanceWould Be Most Helpful?


Type of AssistanceNumber


Outreach Material 15 27%

Financial Assistance 10 18%

Workshop 8 15%

Implementation Assistance 8 15%

Training 6 11%

Other 5 9%

Trial or Money Back Guar. 3 5%


What Form of Recognition (If Any) Would Be Favorable to You?


Form of RecognitionNumber


Placard/Certification 10 24%

Newspaper 7 17%

Other 2 5%

Phase 2: Focused Outreach

Dental Hg Fact Sheet

Panel Seminar

Increased Involvement by the Colorado Dental Association (CDA)

Phase 2: Dental Hg Fact Sheet

Regulatory Outlook for Pueblo Dentists

Mercury Amalgam Separators

Vendors, Operation/Maintenance, Cost

Mercury Recycling

Recyclers, Materials, Methods, Cost

BMP Scorecard

Phase 2: Panel Seminar

May 18, 2004 at Pueblo City-County Library

Agenda: Welcome and Introduction by CDA

Regulatory Outlook for Pueblo Dentists

Mercury Amalgam Separators

• Vendors, types of separators, installation considerations, operation/maintenance

Mercury Recycling

• Vendors, types of recyclables, how to implement a recycling program

Breakout Session

Phase 3: Measurement of Project Value and Success

Follow-up Survey to Pueblo Dentists – May 2004

Final Summary Report - August 2004 Summary of Project Results: BMPs/BATs implemented, Hg releases

prevented, life cycle of Hg captured

Lessons Learned: Barriers to amalgam separator implementation

Recommendations for project improvement

Recommendations for statewide implementation

Project Follow-up – 2005

Overall Conclusions From Dental P2 Effort Surveys Useful for Gauging Interest,

Gathering Information Dentists Thought Fact Sheet, BMP

Insert, Meetings Worthwhile Voluntary Programs May Limit Need

for Regulations Voluntary Programs Allow

Participants to Customize Their Role Efforts Transferable

Applying Project Results Statewide

Pueblo pilot project is a first-step in providing compliance assistance to Colorado POTWs charged with meeting new, lowered discharge permit limits for Hg.

Outreach materials, including dental fact-sheet, vendor information, and panel seminar materials, will be made transferable through out the state.

Outreach materials and ongoing summary reports available at: http://www.cdphe.state.co.us/hm/mercury/dental.asp

Comments/Questions/Ideas?

Contact: Mark McMillan

CDPHE Mercury [email protected], 303-692-3140

Rick KoplitzWater Quality Control Division, CDPHE [email protected] ,303-692-3618

Paul Cozetta Water Quality Control, City of Pueblo [email protected], 729-544-3453

Documents

Promoting Voluntary Efforts to Reduce Dental Mercury Releases to Wastewater Mark McMillan Colorado Department of Public Health and Environment October