Promoting Voluntary Efforts

to Reduce Dental Mercury Releases

to Wastewater
Mark McMillan
Colorado 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/me
rcuryhom.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 Prevention
Phase I Summary Report, Tetra Tech EMI
Inc., February 2004.
Phase 1: Dental Survey/
Data Collection

 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 Amalgam

Used in Your Practice?
(59 Pueblo dentists surveyed)
Number Percent of
Description Responses 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%
Phase 1: Dental Survey Results

What Mercury Recovery Equipment is

Used in Your Practice?
(59 Pueblo dentists surveyed)
Number Percent Equipment
Description Responses Responses Efficiency

Chair-side trap 27 66% 81%

with secondary
filter

Chair-side trap 13 32% 68%

alone

Hg amalgam 1 2% >96%
separator
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)
Phase 1: Dental Survey/
Data Collection
 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
Phase 1: Dental Survey Results
How is Mercury–Containing Waste
Disposed in Your Practice?
(59 Pueblo dentists surveyed)
Item Disposed Medical Recycled Trash Other
Waste
Scrap amalgam 40% 46% 14% 0%

Empty amalgam 42% 11% 39% 8%

capsules
Hg-containing 85% 7.5% 7.5% 0%
extracted teeth
Screens 52% 9% 33% 6%
Traps 64% 12% 18% 6%
Filters 66% 10% 17% 7%
Phase 1: Dental Survey Results
Under What Circumstances Would You
Install an Amalgam Separator?
(59 Pueblo dentists surveyed)
Number Percent of
Circumstance Responses Responses
Required by Law 28 46%
Encouraging Statement 14 23%
from ADA
Cost below $500 10 17%
No Cost 4 7%
Other 4 7%
Phase 1: Dental Survey Results
How Informed Do You Feel Regarding Hg
BMPs and BATs?
(59 Pueblo dentists surveyed)
Number Percent of
How Informed? Responses Responses
Highly informed 9 20%

Moderately informed 25 56%

Not well informed 2 4%

Want more information 8 18%

Phase 1: Dental Survey Results
What Type of Assistance
Would Be Most Helpful?
(59 Pueblo dentists surveyed)
Number Percent of
Type of Assistance Responses Responses
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%
Phase 1: Dental Survey Results

What Form of Recognition (If Any)

Would Be Favorable to You?
(59 Pueblo dentists surveyed)
Number Percent of
Form of Recognition Responses Responses
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 Program
mark.mcmillan@state.co.us, 303-692-3140
 Rick Koplitz
Water Quality Control Division, CDPHE
rick.koplitz@state.co.us ,303-692-3618
 Paul Cozetta
Water Quality Control, City of Pueblo pcozzetta@pueblo.us, 729-
544-3453