CHICAGO — The American Dental Association (ADA) believes the Environmental Protection Agency’s (EPA) new federal regulation represents a fair and reasonable approach to the management of dental amalgam waste. The rule, released Dec. 15, requires dental practices nationwide to install devices, called separators, to capture dental amalgam waste preventing its release to sewer systems. The rule includes reasonable exemptions, a phase-in period and considerations for dental practices that have already installed the devices.
The ADA shares the EPA’s goal of ensuring that dental amalgam waste is captured so that it may be recycled. The ADA originally commented on the draft regulation in February 2015. ADA representatives also met with the EPA and shared views and data as the process evolved. We commend the EPA for its consideration of the ADA’s comments.
We believe this new rule—which is a federal standard—is preferable to a patchwork of rules and regulations across various states and localities.
Dental amalgam is a safe, affordable and durable filling material comprised of a mixture of metals, including silver, copper, tin and mercury. Although less than one percent of mercury released to the environment from man-made sources comes from dentistry, the ADA has long recognized the importance of dentists being good stewards of the environment by capturing and recycling dental amalgam.
In 2002, long prior to federal regulation, the ADA published a set of voluntary guidelines for dentists on the capture and recycling dental amalgam. In 2007, the ADA added to its guidelines the use of amalgam separators that comply with the International Organization for Standardization’s (ISO) Standard 11143. The ADA is pleased to see that a number of provisions from the ADA guidelines are part of the new regulation.
The ADA is in the process of reviewing the rule and background statement in detail, which is more than 90 pages in length, in order to develop practical resources which will be posted on ADA.org/RecycleAmalgam to aid member dentists with questions they may have regarding compliance. In addition, ADA’s Business Resources has partnered with HealthFirst, a vendor that offers ADA member dentists special pricing on an amalgam separator device that will meet the federal regulatory requirements along with recycling services.