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Reducing Dental Mercury Releasesin
New Hampshire
Paul Lockwood (603) [email protected]
2005 National Environmental Partnership SummitMay 8 – 11, 2006
(How to blend compliance
assistance with regulatory
enforcement)
Background: NH Mercury reduction efforts
Rules development process
Assistance and Rules implementation
Measurement results
Amalgam Rules Development & Implementation
inNew Hampshire
NH Mercury Reduction Strategy
4.7.1 Recommended Actions Regarding
Dental AmalgamConduct outreach to the general public and dentist’s offices…to encourage the voluntary use of alternatives to mercury-containing amalgam and encourage the proper collection and disposal of waste amalgam.
Draft legislation…with an effective date of July 1, 2003 to prohibit the use of mercury-containing amalgam.
R-27
R-28
2002 Legislation
HB 1251 – “An Act relative to the use of mercury amalgam fillings by dentists.”
Introduced June, 2002 as a ban on the use of mercury-amalgam in New Hampshire
NH Mercury Reduction Strategy
2002 Legislation
Problems and Issues:
• Environmental or Public Health issue?
• Insurance issues
• Credibility of support data
• NH Dental Society support
HB 1251 – As a ban on mercury amalgam:
NH Mercury Reduction Strategy
2002 Legislation
• DES to draft rules relative to amalgam disposal (RSA 485-A:4 XVIII)
• DHHS to create pamphlet for dentists to provide to patients
HB 1251 – Final version required:
NH Mercury Reduction Strategy
Amalgam Management Rules Developmentin
New Hampshire
Rules Development Workgroup first met summer, 2002
Key issue = Enforcement
Is the best approach a discharge
limit?
or
a performance standard?
(over 1,250 dentists and over 600 facilities)
Performance Standard = Amalgam Separator
Issues:• Level of performance required?
• “Home built” technologies?
• Particulate and soluble Hg?
• Waivers and exemptions?
Amalgam Management Rules Developmentin
New Hampshire
Performance Standard = Amalgam Separator
Key issue still = Enforcement:
600 practices = 600 installations to
inspect and
monitor.
Amalgam Management Rules Developmentin
New Hampshire
Amalgam Management Rules Developmentin
New Hampshire
The Environmental Results Program (ERP) format offers best solution to managing a large regulated sector like dentists…
…especially if ERP has rules backing it up.
• installation of ISO 11143-certified amalgam separator
or
• practitioner is exempt or requesting waiver
Env-Ws 905 STANDARDS FOR MANAGEMENT OF MERCURY-CONTAINING AMALGAMRequires written self-certification from “owner of the practice”:
Amalgam Rules Implementationin
New Hampshire
Exemption for:
• Orthodonists, periodontists, oral or maxillofacial surgeons, oral pathologists, oral or maxillofacial radiologists who don’t generate amalgam wastes
• Retired & out-of-state practitioners (NH licensed but not practicing in NH)
Amalgam Rules Implementationin
New Hampshire
Waiver for:
• “de minimis” discharge of up to 0.5 gram Hg/year (= 1 gram amalgam = 2 fillings)
• equivalent alternative technology
• “zero discharge” (holding tank)
Amalgam Rules Implementationin
New Hampshire
Concurrent to Rules Development (2003 – 2005):
• Surveys & outreach with NH Dental
Society• Information provided at annual
conferences• Articles in journals, newspapers, etc.• Site visits to dental facilities• Best Management Practices manual
Amalgam Rules Implementationin
New Hampshire
Initial Notification July 8, 2005
1,260 Licensed practitioners notified
10% response in first two weeks even though none required until October 1.
Amalgam Rules Implementationin
New Hampshire
Early issues & problems:
• Mobile units & schools
• Semi-retired or not in state
• “Amalgam-free” practitioners
• Endodontists
Amalgam Rules Implementationin
New Hampshire
Results as of J anuary, 2006
out of 1261 dentists
40%
Has amalgam
separator installed
(500)
15%
Exempt
(187)
20%
Retired/Not
in NH
(256)
25%
Haven't
Responded
(318)
Amalgam Rules Implementationin
New Hampshire
Next steps:
• Project turned over to enforcement staff January, 2006
• Recalcitrants are being contacted.
• Requests for de-minimis waivers will be reviewed.
• Random sampling to determine accuracy of self-
certification.
Amalgam Rules Implementationin
New Hampshire
Measurement:Outputs (beans) – 367 surveys completed
860 BMP Guides distributed5 presentations provided7 site visits performed
etc., etc.
Outcomes (behavioral changes)
2002 – Separators in use = 12 dentists = 1%2005 – Separators in use = 500 dentists = 40%Baseline survey is crucial to establish changes!
Amalgam Rules Implementationin
New Hampshire
Environmental Indicators (“hard” numbers)
Measurement:
Dental Mercury Generation Rates:NH % of National Releases 6.34 tons (Environ Report) x .004 (NH population) = 52 lbs/year/900 practicing dentists = 0.06 lbs/dentist/yearPer Chair Generation Rate:240 mg/chair/day x 4 days/wk x 48 weeks/454 grams/lb = 91 lbs/dentist/year/900 practicing dentists = 0.10 lbs/dentist/year
500 dentists x 0.06/lbs/yr x 95% separator efficiency = 28.5 lbs Hg recycled
Amalgam Rules Implementationin
New Hampshire
Conclusions:
The Environmental Results Program (ERP) model is effective for addressing the dental sector. The ERP format can also be used to help develop regulations making their implementation easier.
ERP is also useful for today’s “results-driven” projects and programs.
Amalgam Rules Implementationin
New Hampshire
Reducing Dental Mercury Releasesin
New Hampshire
What’s the real P2 solution?
Not this…
Reducing Dental Mercury Releasesin
New Hampshire
What’s the real P2 solution?
…but this!!!