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ADA Offers Constructive Comments on Proposed EPA Amalgam Separator Rule


February 20, 2015
by American Dental Association (ADA)

The U.S. Environmental Protection Agency’s proposed rule requiring amalgam separators in some dental settings incorporates many of the important principles required by the American Dental Association for its support of a national rule.  However, in comments submitted to the agency today, the ADA notes that it cannot, at this time, offer its support for the rule as written.

The ADA supports a reasonable national pretreatment standard for amalgam waste and applauds the EPA’s efforts to address the Association’s concerns in the proposed rule. The Association has filed comments with EPA with specific suggestions on how to improve the proposed rule and eliminate several areas of ambiguity and internal inconsistencies. The Association remains hopeful that EPA will incorporate its suggestions in a final rule which the Association can support.

The ADA has long supported amalgam separators and their use is widespread. In 2007, the ADA updated its best management practices for the disposal of dental amalgam waste to include the use of separators, collection devices installed in dental office plumbing to capture and remove at least 95 percent of solid waste particles before they enter the sewer system. The use of separators allows greater recycling and reduces the amount of amalgam entering wastewater treatment plants. Some states and municipalities already have separator requirements in place.

Dental amalgam, a safe, affordable and durable material with an established record of safety and effectiveness, is a mixture of metals, including silver, copper and tin, in addition to mercury. Even without separators, 78 percent of dental amalgam is captured by chair-side traps and vacuum filters, while 95-99 percent of the rest is captured by treatment plants.  Very little—less than 1 percent—of the mercury released into the environment comes from dentistry.

The ADA will continue working closely with the EPA on crafting a suitable and workable amalgam separator rule that balances protecting the environment and the concerns and needs of dentists and their patients.

About the American Dental Association
The not-for-profit ADA is the nation’s largest dental association, representing 158,000 dentist members. The premier source of oral health information, the ADA has advocated for the public’s health and promoted the art and science of dentistry since 1859. The ADA’s state-of-the-art research facilities develop and test dental products and materials that have advanced the practice of dentistry and made the patient experience more positive. The ADA Seal of Acceptance long has been a valuable and respected guide to consumer dental care products. The monthly The Journal of the American Dental Association (JADA) is the ADA’s flagship publication and the best-read scientific journal in dentistry. For more information about the ADA, visit www.ada.org. For more information on oral health, including prevention, care and treatment of dental disease, visit the ADA’s consumer website www.MouthHealthy.org.