I think that EPA felt the heat from outside groups and Congress (remember that link I sent a while back where you could watch EPA testify? It was memorable testimony). It appears that EPA is going to look at developing effluent guidelines for dental facilities (propose a rule in 2011). EPA is already trying to limit mercury controls: they do not want to look beyond amalgam separators. What if something beyond an amalgam separator is required to allow a POTW to achieve compliance? I presented data in a previous blog on just such a case study.
EPA expects to propose a rule next year and finalize it in 2012. Dental offices will be able to use existing technology to meet the proposed requirements. Amalgam separators can separate out 95 percent of the mercury normally discharged to the local waste treatment plant. The separator captures the mercury, which is then recycled and reused.
Until the rule is final, EPA encourages dental offices to voluntarily install amalgam separators. Twelve states and several municipalities already require the installation of amalgam separators in dental offices.
Approximately 50 percent of mercury entering local waste treatment plants comes from dental amalgam waste. Once deposited, certain microorganisms can change elemental mercury into methylmercury, a highly toxic form that builds up in fish, shellfish and animals that eat fish.
Fish and shellfish are the main sources of methylmercury exposure to humans. Methylmercury can damage children’s developing brains and nervous systems even before they are born.
Also, remember the Michigan Law? That is still sitting out there as a problem that EPA does not want to touch (especially before the mid-term elections). Will the EPA regions flex their muscles? Will Region 1 continue to be the lone voice out there? Will the ADA be making the decisions? What happens if the effluent guidelines conflict with the Methylmercury NPDES implementation document? What about the EPA-ADA-NACWA MOU?
I hope everyone will take the time to be involved in this. If anyone gets any information (inside) please pass along and be assured anonymity.
See what EPA says: http://water.epa.gov/scitech/wastetech/guide/dental/