Bio-Pure is dedicating it's Q1 Newsletters to this new rule. Although we do not sell Amalgam Separators, we have championed Evacuation System Health for the last decade. In particular appealing for elimination of "nasty products" down the drain. We have experience with all Amalgam Separators. Our product helps save costs by reducing the volume of organic waste they collect. Bio-Pure digests (eat it up) the organic waste unlike chemical cleaners which flushes the waste. These are genuine before and after images sent to us by service technicians in the field.

re Patient Health. This falls outside the scope of our Newsletter which we have limited to Evacuation System Health. This is what we know! We will cover potential risk to patient health and infection control from slow suction in future issues. For those interested in this related topic, we have added the following links: To the Food and Drug administration web page. To the ADA Statement on Dental Amalgam.  To the Campaign for Mercury Free Dentistry. To the article "Are Amalgam Fillings Safe" - Dr. Oz show. written by Jonathan B. Levine, DMD

We all agree that mercury in our water systems is not good. The question is how to stop this?

As I did my research for the Bio-Pure Newsletter, remembering the hype about mercury in CFL's, I realized that this segment would need responsible fact checking. The dental industry does not need amalgam scare tactics by Amalgam Separator manufacturers, any more than consumers need mercury in their food and water. When I discovered that the average amount of mercury in ONE amalgam filling was 100 (exact calculation) times that of a GE Spiral and reviewed the EPA legislation for CFL disposal as a hazardous waste, I had to conclude that there was an issue. Why would the EPA legislate for CFL disposal, and not for Amalgam separation?                     

The EPA estimates that dental offices discharge approximately 3.7 tons of mercury each year to POTWs. This represents about 50% of all mercury discharged to them. Although they filter 90% of the mercury out, the remaining 10% enters our water systems, or is distributed to organic farmers who purchase treated waste as fertilizer. This is consistent with a discussion I had in 2014 with Dr. Fraker,  published in Dental products report June 2013, who was called in as an expert by King County Washington. The county went on to regulate for Amalgam Separation in June 2003. The state of New York legislated for Amalgam Separation in May 2008, after a study by the New York Academy of Sciences, Pollution Prevention and Management Strategies estimated that as much as 40 percent of total mercury loadings in the New York/New Jersey harbor and watershed may have come from dental offices.

In context
I have spoken to a number of dentists on this issue. Often being told that they no longer use amalgam for dental repairs. Looking at the data I can understand why. But this does not solve the issue of us older folk who have existing amalgam fillings that get worked on. The picture of 100 light bulbs going down the drain each time a patient has a filling replaced was a big shock!   

In 2007 the law firm of Pepper Hamilton released Docket ID No. EPA–HQ–OW–2006–0771 in response to a NACWA study estimating that nearly 40 percent of the mercury in the nation’s wastewater system came from dental offices. It states "The ADA opposes mandatory separators, but strongly supports the use of voluntary separators to achieve the mutual goals of EPA and the ADA."

The February Newsletter is going to examine the standards of mercury separation proposed by the new rule. Early local legislation mandated a particle separation rate of 95%. Later state mandates increased this to 95% and 98%. I hear whispers that the new rule will go further. Mercury particles can be filtered out in various ways. This does not address the Soluable Mercury which may well be the same 10% that the POTW's can not capture?

There is also the issue of how to dispose of the hazardous material captured. I am told by a manufacturer who offers total collection that mercury is the recognized "bad" substance, but that there are actually far more "nasty" substances when a complete analysis is done. We are going to explore this further. Then there are the conflicting rules on handling the waste. Some provide a sealed pre-paid collection cartridge which is convenient but costly. Others provide a "bucket" that you empty the collection container into. There are many possible solutions, which we will look at once the separation standard is published.

There are two points that can be made today: i) this waste must not go down the drain ii) less waste to dispose of really does mean money saved.

State and local legislation.
The community web site Open4BioClean publishes a directory of states, counties and districts which have Amalgam Separator mandates today. 

SolmeteX (who have an estimated 75% market share in regulated areas) estimate that less than 2% of dentists in unreglated areas have invested in an Amalgam Separator. 

It comes as no surprise to me to find that the EPA web site includes studies which support their new rule. As my late father used to say "lies, lies and statistics!" I am no less surprised to find that the ADA has opposed legislation since 2002. The body is funded by it's members and I have yet to find a body of members who lobby for increased costs. I am not an expert on water purity. But I have sufficient life experience to suggest that allowing any 400mg of mercury "ground" out of a patients mouth to flush directly down the drain is not right! I will confess to being more than a little concerned that a mere 2% of dentists in unregulated areas have stepped up and addressed this issue.

It is not my place to offend. In fact I commend Bio-Pure for inviting me to include this editorial. It takes a strong company, confident in their message, to hire an external writer to speak out boldly. The need to maintain a healthy evacuation system, or the potential of new science is not new news. In fact it is old news! It took a generation for littering to become socially unacceptable. I wonder what it is going to take to have us think more about wasting electicity. I believe we need to use fewer chemicals when possible. They are harmful to the people who use them. They end up being harmful to us when they go down the drain.

I am not for more rules. I stand firmly against too much governance in small business. Which includes family dental practises. This new rule should not have been required. We had 12 years to do the right thing by self regulation. I am told that this rule is going to get passed. Next month we will take a detailed look at the new standards brought down on us by the EPA.