"Beryl Fletcher" 

<bfletcher@oregondental.org>

12/28/2007 12:02 PM 

To Group Ow-Docket@EPA 

cc

bcc

Subject Attention Docket ID No. EPA-HQ-OW-2006-0771 

 

 

The Oregon Dental Association offers the attached comments regarding the 2007 annual review of 

existing effluent guidelines and pretreatment standards and the preliminary 2008 plan identified by 

Docket ID No. EPA-HQ-OW-2006-0771 

 

If you have any questions regarding these comments please contact me. 

 

Sincerely, 

 

Beryl B. Fletcher 

Director of Professional Affairs 

Oregon Dental Association 

P O Box 3710 

Wilsonville, OR 97070 

(503) 218-2010 Ext. 106 

Email: bfletcher@oregondental.org
December 27, 2007 

To: Email: OW-Docket@epa.gov 

Attention Docket ID No. EPA-HQ-OW-2006-0771 

The Oregon Dental Association (ODA) offers the following comments on the EPA’s 

preliminary study of the need for pretreatment rules requiring additional regulatory 

mandates for dental office pretreatment oversight. 

The ODA represents approximately 75% (more than 2000) of all dentists in the State of 

Oregon. Membership is tripartite in that they join at the local dental society level and 

also belong to the state level, Oregon Dental Association and the national level, 

American Dental Association. 

Oregon’s Best Management Practices Program (BMP’s), which are the same as the 

American Dental Association pre-separator BMP’s, has been a model for voluntary 

pretreatment efforts and demonstrates successful elements for a public-private 

partnership with local and state pretreatment and hazardous waste agencies. Merely 

mandating installation of amalgam separators will not capture the majority of the 

amalgam waste from the waste stream. Proper management of chair side traps and 

suction pump filters are key to a successful waste management program. With limited 

resources at regulatory agency levels and in dental offices, the ODA and local and 

state regulatory authorities developed a plan to implement a voluntary Best 

Management Practices for Oregon dental office wastes. 

ODA has been working in a public-private partnership for voluntary Best Management 

Practices for Dental Wastes with local pretreatment agencies, the Oregon Association 

of Clean Water Agencies (ORACWA) and the Oregon Department of Environmental 

Quality (DEQ). Oregon voluntary efforts for dental wastes were implemented 

approximately ten years ago with the City of Portland in response to Portland’s 

administrative rule proposals for silver discharges. These efforts expanded statewide 

and include mercury, amalgam, and lead wastes in dental offices. The Oregon Dental 

Association is dedicated toward implementation in every Oregon dental office. 

BMP’s have been implemented in most all large communities across the state and in 

some smaller communities. New efforts have been implemented to reach all local 

wastewater pretreatment areas regardless of size. Many areas have 100% compliance. 

The City of Corvallis is just one success example with all dentists in compliance. EPA 

awarded Corvallis EPA's 2006 National First Place Cleanwater Act Recognition Award 

for Pretreatment Program Excellence.
 

The key elements of Oregon’s Voluntary BMP program have included: 

1. Voluntary compliance through outreach and cooperative efforts between ODA, 

local pretreatment agencies and Oregon DEQ. 

2. Does not require significant revenue resources for local pretreatment 

municipalities or dental offices. The program allows for limited overhead 

costs to dental offices and for regulatory agencies. For dental offices, chair side 

traps and suction pump filters are the waste focus since they capture the 

majority of amalgam wastes. These traps and filters are relatively inexpensive 

and must be changed regularly for efficient operation of dental equipment. 

Oregon disposal practices have been re-routed to recycling rather than landfills, 

wastewater and incineration practices. Chair side traps and suction pump filters 

collect the majority of amalgam wastes with separators only capturing miniscule 

particles of 15 - 20%. 

Additionally, overhead costs are limited for state and local pretreatment agencies with 

no mandates for expensive sampling and permit requirements. 

3. Education with the ODA providing training through the following avenues: 

a) Seminars and workshops and presentations including: 

• Statewide Annual dental association convention, 

• Local dental society meetings (sixteen societies in Oregon) 

• Oregon Dental Assistants Association meetings, 

• Oregon Dental Executives Association meetings (office managers 

association), 

• community college dental assistant training programs, 

• Northwest Pretreatment meetings, and 

• Oregon DEQ staff training workshops. 

4. Direct mailings to all Oregon dentists regardless of ODA membership. 

5. Website accessibility to all dental professionals to BMP information and 

recycling resources www.oregondental.org and links from www.oracwa.org and 

www.oregon.gov/deq websites. 

6. Newsletter articles developed for ODA and local dental society newsletters. 

7. Active BMP workgroup between stakeholders with focus on development 

and ongoing improvement strategies for Oregon’s BMP program for dental 

offices. Workgroup members include: 

a. Oregon Dental Association leadership and staff 

b. Oregon Association of Clean Water Agencies 

c. Oregon Department of Environmental Quality 

d. Oregon OSHA 

e. Oregon Health Division Infection Control staff 

f. Portland METRO Recycling 

Recently we have added the League of Oregon Cities and Association of Special 

Districts to our workgroup efforts. 
8. Memorandum of Agreements with local pretreatment municipalities and 

commissions to define working relationships and cooperative efforts. 

9. Maintenance of recycling resource list through partnership efforts with local 

pretreatment agencies, Oregon DEQ and Oregon ACWA to review new potential 

recyclers and facilitate the ongoing review of the list is a key factor. The result 

has been that dental suppliers have become involved and some facilitate mail 

back and pick service programs. The program started with just few resources 

for appropriate waste disposal to a large list of several pages and continues to 

grow. Cooperative efforts and involvement for maintenance of the list is 

instrumental to successful recycling efforts. Recyclers go in and out of business 

so review and oversight facilitates the success. 

10. Surveying of dental offices on waste disposal practices (see attached survey 

document). Not all dental offices place or remove amalgam. Orthodontist 

offices for example do not handle amalgam or mercury in any way. Many offices 

currently are only removing amalgam. Our survey document captures this 

information. 

We are currently capturing survey information and are developing a database together 

with Oregon ACWA for all survey information received from dental offices. Data input 

is currently in process for the statewide surveys sent to all dentists in late September. 

Notably, areas of survey questions cover a variety of data including those dental offices 

that do not have any contact with amalgam, average restoration placement and 

removal as well as those dental offices that currently have an amalgam separator 

installed. 

11. Exhibit booth at the ODA Convention - Oregon ACWA members together with 

ODA staff have an exhibit booth at ODA’s state convention in April of each year. 

Information on Oregon’s BMP program and access to direct contact with all 

dental professional staff is available through this exhibit. 

12. Amalgam and mercury collection events sponsorship during the ODA state 

convention in April of each year. Oregon DEQ has also developed additional 

recycling disposal of amalgam at many of the local waste facilities around the 

state. 

Convenient disposal and cost factors are issues with dental offices since most dental 

offices are small businesses with average overhead costs of 68%. Dental offices are 

already are subject to many of the same regulatory requirements for infection control as 

hospital operating rooms. Equipment costs are significant. Additional overhead costs 

drive up the costs of already strained resources to provide dental care to the neediest 

populations. 

13. Certificates/letters of compliance to dental offices – Dental offices are sent 

a certificate of compliance when demonstrating they comply with ODA BMP’s. 

Dentists are happy to comply and appreciate recognition of their efforts in 

environmental protection. 

New Oregon legislation will eventually require amalgam separator installation by 

January 1, 2011 for all dental offices. Oregon Senate Bill 704 allows for dental offices 

in compliance with the ODA BMP’s to have an extension until January 1, 2011 to install 
an amalgam separator. This applies to those dental offices that have materials 

containing mercury that pass through a drain. The extension was granted in 

recognition of the value and effectiveness of the BMP program in Oregon. This 

extension is critical for many dental offices since building constraints relating to space 

availability, plumbing and electrical components are difficult or limited in many of the 

office buildings housing dental offices. Cost factors in the installation can be 

significant. 

Oregon dentists and the ODA are committed to environmental responsibility. ODA 

participated in a Oregon’s Mercury Solution Team and helped develop a report called 

“Mercury- On the Road to Zero” which developed strategies to eliminate releases of 

mercury in Oregon’s environment by the year 2020. ODA BMP’s are part of those 

strategies. The report generated, was funded by a Pollution Prevention Incentives for 

States grant from the U. S. Environmental Protection Agency and the Oregon 

Department of Environmental Quality. Additional support was provided by Portland 

General Electric, Portland METRO, Clean Water Services and the Oregon 

Environmental Council. A copy of the document is available on the Oregon 

Environmental Council website http://www.oeconline.org/publications/pubs-reports. 

This is another example of voluntary cooperative efforts with public and private 

business. 

In addition to working on voluntary BMP’s and solution teams, Oregon dentists are 

committed to their community not only for dental health needs but they also live and 

raise their families in these communities. Dental health is about prevention as most all 

dental disease can be prevented. Oregon dentists have demonstrated in the survey 

documents we are capturing, they are committed to environmental responsibility. They 

have also been very instrumental in sharing resources for recycling. ODA’s recycling 

list has grown largely due to information they have shared relating to companies they 

have been using for recycling. 

Oregon’s BMP Program motto is: 

Dentistry is about prevention! 

Prevention=BMP 

If it’s not going down the drain or in the landfill, it must be a BMP! 

We respectfully submit our comments and ask the EPA to recommend voluntary BMP’s 

as a means to an effective, cost conscious and responsible method to dental office 

waste management. 

Sincerely, 

On behalf of the Oregon Dental Association 

Beryl B. Fletcher 

Director of Professional Affairs 

Oregon Dental Association 

P O Box 3710 

Wilsonville, Oregon 97070 

(503) 218-2010 Ext. 106 

Email: bfletcher@oregondental.org