"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 pr etreatment standards and the pr eliminary 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.orgDecember 27, 2007

To: Email: OW-Docket@epa.gov

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

The Oregon Dental Association (ODA) offe rs the following comments on the EPA’s preliminary study of the need for pretreatment rules requ iring additional regulatory mandates for dental office pretreatment oversight.

The ODA represents approximately 75% (more t han 2000) of all dentists in the State of Oregon. Membership is triparti te in that they join at t he local dental society level and also belong to the state le vel, 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 su ccessful elements for a public-private partnership with local and state pretreatment and hazardous waste agencies. Merely mandating installation of amal gam separators will not capt ure the majority of the amalgam waste from the waste stream. Proper management of chair side traps and suction pump filters are key to a successf ul waste management pr ogram. With limited resources at regulatory agency levels and in dental offices, the ODA and local and state regulatory authoritie s developed a plan to implement a voluntary Best Management Practices for Oregon dental office wastes.

ODA has been working in a public-private par tnership for voluntary Best Management Practices for Dental Wastes with local pr etreatment agencies, the Oregon Association of Clean Water Agencies (ORACWA) and th e 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 o ffices. The Oregon Dental Association is dedicated toward implem entation in every Oregon dental office.

BMP’s have been implemented in most all la rge communities across the state and in some smaller communities. New efforts have been implemented to reach all local
wastewater pretreatment ar eas regardless of size. Many areas have 100% compliance.

The City of Corvallis is just one success ex ample 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 Vo luntary 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 effici ent operation of dental equipment. Oregon disposal practices have been re-rout ed 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 sampli ng and permit requirements.

3. Education with the ODA providing trai ning through the following avenues: a) Seminars and workshops and presentations including:

• Statewide Annual dental as sociation convention,

• Local dental society meetings (sixteen societies in Oregon)

• Oregon Dental Assistants Association meetings,

• Oregon Dental Executives Associ ation meetings (office managers association),

• community college dental a ssistant 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 En vironmental Quality d. Oregon OSHA e. Oregon Health Division Infection Control staff f. Portland METRO Recycling Recently we have added the League of Ore gon Cities and Association of Special Districts to our workgroup efforts.8. Memorandum of Agreements with local pretreatm ent municipalities and commissions to define working rela tionships 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 wi th just few resources for appropriate waste disposal to a large list of several pages and continues to grow. Cooperative efforts and involvem ent for maintenance of the list is instrumental to successful recycling effo rts. 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 pl ace 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 info rmation 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 surv eys sent to all dentists in late September. Notably, areas of survey questions cover a va riety of data including those dental offices that do not have any contact with am algam, average restoration placement and

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

installed.

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

ODA staff have an exhibit booth at ODA’s stat e convention in April of each year. Information on Oregon’s BMP program and a ccess to direct contact with all dental professional staff is avai lable through this exhibit.

12. Amalgam and mercury collection events sponsorship during the ODA state convention in April of each year. Or egon 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 is sues with dental offi ces since most dental offices are small businesses with average ov erhead costs of 68%. Dental offices are already are subject to many of the same regu latory requirements for infection control as hospital operating room s. Equipment costs are signifi cant. Additional overhead costs drive up the costs of already strained resour ces 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 demonstrat ing they comply with ODA BMP’s. Dentists are happy to comply and apprecia te recognition of their efforts in environmental protection.

New Oregon legislation will eventually requ ire 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 installan amalgam separator. This applies to t hose dental offices that have materials containing mercury that pass through a dr ain. The extension was granted in recognition of the value and effectivene ss of the BMP program in Oregon. This extension is critical for many dental office s since building constraints relating to space availability, plumbing and electr ical 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 res ponsibility. ODA participated in a Oregon’s Mercury Soluti on Team and helped develop a report called “Mercury- On the Road to Ze ro” which developed strategies to eliminate releases of mercury in Oregon’s environment by the ye ar 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. A dditional 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/pub lications/pubs-reports

. This is another example of voluntary c ooperative 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 pr evention as most all dental disease can be prevented. Oregon dent ists have demonstrated in the survey documents we are capturing, they are committ ed to environmental responsibility. They have also been very instrumental in shari ng resources for recycling. ODA’s recycling list has grown largely due to information t hey 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