Appendix A:

Best Management Practices (“BMPs”)

for Minimization of Mercury Discharges from Dental Offices

to the Sewerage System

Prepared by the Northeast Ohio Regional Sewer District

in Cooperation with Representatives of

the Ohio Dental Association and the Greater Cleveland Dental Society

Page 1 of 7

By making a check mark in the appropriate boxes (to indicate which, if any, of the

recommended BMPs will be implemented at your office) and providing the requested

information below, a signed copy of this document may be submitted to the Northeast

Ohio Regional Sewer District (“NEORSD”) as the required BMP Plan for this office.

Additional pages may be attached, as necessary, to supplement this document. (Send a

request to mercuryprogram@neorsd.org if you would prefer to be e-mailed a

Microsoft Word version of this document.)

 If the practice at this office does not handle (place or remove) dental amalgam,

you may make a check mark in this box and proceed directly to page 7 of this

document. (If the practice at this office handles dental amalgam in any form,

such as extractions of amalgam or extractions of teeth that contain amalgam,

do not make a check mark in this box.)

Mandatory BMPs

Install a dental amalgam separator certified to meet a removal efficiency of

at least 99% by ISO Standard 11143:1999. If the separator is not on the

“Northeast Ohio Regional Sewer District Approved Dental Amalgam

Separator Models” list, provide a copy of the certification to the NEORSD

Mercury Program for approval before installing the unit. Keep

documentation to show that you maintain the separator according to

manufacturer’s specifications. Your maintenance plan and maintenance

records must be made available to NEORSD upon request.

Eliminate all use of bulk elemental mercury (also referred to as liquid or

raw mercury). Use only precapsulated dental amalgam. Any bulk

elemental mercury must be recycled or hauled away as hazardous waste. It
Best Management Practices (“BMPs”) for Minimization of Mercury Discharges

from Dental Offices to the Sewerage System

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must never be poured into the regular trash, in with infectious waste (red

bag), or down the drain. (You may contact NEORSD Mercury Program

staff at 216-641-6000 or the Ohio Dental Association at 614-486-2700 for

information on recycling bulk elemental mercury or dental amalgam.)

Limit the amount of amalgam used to the smallest appropriate size for each

restoration. Keep a variety of amalgam capsule sizes on hand to more

closely match the amount triturated to the amount needed in the restoration.

Change or clean chairside amalgam traps frequently. Flush the vacuum

system before changing the chairside trap.

Change vacuum pump filters and screens at least once per month or as

directed by the manufacturer.

All amalgam waste must be either recycled (preferred method) or hauled

away as hazardous waste (acceptable alternative). Included are:

• Non-contact amalgam (scrap);

• Contact amalgam (e.g., extracted teeth containing amalgam);

• Amalgam/sludge captured by chairside traps, vacuum pump filters,

screens, and other devices;

• Used amalgam capsules that visibly contain any mercury;

• Leaking or unusable amalgam capsules;

• Spilled mercury and or amalgam must be swept up immediately and

placed into an amalgam recycling container. Any mercury should be

cleaned up in accordance with proper procedures.

Amalgam waste must never be put in the regular trash, put in with infectious

waste (red bag), or flushed down the drain. Amalgam-containing traps,

filters, or screens must never be rinsed over drains or sinks.

Store amalgam waste in covered, segregated, and clearly labeled airtight

plastic containers or as directed by your recycler.

Maintain a log of amalgam waste generation and recycling/disposal.

Documentation of all amalgam waste recycling and disposal must be

obtained from your recycler or hazardous waste hauler, kept on file, and

made available to the NEORSD upon request.

Train all staff that handles or may handle mercury-containing material in

its proper use and disposal.
Best Management Practices (“BMPs”) for Minimization of Mercury Discharges

from Dental Offices to the Sewerage System

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Recommended BMPs

 Use, when appropriate, mercury-free alternatives to amalgam (e.g., gold,

ceramic, porcelain, composites, polymers, glass ionomers, cold silver, gallium).

 Clean or replace under-sink traps and sumps, taking care to avoid spillage of

the contents from plumbing parts. Remove sludge that may contain mercury,

and have it recycled or hauled away as hazardous waste.

 Install clear plastic, easily removable under-sink P-traps, and have the contents

recycled or hauled away as hazardous waste if they may contain inadvertently

spilled mercury-containing material.

 Use disposable chairside amalgam traps instead of reusable traps in your

cuspidor and vacuum system, and have the disposable traps recycled or hauled

away as hazardous waste.

 Maximize the use of the high-speed suction (vacuum) system, because it

captures more of the amalgam waste than does the coarse screen in a cuspidor.

 During amalgam restoration/extraction procedures, remove wet cuspidors from

service and rely solely upon the high-speed suction (vacuum) system to remove

debris and saliva.

 Avoid using sodium hypochlorite (bleach) to disinfect vacuum lines, because it

dissolves mercury out of amalgam.

 Obtain mercury spill kits, place them in appropriate easy-to-access locations,

and immediately use them as directed by the manufacturer for any spill of

mercury-containing material. All spilled mercury-containing material must be

recycled or hauled away as hazardous waste.

 Implement a program to have mercury-containing thermostats, switches, and

fluorescent light bulbs recycled when they are replaced. Thermostats and

switches should be replaced with mercury-free alternatives.

 Describe below any additional BMPs for mercury discharge minimization that

you may have identified and plan to implement.
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from Dental Offices to the Sewerage System

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Best Management Practices (“BMPs”) for Minimization of Mercury Discharges

from Dental Offices to the Sewerage System

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Please provide the following information to the best of your ability.

1. List the individuals, including all the dental care practitioners at your office, who are

responsible for developing, implementing, and practicing under this BMP plan, and

designate one individual who has the primary responsibility for it:

2. List and describe all identified potential sources of mercury or mercury-containing

materials that could enter the sewerage system from this office:

3. Describe any BMPs that you may have implemented in the past and/or may be

currently implementing for mercury discharge minimization. (See previous pages of

this document for examples.) Also, please provide any information that you may

have obtained regarding the effectiveness of the BMPs:
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4. Provide information from any technical/economical evaluation that you may have

performed on BMPs for mercury discharge minimization:

5. Provide a schedule for implementation of the BMPs that you have indicated will be

implemented for mercury discharge minimization at this office. Implementation of all

mandatory BMPs should begin as soon as possible and must begin no later than 90

days from the date of the BMP Plan.

6. Describe any methods that you may have identified for measuring progress toward

the BMP Plan goal and updating this BMP Plan (e.g., documenting increased

utilization of mercury-free alternatives, researching new BMPs, etc.):
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from Dental Offices to the Sewerage System

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Your Name:

Mailing Address:

Office Address (if different from Mailing Address):

Telephone Number:

________________________________________________ __________________

Your Signature Date

If this document is to serve as your required BMP Plan for mercury discharge

minimization, send one completed copy of it for each office at which you practice no

later than May 31

st

, 2011 to the address below:

Northeast Ohio Regional Sewer District

4747 East 49

th

Street

Cuyahoga Heights, OH 44125-1011

Attention: Mercury Program