1. There was a 54% response rate and out of the 250 offices surveyed, 134 responded to the survey.
   
   
2. Did your dental practice receive a copy of the "Environmentally Responsible Dental Office: A Guide to Proper Waste Management in Dental offices?"
• 118 responded Yes - which was a favorable response
• 8 said they did not get the guide and were sent a copy
  
  
3. Does your dental office use dental amalgam as a restorative material?
• 26% of those that answered do not use amalgam

 

• Dan Ferris believes that there is a reduction in amalgam use according to information that he received in a recent "Delta Dental" meeting.
• Peter Taylor indicated that he has a report from the American Dental Association that obtained information on the sale of mercury to dentists – it also reflects decline in the use of amalgam.
• Question as to whether results would be sent to dentists.
• Peter Taylor advised that he planned to put the general results of this survey in the Vermont State Dental Society’s next newsletter. He indicated he would be focusing on key questions, explaining contact vs. non-contact and address the issue of disposing of elemental mercury in the dental offices.
• Dental Society’s newsletter is distributed four times per year and these results would potentially be in the August/September issue.
• Suggestion to review information provided by the US Naval Dental Research.
• Canada is doing research on discharges using the ISO certification for 95% removal. Two or three brands are already certified and more in progress.
• Agency completed procedures for medical waste hauling. The medical waste was previously regulated as hazardous waste but has since been transferred to solid waste regulations where a procedure has been developed. The procedure currently excludes teeth. Essentially, as long as the amalgam is sent to be processed for precious metal recovery, it is exempt from hazardous waste management regulations.
• Most of the amalgam separator manufacturers will take contact and non-contact materials for disposal.
• Concern that the material being sent for precious metal recovery has bio-hazardous material in it is well.
• Suggestion that by developing Best Management Practices (BMP) Procedures through the Agency, it would eliminate the questions regarding correct disposal. The dentists would have a set of guidelines to make it clear what practices should be followed. If the dental offices conform to the BMP Procedure, they will not be subject to RCRA hazardous waste requirements.
• Question as to whether the Vermont State Dental Society has done any Jerome meter testing in dental offices.
• Concern that older dental offices may have mercury still left in the building from minor spills during the amalgam mixing process.
• Concern that hygienists could potentially be women of childbearing age and exposed to mercury from historic spills in building.
• Suggestion that the dental society rent a Jerome meter, such as one the Health Department has, to do their own monitoring for mercury in dental offices.
• Dan Ferraris added that many dental offices now have linoleum rather than tiles (as common in the past) which would prevent mercury from getting in between tiles. Also carpet can be a problem and many carpets have been replaced because they could not be cleaned.
• Dental Society commended for their efforts in conducting survey and encouraged to continue with follow-up surveys in the future.
• Question to Dental Society as to the use of amalgam being determined by the amount purchased by dentists. When you examine different use categories, how do they compare?
• Concern that USGS is no longer reporting numbers regarding the sources of mercury pollution. At one point dental use was rated the third largest contributor nationally.
• Suggestion that Vermont State Dental Society collect data on:
• Number of chairs in different dental offices and record a per patient/per chair use
• Question as to the relationship between the number of patients that go through the facility and the number of chairs per facility.
• Suggestion by Dan Ferraris that a more accurate assessment would be the number of dentists in the office as a dentist could have five chairs but three could be for dental hygienists and only two working chairs.
• Michael Bender to research the information regarding the per chair relationship and advise the Committee.
• Suggestion by Peter Taylor that per chair usage may vary greatly in a dental office. Total amalgam usage in an office would be a better measure.
• Number of dentists not on municipal waste systems. Difficult to get mercury out of a septic tank. Perhaps this should be indicated when the dental office is sold. Banks presently conduct environmental audits and perhaps this type of audit for mercury should be included in reference to dental offices that are sold.

• Massachusetts: (Strategic Enviro Technology Program "STEP")
• The Massachusetts Executive office hired a consultant to conduct a three-month study to evaluate existing protocol for amalgam separators.
• The second phase of lab and field testing is planned if the first phase research finds that the protocol is inadequate.
• Preliminary recommendation in January
• Tony French to assist in review process
• Representative from American Dental Association is a part of the research.
• Six-state group including California and New York also conducting research. Michael Bender expecting information packet which he will share with the Committee and provide to Peter Taylor.
• Question as to whether state will be setting a regulatory threshold by developing BMP Procedure.
• Question as to whether the Advisory Committee would have a role in developing the BMP Procedure.
• Suggestion that once BMP are in place that dental offices should have some sort of monitoring or evaluation, possibly including a reporting requirement
• Question as to how much of the amalgam actually stays in the patient’s mouth versus the amount left over from the amalgam capsule and what is done with the remaining amalgam.
• Dan Ferraris told the Committee that historically elemental mercury was mixed by one measure, which was termed as a "spill." This is how the term "spill" capsule came about. Spill capsules are typically sold in one, two or three spill capsules. Most fillings are two spills at about ½ of a gram of mercury. The dentist determines the amount after examining the tooth and commonly mixes a little more than is needed. What is left over after the filling is in place is disposed as "non-contact" amalgam. The filling is smoothed and when carving the filling it goes into suction as chunks. A high percentage of the amalgam goes into the patient’s mouth. What goes out of the office is when a patient comes into the office and the tooth shaped down for a replacement filling. While using the drill, the shavings go all over the place and that is what goes into a separator or into sludge.
• Comment that statistics show that 40 tons of mercury per year is used by dental offices and a large percentage is what is generated as waste is from existing fillings. Question as to how much stays as amalgam of this 40 tons and how much is free mercury.
• Suggestion that information regarding amalgam use should be more Vermont specific.
• Question if we can estimate how much is going into the lines? Peter Taylor advised that this was unknown.
• Question as to how many fillings are replacement and how many are new. Dan Ferraris advised that this would be impossible to track.
• Suggestion by Peter Taylor regarding Bill (S.91):
• Bill suggests a report from the Health Department in three years on amalgam use. There are many changes in the use of amalgam. A more valid way of evaluating may be the rate of decline of use.
• Concern over dental offices being prohibited from using amalgam.
• Suggests that an evaluation of use be considered a few years from now.
• Dan Ferraris stated that he was concerned environmentally and believed there was no health concern from the patient’s standpoint. He believes there are certain instances where amalgam needs to be used.
• Neil Kamman suggested to concentrate efforts on source apportionment –how much mercury goes into the water and how can it be controlled?
• Peter Taylor advised the Committee:
• The most significant project in the next six months would be revising the BMP guide to include the solid waste procedures and the contact/non-contact definitions.
• The Dental Society wants to recreate its web site and place the BMP guide on line. The question is whether to invest the funds into reprinting the guide. There still would be a need for hard copies for those dentists who do not have internet capability.
• Suggestion that Department would take the lead in developing the BMP Procedures which is one step away from a rule or regulation.
• Suggestion to re-evaluate all BMP that are currently in the guide and include in the Procedures.
• Suggestion to form an amalgam work group to gather information and stay current using information provided by Department engineer. The information provided by this group will be brought to conclusion in 6 months to 1 year from the time it is formed.
• Concern that there is a gap between Medical Waste Procedures and RCRA Rules for recovery of precious metals.
• Suggestion to establish the BMP Procedures now and amend to include information on amalgam separators later once sufficient research has been completed.
• Suggestion to have one Department engineer evaluate existing data on amalgam separators.
• Suggestion to not make a recommendation to dentists to spend the funds to purchase amalgam separators until the Committee is certain this is the potential solution to the problem.
• Suggestion that the Committee stay current on the amalgam separator studies.
• Suggestion to put together a time line on issues where the Committee can move forward on amalgam, interim recommendations and continued coordination with the Vermont State Dental Society.
• Peter Taylor suggested waiting for other research as the Dental Society did not have the resources to complete a study.
• Dan Ferraris advised that in his conversations with other dentists, the predominant concern is infection control in dealing with hazardous waste. Everyone is talking about focusing on the health standpoint rather than an environmental standpoint. Once this is clarified, he believes there will be a huge leap forward in compliance. The dentists need direction; the requirements for them at this point are strictly up to interpretation.
• Suggestion that Committee review the sludge standards for mercury.
• Suggestion that any work toward sludge standards be included in next year’s work plan.
• Suggestion to have a draft of the BMP Procedures available for review at the Advisory Committee’s October meeting.

• Michael Bender advised he was willing to work with Dr. Bress on the report to be presented to the Committee.
• Suggestion to coordinate with other New England states for consistency. Dr. Bress indicated that the New England states were relatively standard in their protocol for fish advisories; however, the sampling generates different results. The results of this testing was still more accurate for the population than a national standard.
• Michael Bender advised Committee that the June issue of Consumer Reports contained a report on testing of large predatory fish and canned tuna. Another report was completed by Maine regarding the differentiation of mercury levels between white and light tuna.
• It was reported that Connecticut Health Department has recommendations for no more than one tuna steak meal per month for sensitive populations.
• Michael Bender will provide data regarding consumption limitations for tuna steak for Bill Bress for consideration of incorporating into Vermont’s advisories.
• Dr. Bress advised that certain fish should not be eaten. He expressed a concern in advising people to not eat fish at all.
• EPA guidelines are a general formula for children. For every 20 pounds of body weight, one ounce of fish. (2 ounces for a 40-lb. body weight – 1 ½ oz. of white tuna and 3 oz. of light).
• EPA guidelines are based on mother’s body weight - fetus is much smaller than child’s weight – cannot extrapolate back to young child’s restrictions as it would allow more for a child – all intake by mother goes to fetus.

• Electronics – Tom and Karen
• *Where do electronics ultimately end up?
• *Why are electronics an issue in landfills?
• *Research and report on electronics take back programs.
• Lamps – Jen and Laura
• *What are some other special methods for handling lamp disposal?
• *What are the worker safety issues regarding lamp management?
• Appliances – Tom, Karen and Gary Gulka
• *Potential funding for removal of mercury components from appliances.
• *Does the pending legislation adequately address leveling the playing field for all those required to remove mercury devices from appliances
• Vehicles – Tom and Bart
• Thermostats – MERC Committee
• Dental – EAD
• Batteries – Tom and Karen
• Medical – Karen
• Manometers – Mike

• Collection options
• Current collection programs
• Conducted by whom
• To what degree
• Pros and cons of current collection programs
• Possible improvement/recommendations
• Cost
• Current collection programs
• Potential funding alternatives
• Does it require legislation to make it work?
• Current collection programs
• Potential other programs
• Special issues to be addressed for specific categories (as indicated above*)

1. Environmental Monitoring Data

• Need for Environmental Monitoring Data:
• Refinement of Fish Advisories (lake or lake class specificity) using REMAP data.
• Development of VT specific Hg criterion and assessment of waters in violation.
• Development of Hg Load Allocation and subsequent TMDL (Total Maximum Daily Load)analysis.
• Where good coverage exists:
• In-lake chemical and biological Hg measurements.
• Atmospheric deposition and loading estimates (for Underhill, Vt).
• Estimates of VT’s contribution to Hg use and emissions (new emissions inventory).
• Where monitoring coverage or information is lacking:
• Point source loading of Hg, and particularly of meHg.
• Revised emission factors for area sources; particularly landfills.
• Revised estimates of mobile source Hg in light of new findings of high Hg in fuel.
• Atmospheric deposition estimates for areas away from Underhill (e.g. southern VT)
• Proposed activities:
• Review literature regarding point source Hg and meHg loadings. Combine findings with NPDES inventory data to estimate Hg loadings to watersheds statewide.
• Review existing and new literature regarding emissions of Hg and meHg from landfills. Estimate potential Hg emissions from what few landfills remain in Vermont.
• Review information from Naval Dental Laboratory regarding Hg and meHg in dental office wastewater. Develop estimates of potential loadings attributable to this source. These loadings are likely either passed to WWTF’s, or treated on site via septic systems, and thus may not need to be treated separately.

• Suggestion to obtain EPA translator for fish tissue data and water data.
• Suggestion to define lakes for which special advisories exist and where species which are known to have higher levels of mercury exist and post restrictions on fish consumption that are lake specific.
• Suggestion to obtain information from a Florida landfill study by Steve Lindberg which showed significant levels of Hg and meHg measured in the air downgradient of the landfill working fce.
• Suggestion that data from Lindberg’s work shows that Hg levels in measurements from tailpipe emissions of vehicles are below dection limits. Question as to level of detection given that these levels are excessively difficult to measure.
• Suggestion to evaluate study by Jerry Keeler in Michigan regarding mercury content in gasoline. The study is not yet published.
• Suggestion to follow the New Jersey Department of Environmental Protection study regarding emissions by electric arc furnaces from the incineration of appliances and automobiles. The study is not yet published.
• Suggestion to evaluate monitoring data from other states.
• Suggestion to obtain paper by Anthony Carpi, a student at Cornell to become a part of the review.
• Suggestion to obtain data on how much sludge is being incinerated in the state and how much is being land applied.
• Suggestion by Neil that he could obtain a UVM intern beginning in September to put together a status report from a data review to use to evaluate future potential work by the Committee regarding mercury monitoring data.

2. Distribution of Fish Advisories

• 150 fish advisory notices were given to Neil from Dr. Bress.
• Sign maintenance staff in water quality are available to post the advisories up to September.
• Mr. Kamman contacted the education and outreach staff for fish and wildlife to advise his intentions for posting the advisories.
• Suggestion to notify the Commissioners of the Department of Environmental Conservation and Fish and Wildlife prior to any distribution.
• Mr. Kamman drafted a memo to the Commissioners for the Committee to approve.
• Concern that the advisories might create negative publicity for fishing.
• Currently advisories are only listed in fishing digest.
• Question as to whether there might be potential for other groups to post the advisories such as VPIRG, NGO groups, National Wildlife Federation, fish and gun clubs, etc.
• Question if more advisories would be available if there were others to post them. Dr. Bress indicated advisories would be made available.
• Suggestion to meet with Fish and Wildlife and/or Environmental Commissioner to express the Committee’s concerns.

• Neil Kamman encouraged the Committee members to evaluate the emissions inventory which was presented to the Committee by Bart Sponseller at its April meeting.
• Suggestion that the Committee further investigate the information regarding releases by automobile switches within the state.
• Suggestion that the Committee follow the progress regarding automobile switches of the Clean Car Campaign.
• The Committee was advised that Bart Sponseller was researching automobile smelter locations within the United States.

• Suggestion that the Committee pursue education and outreach regarding switch removal on vehicles and appliances.
• Suggestion that Committee follow work by NEWMOA regarding salvage yards as it is on their work plan for next year.
• Agency is evaluating a training program for salvage yards.

• Mercury Legislation
• S-91 did not pass – the bill was voted out of the Senate Natural Resources Committee and went into Appropriations – it never left Appropriations and was never voted upon on the Senate floor.
• Maine passed the notification section, bans on certain items, dental notification and the requirement that hospitals be provided with data regarding mercury content in products. The Department of Health would need to develop language for posters and pamphlets for the dental notification requirement.
• New Hampshire passed Notification
• Clearinghouse passed three states and NEWMOA directors agreed on how it would be established, funded, etc. NEWMOA’s will investigate methods to insure confidentiality. A grant for $50,000 was applied for through the EPA to fund the Clearinghouse.
• Hospitals
• Vermont hospitals were surveyed for their use and disposal of mercury products.
• Nine out of sixteen responded to the survey which was a joint effort by the Environmental Assistance Division (EAD) and the Vermont Association of Hospitals and Health Systems (VAHHS)
• Many Vermont hospitals have already joined "Pledge" programs established by the EPA and other organizations. Vermont’s efforts will be to provide assistance to hospitals to help them obtain the goals established under mercury reduction pledge programs.
• The EAD is working with the VAHHS to provide digital thermometers and the pamphlet currently being printed by the Health Department regarding fish consumption for pregnant women and nursing mothers. There remains a need for additional funding of this program in order to supply the thermometers in the new parent packets to be distributed through the hospitals.
• Grocers
• The Agency recently mailed letters to approximately 1,100 of Vermont’s grocers to encourage them to voluntarily pledge to discontinue the sale of mercury fever thermometers in their stores once those in stock were sold.
• The deadline for response by the grocers is July 9, 2001 and the EAD has already received over 100 pledges.
• Question regarding the use of mercury thermometers by fishermen to measure the temperature of the water prior to fishing.