New Environment Canada Requirements for Dental Amalgam Waste
First printed in JCDA • July/August 2009, Vol. 75, No. 6, 424

July 31, 2009 - In April 2009, Environment Canada published a Proposed Notice in the Canada Gazette that detailed new requirements for dental practices regarding the release of mercury from dental amalgam waste.

Of particular significance, Canadian dentists who have not currently implemented best management practices for amalgam waste at their dental practice will be required to prepare and implement a pollution prevention (P2) plan in the months following the publication of the Final Notice, which is scheduled for December 2009.

However, if a dental practice currently follows amalgam waste best management practices — which include the installation of an ISO 11143 certified amalgam separator and the use of a certified hazardous waste carrier for the recycling or disposal of amalgam — or adopts these measures before the publication of the Final Notice, dentists will not be required to take any further actions.

Similarly, dental facilities that exclusively practise certain specialties will be exempt from the new Environment Canada requirements, because these practitioners do not generate sufficient quantities of amalgam waste. This exemption covers the specialties of oral and maxillofacial radiology, oral and maxillofacial surgery, oral medicine and pathology, orthodontics and dentofacial orthopedics and periodontics.

Background on Amalgam Waste Disposal

CDA has worked closely with Environment Canada on amalgam waste disposal for many years. After engaging in discussions with Environment Canada officials to inform them about how dentists use and dispose of amalgam in dental offices, CDA signed the Memorandum of Understanding on Canada Wide Standards (CWS) on Mercury for Dental Amalgam Waste in 2002.

The primary objective of these voluntary standards was for the dental profession to achieve a 95% national reduction in mercury releases from amalgam waste by 2005, from a base year of 2000. The profession has made significant strides toward achieving the CWS targets, due to the ongoing efforts of Canadian dentists.

In 2003 and 2007, Dr. Philip Watson and fellow researchers from the faculty of dentistry at the University of Toronto conducted a national survey of dentists in all provinces and territories in Canada, to collect information about the use and disposal of dental amalgam. In 2007, this study showed that 72.5% of dentists who place and remove restorations and practice clinical dentistry perform these procedures in offices equipped with ISO-compliant amalgam particle separators. This figure increased dramatically from 27.4% in 2003 and has likely increased even further since the report was published. During that same time frame, the amount of mercury entering wastewater streams decreased from 1,046 kg in 2003 to 452 kg four years later.

CDA has always supported a voluntary approach to the implementation of the CWS and encourages dentists to install an amalgam separator at their practice. The proposed Environment Canada notice, requiring dentists to prepare and implement a P2 plan in the absence of best management practices in amalgam waste disposal, preserves the voluntary approach of meeting the goal of a 95% reduction in mercury releases.

P2 Plan Requirements

P2 planning is a process that examines the current operations of an organization with the goal of developing a plan to eliminate or reduce pollution at the source. The P2 plan itself contains detailed information on the most efficient ways to prevent or minimize the creation or release of pollutants and waste, in this case to prevent mercury from dental amalgam entering the wastewater streams.

According to the new requirements, a dentist’s P2 plan would have to be prepared no later than 3 months and implemented no later than 6 months after the publication of the Final Notice expected in December 2009. Dentists could use a P2 plan already prepared or implemented for another purpose, but it must be revised to ensure that it meets all Environment Canada requirements. A copy of the P2 plan must remain at the location where amalgam removal and disposal takes place, namely the dental practice.

Dentists can request an extension of time in preparing or implementing a P2 plan, or apply for an exemption of one or more of the factors to consider, by submitting official request forms to Environment Canada. These forms will be available online when the Final Notice is published in the Canada Gazette.

Environment Canada has developed a handbook which provides information on the P2 planning process, a model plan template and detailed information on the appropriate pollution prevention practices and analytical techniques.

The following online resources are available for further guidance.

National Office of Pollution Prevention

Pollution Prevention Planning

Canadian Pollution Prevention Information Clearinghouse

Canadian Environmental Protection Act (CEPA) Environmental Registry

Questions on Amalgam Waste Requirements in Your Province?

Some provincial dental regulatory authorities, including Ontario and Saskatchewan, currently have regulations that require the installation of an ISO-compliant amalgam separator for dentists who place and remove amalgam restorations at their clinical practice.

For questions about amalgam waste disposal requirements in your area, please contact your provincial dental regulatory authority. Dentists can also consult the Dental Amalgam Waste section of the Environment Canada website at: www.ec.gc.ca/MERCURY/DA/EN/da-reqres.cfm?SELECT=DA.

For specific questions regarding P2 plans, please contact Ms. Marie-Hélène Lacasse in Environment Canada’s Waste Reduction and Management Division at tel.: (819) 934-6059 or email: marie-helene.lacasse@ec.gc.ca.