In one of its last acts as an agency of the previous administration, the Environmental Protection Agency signed a "Memorandum of Understanding" with the American Dental Association to promote the ADA's voluntary "best management practices" doctrine for handling amalgam waste in the dental office. (www.epa.gov/guide/dental) The agreement gives the ADA six months to file a baseline report on the current status of separator usage, and three years to report on progress toward increasing separator use among dentists. There is no provision to prevent local jurisdictions from imposing mandatory separator regulations.

Evidence presented at a Congressional hearing on July 8, 2008, demonstrated that the information that the new Memorandum seeks to develop is already known, and that voluntary compliance programs are only minimally effective. (http://iaomt.org/news/archive.asp?intReleaseID=280&month=9&year=2008).

The full text of the Memorandum is attached: