Dental Industry Finalises Position In Minamata Ratification
24th Mar 17
The dental industry's advice to the Australian Government is that the Minamata Convention should be ratified and the proposed national campaign to promote amalgam separators should also focus on collection and processing of the waste.
Key Issues For The Dental Industry —
As the peak business organisation representing dental product manufacturers and suppliers, the Australian Dental Industry Association (ADIA) was invited by the Australian Government to tender advice and guidance on the exposure draft of the final regulation impact statement on the ratification of the Minamata Convention on Mercury released by the Department of Environment and Heritage. This document assesses the importance of ratification from an environmental perspective, policy options post-ratification, and the likely costs to business.
This issue is of profound importance to the dental industry as mercury is a constituent element of dental amalgam.
In ADIA's response to government, the Association has backed the position of the World Health Organization (WHO) which believes that mercury is one of the top ten chemicals of major public health concern and that dental amalgam waste, when rinsed into sewage systems or disposed of as municipal waste, is a source of mercury pollution that is readily avoidable. It is in this context that ADIA supports ratification of the Convention.
In terms of Australia’s obligations post-ratification and policy associated with securing these outcomes, ADIA provided the following observations and recommendations to the Australian Government:
Preferred Approach —
The Australian Government canvassed four policy options ranging from do nothing to a series of inter-related measures affecting many industries, including the dental industry.
The Australian Government's preferred approach, and the one that it has sought comment on, proposed that after ratification the Australian Government supported by state/territory government runs a national communications campaign promoting voluntary installation of dental amalgam waste traps and separators. Additional measures include controlling: import and export of mercury and products containing mercury; manufacture of mercury and products containing mercury; mining for mercury; interim storage of mercury; emissions of mercury to the atmosphere; releases of mercury to land or water; and management, recovery, recycling, reclamation, and reuse of mercury.
ADIA has supported this approach.
National Promotional Campaign Expansion —
ADIA has welcomed the Australian Government's proposed support for a national communications campaign to promote voluntary installation of dental amalgam waste traps and separators.
In its submission, ADIA has stated that the outcomes the Australian Government is seeking will be best served if the communications campaign includes advice to dentists and allied oral healthcare professionals on the need to ensure that the dental amalgam waste is collected for recycling.
Other Obligations Under The Convention —
Upon ratification Australia will have a number of obligations under the Convention that directly affect manufacturers and suppliers of dental products. These include: research and development of alternatives to dental mercury; encouraging dental professionals and dental schools to educate and train dental professionals on the use of alternatives to dental amalgam; restricting use of dental amalgam to its encapsulated form; and promoting best environmental practice in dental facilities to reduce releases of dental amalgam waste to water and land.
ADIA's advice to government referenced the fact that Australia’s dental industry has, for many years, been actively working to achieve outcomes in this area thus, from the perspective of dental product manufacturers and suppliers, ratification of the Convention is thought not to be an issue.
Mercury Import/Export Controls —
Under the Convention there is a commitment to the phase-down of dental amalgam; however, its continued use is permitted. In order to ensure that manufacturers of dental amalgam have access to sources of elemental-free mercury for dental amalgam production, ADIA has recommended that care be taken in the establishment of import/export controls so as to permit the continued international trade in mercury for this purpose to be continued.
ADIA believes that Australian Government's financial analysis contains an inaccurate assessment on the costs associated with Convention ratification insofar as dentistry is concerned. However, as the costs are likely to remain considerably lower than the benefits identified by the Australian Government, ADIA has no hesitation in supporting ratification.
ADIA believes that ratification of the Convention to be in Australia’s best interests from an environmental perspective — a comment made with the confidence that Australia’s dental industry is able to offer the alternative products and waste collection programs that are necessary for the nation to meet its obligations.
Member Engagement —
Businesses that manufacture and supply dental products drive ADIA's policy advocacy priorities and, with respect to issues associated with the use of dental amalgam members convened under the auspices of the ADIA Reference Group - Minamata Conventon Ratification to provide advice and guidance to ADIA staff responsible for negotiating outcomes with the Australian Government, with updates provided at the quarterly ADIA State Branch Briefings. If your business has an interest in this matter, get involved today.
Further Information —
For further information for ADIA's activities to support dental product manufacturers and suppliers in this area contact the ADIA Advocacy Team via email at firstname.lastname@example.org. To keep up to date follow ADIA on Facebook at www.facebook.com/dental.industry or subscribe to the Twitter feed @AusDental.
Currency Of Information & Disclaimer —
This update was issued on 24 March 2017 and please note that changes in circumstances after the publication of material or information may impact upon its accuracy and also change regulatory compliance obligations. The statements, regulatory and technical information contained herein are believed to be accurate and are provided for information purposes only. Readers are responsible for assessing its relevance and verifying the accuracy of the content. To the fullest extent permitted by law, ADIA will not be liable for any loss, damage, cost or expense incurred in relation to or arising as a result of relying on the information presented here.
This publication is available for your use under a Creative Commons Attribution 3.0 Australia licence, with the exception of the ADIA logo, images and where stated.
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