Mercury Reduction From Crematoria Through Collaboration and the Development of Best Management Practices ______________

Mercury Reduction From Crematoria Through Collaboration and the Development of Best Management Practices _____________________________ Mark McMillan Colorado Department of Public Health and Environment

Looking to the Heavens For Answers: Mercury Emissions From Crematoria _____________________________ Mark McMillan Colorado Department of Public Health and Environment

Holistically Assessing Mercury Impacts Public Health Data Historical Mining Releases Water Quality Monitoring Env’l Pollution Permits Fish Consumption Data Air Quality Monitoring Computer Modeling Demographics Data

“Mercury-Free Colorado Campaign” Initiatives • Problem Characterization • Industry (Automotive Switch) • Dental • Consumer • Public Education and Outreach • Crematoria Pollution Prevention Champion Award Environmental Achievement Award 2005

Crematoria P2 Initiative • Dental Amalgam Known Mercury Source • Mercury Released When Fillings Are Volatilized • CO Inventory Identifies Crematoria as Significant Source • (largest source not addressed with rulemaking/P2) • At Least 100 Pounds Released Annually in Colorado • Prefer Pollution Prevention “Carrot” over • Regulatory “Stick” • Effort to Work with Representative Stakeholders to • Identify Best Management Practices

Crematoria P2 Initiative – Cont. • CDPHE Approach Successful When Applied to Other Sectors • In Response to U.S. EPA Request to See if: • 1- Strategies Exist to Limit Mercury Emissions • 2- Results are Transferable • Funding for Initiative Came from U.S. EPA • – Used for Contractor Support • About a Six Month Stakeholder Process

Crematoria Hg Initiative Task 1: Form “steering committee” from industry stakeholders Task 2: Review Hg emissions estimates Task 3: Identify “BMPs” for Hg reduction Task 4: Inform industry community Task 5: Report Task 6: Evaluate

Project Steering Committee • Committee Members – Colorado Industry Leaders, Dentists, P2 Engineers, Hg Experts, etc. • Committee Member Responsibilities: • Represent industry “community” • Provide technical input and “reality checks” • Educate peers to Crematoria Initiative

Options • No Action • Pollution Control • There is precedence for pollution control. • Other countries are imposing strict standards and the installation of control equipment on crematoria stacks • Equipment is very expensive ($175K to $700K+) • Pollution Prevention • Voluntary amalgam extraction prior to cremation • Became focus of stakeholder group

Goal: Balance Funeral Professionals Public Environment

Colorado Crematoria Mercury Emissions Estimate Assumptions based on literature review and research • 0.5 g of Hg per filling • 8.62 fillings per adult over 60 years of age • 25 percent of population edentulous • ~15,000 cremations in Colorado (CANA, 2005) - Figure Increasing Annually 48,685 grams or 107 pounds per year of mercury released from Colorado crematoria

Colorado Crematoria Mercury Emissions Estimate Assumptions based on literature review and research • 0.5 g of Hg per filling • 8.62 fillings per adult over 60 years of age • 25 percent of population edentulous • ~15,000 cremations in Colorado (CANA, 2005) - Figure Increasing Annually 48,685 grams or 107 pounds per year of mercury released from Colorado crematoria ~ 6,500 pounds nationally vs. 240 currently reported

Initial Plan • Test Voluntary Extraction & Collect Data • Number of teeth with amalgam fillings • Removal time • Removal challenges • Gauge public perspective • Create language for authorization upon voluntary agreement

For voluntary removal to work… • Families must voluntarily agree (organ donor concept) • Utmost respect for body must be maintained • Removal must be relatively easy • Technically • Short amount of time • Education long before and during process

Barriers • Technical Issues • Professional/ Industry Concerns • Social and/or Ethical Challenges

Barriers - Technical Issues • Methodology of Emission Estimates • - Sources of Data • - Assumptions • - Transparency • Control Technologies • - Costs • - Effectiveness of Control Technology • Tooth Removal • - Who? • - When? Pre-Embalming? Post? • - How? Training Needed? Tools Needed? • - Etc.

Barriers – Professional/ Industry • Making Recommendations, Decisions Based on Estimates • Removal of Teeth Seen as Possible Degradation of Body • “Tooth Removal Seen As Contrary to Training” • (Pacemaker Removal – Certain Comfort Level Exists) • Interestingly, Amalgam Removal Appeared Straightforward • “Informed Speculation” – Never Able to Fully Test Ideas

Barriers - Social Implications • Concern for Grieving Families in Making Decision to Remove • Concern for Public Perception of Industry • Generational Differences – • “Do What You Have To Do” versus “Excuse Me, Do What?”

Outcomes of Initiative • Furthered the Understanding of the Issue • - “Create Solutions, Not Problems” • - Solid Peer to Peer Involvement, Education • Stakeholders Chose Not to Proceed with Voluntary Initiative, • Whether Amalgam Removal or Control Technologies • Stakeholders Recommended Formal Regulation of Industry • for Mercury Control

Outcomes of Initiative – cont’d • REPORTS/PRODUCTS • Colorado Crematoria Mercury Report • Possible Trends in Crematoria Emissions Report • Control Technologies for Crematoria Mercury Emissions Report • Draft Fact Sheet for Crematoria Owner/Operators • OPPORTUNITIES • In Dialogue with National Trade Association (CANA) • Communicating Inventory Findings to U.S. EPA

Lessons Learned • For some in industry, mercury issue comes as surprise; • Industry not comfortable with change, but might listen; • Social and ethical concerns appear realistic; • National emissions inventory (U.S. EPA) needs to be revisited; • Technical aspects of amalgam removal must be answered; • However, “preparing” body for cremation is common • (examples: pacemaker, artificial limbs) • Organ donor concept gained some traction;

Where do We go from Here? • Use Reports to Develop Informed Next Steps • Technical • Social • Professional Challenges • Continuing Dialogue With Industry (CANA) • Open More Formal Dialogue with EPA on Inventory

Contact Information Mark McMillan, M.S. Colorado Dept. of Public Health & Environment Mercury and Environmental Problem Solving Programs 303-692-3140 mark.mcmillan@state.co.us

Supplemental Slides

Project Steering Committee Committee Members • Daren Forbes, Horan and McConaty • John Horan, Horan and McConaty • George Malesich, DMFDA President • Ray Ann Mori, Monarch Society • John Reindl, Dane County, Wisconsin • Martha Thayer, Mortuary Sciences School Director, Arapahoe Community College Also, CDPHE Staff and Contractor Support – P2 Engineers and Practicing Dentist

Project Steering Committee Responsibilities • Represent industry community • Provide technical input and “reality checks” • Review written materials • Actively participate in meetings and conference calls • Educate peers to Crematoria Initiative

Colorado Environmental Problem Solving • Is there an immediate, urgent, or significant human health risk, • potential for environmental harm or the potential for • significant environmental benefit? • Is there a well-defined set of impacts? • Is the problem recurring, or is there a cluster of concentration • of occurrences? • Is it within the agency’s role and jurisdiction? • Is it conceivable that success could be measured? • What are the public expectations in addressing the problem • and/or is the problem important to the public? • Would staff and stakeholders be willing to work on it?

Mercury Reduction From Crematoria Through Collaboration and the Development of Best Management Practices ______________