M.A.R.S Blog Series on Correcting Misinformation about the EPA Regulation – Recycling Restrictions Part 2

M.A.R.S Blog Series on Correcting Misinformation about the EPA Regulation – Recycling Restrictions Part 2

Thank you for following our series on misinformation about the EPA Regulation. Our last blog introduced today’s topic, which is discussing a fable told by an amalgam separator manufacturer representative regarding shipping restrictions on amalgam separators.

Today’s segment, we are breakings down the facts to disprove the statements made by an ill-informed individual.

Finding the Truth Behind the Lies

Whenever M.A.R.S debunks misinformation, we try to provide third-party proof with our statements. In our research, we contacted multiple hazardous waste facilities, researched any documentation that may restrict the transportation of hazardous waste, and spoke with mercury experts. The following are our findings, proving what we have known all along, the LibertyBOSS is safe to transport as any other amalgam separator.

Mercury Amalgam Category

Our first task was to analysis the US Hazardous Material Shipping Standards (49 CFR 172.101). Upon our review, we had concluded that there are only three possible categories that amalgam could fall under; mercury, mercury compound (solid), or mercury contained in manufactured articles.

From there, we had to determine, based on many expert opinions, which category would most closely resemble amalgam.

Hazardous Materials Table

MercuryThe FedEx Ground Hazardous Material Table, allows up to one pound of mercury to be transported by ground (under the “mercury” listing).

If the contents of an amalgam separator were to be considered under the heading of “mercury,” there would have to be a two pounds of amalgam to generate even one pound of mercury. The average amalgam filling contains 50% of mercury. The average amalgam separator contains roughly 5% amalgam of the total material captured by the unit.

Even at an extreme consideration of an amalgam separator containing 10% amalgam, only half of that material would be mercury. Which would mean an amalgam separator with 10 pounds of captured material would only contain a half pound of mercury, well below the shipping standards.

Mercury Compound Solid – Our first guess (and the most restricted) was the Mercury Compound Solid. According to the EPA, “Mercury exists in three forms: elemental mercury, inorganic mercury compounds (primarily mercuric chloride), and organic mercury compounds (primarily methyl mercury).”

The mercury found in Dental Amalgam falls under the form of elemental mercury. Which means, when considering amalgam’s category in the 49 CFR 172.101 chart, it cannot be considered a mercury compound.

Mercury Contained in Manufactured Articles – This definition may be the most accurate description of amalgam and amalgam separators. If this were the case, there is no weight restriction, as long as the unit is packaged and the material is contained properly. M.A.R.S exceeds shipping requirements, as the LibertyBOSS is self-contained in a 3/8” thick high-density polyethylene shell, sealed with a 5 mil bag, and packaged in a double wall box. The LibertyBOSS is the most secure mercury shipping container

Points to Consider

The information in this segment is third-party empirical facts that prove that the LibertyBOSS can be shipped and recycled under current laws and restrictions. Our next segment will be reviewing obvious common sense arguments that should have occurred to the “amalgam separator expert” who started the misinformation.

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