Civil Society Opposes Interference in Implementing Decision MC-3/2 (Dental Amalgam)

78 Civil Society Groups protested in letter to:

Monika Stankiewicz, Executive Secretary

Minamata Convention on Mercury

Geneva

Dear Executive Secretary Stankiewicz:

On behalf of 78 CSOs from 44 countries, thank you for your leadership to keep the Minamata Convention moving forward during this challenging past year. At COP3, the Parties agreed to an accelerated schedule for phasing down dental amalgam use and requested the Secretariat to prepare a compilation of submissions that address alternatives and successful amalgam use reductions (Decision MC-3/2).

We are aware that you have come only recently to the dental amalgam issue – in which some health organizations have a long record as polluters themselves. Civil society, therefore, urges you to consider the deep concerns raised by preparing the Decision MC-3/2 compilation document on dental amalgam “in close cooperation with the World Health Organization.”[i] While we acknowledge and appreciate that many signatories below have a close working relationship with the national and regional offices of WHO and recognize that UN agencies must cooperate in their respective missions, the actions of WHO headquarters in Geneva raise concerns. For example:

A WHO Bulletin article claims that the Minamata Convention merely “proposes nine measures to phase down the use of dental amalgam” and calls for “demonstrating the feasibility of voluntary implementation of the phase down of the use of dental amalgam.”[ii] In fact, far from voluntary, the Convention requires parties to “phase down the use of dental amalgam.”[iii]

To support its recent claim that “In rural settings, health facilities often lack a reliable supply of electricity and water, a necessary condition for the proper use of resin-based composites,” the WHO Bulletin article cites the 2016 UNEP document Lessons from countries phasing down dental amalgam use.[iv] But that statement cannot be found in the cited source – no doubt because it is dental amalgam that requires electricity while mercury-free techniques, like atraumatic restorative treatment (ART) that uses glass ionomer restoratives, were developed to overcome this very flaw of dental amalgam.

In its recent resolution on oral health[v], WHO-Geneva chooses to emphasize “preventative programmes” and developing alternatives via “focused research” despite overwhelming evidence that caries prevention programs do not eliminate dental amalgam use and alternatives are already so available that countries are banning dental amalgam. As seen at the COPs, WHO-Geneva also lobbies for expensive dental amalgam waste management equipment in countries with no infrastructure to collect, transport, and store dental amalgam waste.

Meanwhile WHO-Geneva appears to be unable to objectively recognize the successful phase down measures many developing countries are implementing, such as…

> Phasing out dental amalgam use: Nepal[vi], Philippines[vii], and Suriname[viii] have phased out dental amalgam use or announced plans for phasing out dental amalgam use.

> Ending dental amalgam use in children and other vulnerable populations: Mauritius[ix], Nepal[x], Philippines[xi], Tanzania[xii], Vietnam[xiii], and some Pakistani provinces[xiv] have ended or are ending dental amalgam use in children and other vulnerable populations.

> Ending dental amalgam use in programs: Bangladesh’s armed forces[xv], Indonesia’s national health insurance[xvi], and Mongolia’s ban on dental amalgam procurement[xvii] are ending dental amalgam use via these government programs. The Cameroon Baptist Convention hospital system’s network of dental clinics – which provided oral care to approximately 47,000 in 2016 – phased out dental amalgam use more than a decade ago.[xviii]

> Updating dental curricula: Bangladesh and Uruguay[xix] have updated their dental school curricula to focus on alternatives to dental amalgam.

> In Decision MC-3/2 on Dental Amalgam[xx] the Conference of the Parties specifically requested “the secretariat to prepare, by 30 April 2021, a document…”[xxi] The Parties further specified that the document be “containing the information received from parties pursuant to paragraph 2 of the present decision and the compilation of information pursuant to paragraph 4 of the present decision.” Parties and others openly submitted information for the Secretariat to compile. We commend the Secretariat for transparently posting these submissions on its website.[xxii] WHO-Geneva can transparently submit information as called for in Decision MC-3/2 to be posted on the website. No entity, however, should be permitted to interfere with the Decision MC-3/2 document via “close cooperation” behind closed doors.

We the undersigned civil society therefore request the Secretariat (1) prevent any interfering with the document referenced in Decision MC-3/2, and (2) undo any interference that has occurred – including work product that ignores submissions made or work product that adds interpretations not compiled from transparent submissions. If possible, we ask furthermore to permit Parties, non-party Signatories, and civil society to review the draft of the document before it is finalized to make sure that it is consistent with the submissions made to the Secretariat.

Thank you for your attention to these concerns of civil society.

Sincerely,

Charlie Brown,

World Alliance for Mercury-Free Dentistry on behalf of these 78 CSOs