ALKYLPHENOLS & ETHOXYLATES RESEARCH COUNCIL
Position on Proposed Risk Management Goals for NP/NPE

The proposed Risk Management Strategy for Nonylphenols and Nonylphenol Ethoxylates (page 7) states:

All risk management actions have the same environmental objective, which is to achieve ambient concentrations in Canadian waters that do not exceed the draft Canadian Water Quality Guidelines of 1.0 ug/L NP TEQ for freshwater and 0.7 ug/L TEQ for marine water, such that no adverse effects are likely to occur in the resident aquatic biota.

While there are questions about these precise numerical values, APERC supports an objective that acknowledges that acceptable environmental levels of these compounds can be defined. As Environment Canada has recognized, NP/NPE do not meet the persistent, bioaccumulative and toxic criteria for "virtual elimination." Moreover, available research and monitoring data have demonstrated that effective chemicals management and wastewater treatment can achieve these water quality guidelines (WQG) in the environment. Indeed, available monitoring data in Canada shows that most areas already achieve levels below the WQG.

However, in describing how to achieve this objective, the draft Proposed Risk Management Strategy document recommends approaches that far exceed the controls necessary to achieve those numerical objectives. Instead of promoting a program aimed at reducing and maintaining environmental concentrations below WQG, the document recommends 100% substitution or a defacto ban on products containing NPE. Such an approach is inconsistent with Environment Canada's recognition that NPEs should be considered a "Track 2" substance and managed in accordance with a "life cycle management" program.

Promoting the reformulation or substitution of Track 2 CEPA toxic chemicals is wholly inappropriate unless it can be shown that other strategies will not achieve the WQG. The strategy document suggests that substitution and reformulation "reflect the best available techniques economically achievable (BATEA) that are readily available."

While it is recognized that alcohol ethoxylates as well as other surfactants can sometimes serve as effective substitutes, these products will not readily work in all situations and more importantly, reformulation could result in the introduction of other human health and environmental issues that have not been evaluated.

APERC believes it is critically important at this stage in the stakeholder process to define explicitly, the goals and objectives of the Risk Management Program. As such, APERC advocates that the stated objectives should be to achieve safe levels in the environment as determined by the WQG and not 100% substitution. Once the goals are defined, the Stakeholder process can be used to explore the ability of establishing risk management instruments that can achieve those objectives.

For additional information, contact:

Robert Fensterheim, Executive Director
Barbara Losey, Deputy Executive Director
Alkylphenols & Ethoxylates Research Council (APERC)
Toll Free: (866) APERC-NA

                                                                                                                             

 

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