October 10, 2001

Ms. Britt Erickson
Environmental Science & Technology
Washington, DC
Sent via fax: 202-872-4574

Re: "Estrogenic Seafood" (September 1, 2001, pp. 356 A - 357 A)

Dear Ms. Erickson:

The Alkylphenols & Ethoxylates Research Council (APERC) is composed of manufacturers, processors, users and raw material suppliers of alkylphenols (APs), alkylphenol ethoxylates (APEs) and other derivatives. For the past 13 years, APERC and its predecessor organization, the Alkylphenols and Ethoxylates Panel of the Chemical Manufacturers Association, now the American Chemistry Council, have been conducting research studies and providing science-based information regarding the health and environmental safety of APs and APEs including the nonylphenol, octylphenol and their ethoxylates mentioned in your article.

Regarding the article, there is published data that demonstrates nonylphenol (NP), octylphenol (OP) and their ethoxylates (NPEs, OPEs) are highly biodegradable materials that are effectively removed in well-functioning biological sewage treatment plants. ¹ Where effective sewage treatment exists, levels of these materials in receiving water are low, even in streams receiving a considerable input of industrial wastewater.²

Studies of overloaded, and hence poorly functioning, biological treatment plants in Switzerland have demonstrated lower removals.³ Comparison of treatment plant operating performance, as measured by organic carbon removal, and NPE treatability showed a direct correlation. Consequently, finding NP and OP in the Adriatic Sea is an indication of overloaded and/or poorly functioning sewage treatment plants in the region.

Inadequate sewage treatment has important public health as well as environmental implications due to the release into the environment of human pathogens and innumerable potentially hazardous substances. The report by Fulvio Ferrara on the presence of dioxins, PCBs, pesticides and heavy metals in fish from the Adriatic Sea would appear to confirm this concern.

We would welcome the opportunity of arranging a time for you to discuss with our scientific and technical experts the environmental fate of NPEs and OPEs and how the presence of NP and OP in the Adriatic Sea indicates inadequate sewage treatment in the region.

Please let me know if I can provide any further clarification.

Sincerely,

Robert J. Fensterheim Executive Director

Literature Cited

¹ (a) Naylor, C.G. Textile Chem. Colorists 1995, 27, 29-33. (b) Naylor, C.G. Industrial Wastewater 1996, Sept/Oct, 61-65. (c) Bennie, D.T. Water Quality J. of Canada 1999, 34 (1), 103. (d) Mackay, L.G., Croft, M.Y., D.S. Selby and R.J. Wells J. of AOAC Int. 1997, 80 (2), 401-407.

² (a) Naylor, C.G., Mieure, J.P., Adams, W.J., Castaldi, F.J., Ogle, L.D. and Romano, R.R. J. Am. Oil chemists Soc. 1992, 69, 695-703. (b) Naylor, C.G., Williams, J.B., Varineau, P., and Webb, D. Proceedings: CESIO 4th World Surfactants Congress, vol. 4, 378-391, 1996. (c) Field, J. and Reed, R. Environ. Sci. Technol. 1996, 30, 3544-3550.

³ Ahel. M., Giger, W. and Koch, M. Water Res. 1994, 28, 1131-1142.

 

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