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UNITED STATESAPERC Cover letter and Comments on 59th Report of the Interagency Testing Committee — February 21, 2007
APERC Bulletin - EPA FINALIZES NONYLPHENOL WATER QUALITY CRITERIA: Levels in US Waters Not a Cause for Concern - April 12, 2006
In February 2006, APERC submitted comments on the Beta Version of the CleanGredients database http://www.cleangredients.org/. The CleanGredient database is being developed with the intention of providing ecological and human safety data on ingredients used in industrial and institutional cleaning products.
APERC's comments highlight the following points:
- NPEs and their biodegradation intermediates meet the CleanGredient criteria for acute aquatic toxic, biodegradation.
The aquatic toxicity of NPEs used in cleaning products fall into the lowest Global Harmonization System (GHS) for Classification and Labeling category of concern (Level III) (LC50 > 10 ppm). In addition biodegradation studies have documented that NPEs and their degradation products are ultimately biodegradable (>60 mineralization within 28 days when tested in OECD 301B and 301F)
- NPEs are among the most extensively studied surfactants available.
- Current uses of NPEs do not pose a risk to the aquatic environment in the United States.
NPEs and their degradation products have been the subject of extensive environmental monitoring, which has shown that in 99% of US surface waters aggregate levels of these compounds, adjusted for their relative toxicities, are below EPA's recently adopted ambient chronic WQC for NP.
Washington State Removes NP from PBT List
The Washington State Department of Ecology removed nonylphenol (NP) from its list of PBT chemicals in a final rule on persistent bioaccumulative toxic (PBT) substances (Chapter 173-333 WAC) that was effective on February 13, 2006.
The removal of NP was due primarily to comments which provided extensive data that support the conclusion that NP is not persistent or bioaccumulative. APERC encouraged Washington State to utilize a weight-of-evidence approach that considers the quality of data in its PBT assessments. Organizations that supported removing NP from the list included the Association of Washington Business (AWB), the National Council of Air and Stream Improvement, Inc. (NCASI), Northwest Pulp and Paper Association (NWPPA), and The Boeing Company.
To access APERC's November 18, 2005 comments and November 29, 2005 supplemental comments on the Department of Ecology's Revised Draft Washington State Rule, Chapter 173-333 WAC on Persistent Bioaccumulative Toxins (PBTs) (September 29, 2005) click on: November 18 Cover Letter, November 18, 2005 Comments, November 29 Supplemental Comments and Table.
Nonylphenol ethoxylates (NPEs) were highlighted in the cover feature of the January 2006 issue of International News on Fats, Oils and Related Materials (inform). The article provides an overview of endocrine issues and the global regulatory status of NPE surfactants.
inform, the monthly business and scientific publication of the American Oil Chemists' Society (AOCS), serves professionals interested in the science and technology of fats and oils, surfactants, detergents, proteins, oleochemicals and related substances.
This article was made available with the permission of AOCS and inform.
APERC Cover letter and Comments on EPA’s Design for the Environment (DfE) Environmentally Preferable Products (EPP) Green Formulation Initiative for Cleaning Products and on the Proposed Attributes for Surfactants in Hard Surface and Carpet Cleaners — March 10, 2005
APERC STATEMENT: A SECOND USGS STUDY IN COLORADO FINDS LEVELS OF NP ARE LESS THAN EPA’S PROPOSED WQC — February 28, 2005
November 2004 Update
There are no present or pending regulatory restrictions on the manufacture, processing or use of APs and APEs by the United States government. In 1996, US EPA evaluated the risk of nonylphenol (NP) and concluded that NP is generally not present at levels of concern in US waters. Early in 2004, EPA recommended an acute ambient Water Quality Criterion (WQC) for NP of 27.9 ug/l and a chronic freshwater criterion of 5.9 ug/l. These environmental standards are expected to be finalized in 2005.
Recent studies conducted by the US Geological Survey indicate that the trace levels of NP and nonylphenol ethoxylates (NPEs) generally found in US rivers and streams are in line with the findings of previous studies and are with few exceptions below the draft WQC for NP. Given the widespread use of NP/NPEs, these results likely reflect the compound’s treatability and biodegradation as well as the use of good disposal practices and the high standard of wastewater treatment in the United States.
It is relevant to note that EPA WQC values do not represent enforceable regulatory limits; rather, these values are considered in the adoption of state level water quality standards used in setting industry and municipal wastewater treatment facility specific discharge permits.
APERC wholeheartedly endorses EPA’s efforts to establish WQC for NP. Click here to view APERC’s comments on the draft NP WQC.
EPA published a draft Environmentally Preferable Purchasing (EPP) Greening Guide for Cleaning Products for public comment on June 30, 2004 (69 FR 39471). The purpose of the Guideline is to advise purchasers for the federal government about environmental factors to consider in selecting cleaning products. Unfortunately, the draft EPP Guide for Cleaning Products includes unsubstantiated and misleading information about alkylphenol ethoxylates as well as unsubstantiated approaches for the evaluation of environmentally preferable cleaning products. APERC submitted comments, which urge EPA to remove the draft Guide from its website until such time as the Guide has been reviewed in accordance with the Agency’s Data Quality Guidelines.
APERC Comments and Attachment on EPA's January 5, 2004 Notice of Availability of Draft Aquatic Life Criteria Document for Nonylphenol and Request for Scientific Views – April 5, 2004
Supplemental Comments – June 25, 2004APERC BULLETIN: EPA PROPOSES WATER QUALITY CRITERIA FOR NP – January 22, 2004
INTERAGENCY TESTING COMMITTEE DROPS 20 ALKYLPHENOL AND ETHOXYLATES – September 19, 2002
The Interagency Testing Committee (ITC) under the Toxic Substances Control Act recently announced the removal of 20 alkylphenol and alkylphenol ethoxylate compounds from its Priority Testing List as a result of information supplied by APERC (see the ITC 50th Report at http://tsca-itc.syrres.com/Reports/).APERC meets regularly with ITC to provide research updates on alkylphenols and ethoxylates. The ITC is composed of scientists representing over 20 US federal agencies including the Environmental Protection Agency, the Food and Drug Administration, the Department of the Interior, the Department of Agriculture, the National Science Foundation and the National Institute of Environmental Health Sciences.
For more information about the ITC visit http://www.epa.gov/opptintr/chemtest/whatitc.htm. For more information about alkylphenols and their derivatives visit www.aperc.org.
NONYLPHENOL FOUND NOT PERSISTENT OR BIOACCUMULATIVE - September 19, 2002
Washington State recently announced that nonylphenol has been removed from its draft list of persistent, bioaccumulative and toxic substances (PBTs).Driven by data submitted by APERC, the state's Department of Ecology determined that nonylphenol, which is widely used to make industrial surfactants and cleaning agents, is nether persistent nor bioaccumulative. Specifically, the Department found that for nonylphenol: 1) the regional half-life value is below the criterion used to assess persistence; and, 2) the bioconcentration factor is below the criterion used to assess bioaccumulation potential.
Following publication of the original PBT working list of more than 50 substances, research data demonstrating that nonylphenol is not persistent or bioaccumulative was submitted to the state's Department of Ecology by APERC, the industry's principal research group on health, safety and environmental issues.
Further details on the Washington State PBT list can be found in "Ecology PBT Working List: Responses to Public Comments on Appendix E" on the state’s website: www.ecy.wa.gov/biblio/0203030.html.
STATEMENT ON USGS STUDY – April 9, 2002
RISK ASSESSMENT REVIEWS OF TRIS(NONYLPHENYL) PHOSPHITE (TNPP): European Union and United States – June 20, 2001
PRESS RELEASE: NEW U.S. CANADA GUIDELINES TO LIFT REGULATORY "CLOUD" OVER NONYLPHENOL ETHOXYLATES: NPE USERS TO RECEIVE NEW COMPLIANCE TOOL – March 21, 2000
ENVIRONMENTAL MANAGEMENT PROGRAM
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