Phone: 202.419.1500
or: info@aperc.org
WHAT'S NEW
2012
European Decision to List para-tert-Octylphenol as "Substance of Very High Concern" is Not a Restriction on Marketing or Use in Europe — February 2, 2012
The European Chemicals Agency (ECHA) recently added para-tert-Octylphenol (ptOP) to the candidate list of Substances of Very High Concern (SVHC) under the European Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). It is important to note that identification of a substance as a SVHC does not constitute a restriction of its marketing and use in Europe. Rather, it is a means to communicate prioritization of that chemical for consideration for further assessment using a process called “authorisation” under REACH.Questions and Answers about the Listing of para-tert-Octylphenol as a Substance of Very High Concern — February 2, 2012
While the addition of ptOP to the SVHC list does not impose any restrictions on the marketing and use of ptOP in Europe, it does impart customer communication obligations on companies that manufacture, import or use the compound in the European Union (EU), whether on its own, or depending on its concentration, in preparations or articles. This Question and Answer Document is provided to clarify these communication requirements.
2011
Alkylphenols & Ethoxylates Research Council Questions Need and Basis for U.S. EPA Program to Assess Alternatives for Nonylphenol Ethoxylate Surfactants
(09-29-11)
Alkylphenols & Ethoxylates Research Council Statement on Greenpeace Laundry Reports
(09-12-11)
Industry Reacts Strongly Against French Assembly Proposal to Ban Alkylphenols and Other Classes of Chemicals
May 17, 2011
Alkylphenols & Ethoxylates Research Council Questions Need for EPA Program to Assess Alternatives to Nonylphenol Ethoxylates – February 9, 2011
The U.S. EPA recently announced that the Agency’s Design for Environment (DfE) Program will conduct an Alternative Assessment on nonylphenol ethoxylates (NPEs) in 2011 using draft Alternative Assessment criteria, which were released by DfE informally for public comment.1,2 The Alkylphenols & Ethoxylates Research Council (APERC) submitted comments on the criteria, which lack harmonization with other national and international hazard classification systems, and questioned the need for EPA to launch a program to assess alternatives for these compounds, which have not been shown to be a risk to human health or the environment.
In APERC's view EPA's characterization of NP and NPE as “compounds of concern” in the Agency’s Chemical Action Plan (CAP) for these compounds is simply not justified. The CAP document for NP/NPE is not scientifically robust, does not reflect the weight-of-evidence for the extensive data available for these compounds, and includes many oversights and inaccurate representations of the scientific weight-of-evidence for these compounds. Equally egregious is the Agency’s plan to use Alternative Assessment criteria, which have not been subject to full public review to determine their scientific validity, in order to “learn lessons” about assessing the relative safety of alternative compounds for compounds that have not been shown to be unsafe.
For more than twenty years APERC and its member companies have been actively engaged in the conduct and review of toxicological and environmental fate and effects research on NPEs and their environmental degradation intermediates; consequently, APERC can contribute considerable information and expertise relevant to the environmental and toxicological assessment of these substances. Based on APERC’s review of the data for NPEs and their degradation intermediates, including nonylphenol (NP), the scientific weight-of-evidence continues to support the safety of their current uses to the workers and consumers that use them in formulated products as well as to the environment.
- US EPA Office of Pollution Prevention and Toxics, Design for the Environment Program. (2010, November). Alternatives Assessment Criteria for Hazard Evaluation,” Available at http://www.epa.gov/dfe/alternatives_assessment_criteria_hazard_eval_nov2010_final_draft2.pdf.
- US EPA Press Office (2010, November 30). News Release (HQ): EPA Announces New Tool to Promote Safer Chemicals and Products.
2010
Maine Ignores Scientific Weight-of-Evidence and Governmental Assessments by Designating Nonylphenol and Nonylphenol Ethoxylates as Priority Chemicals – December 17, 2010
The Maine Board of Environmental Policy approved a regulation on December 16, 2010 that will designate nonylphenol (NP) and nonylphenol ethoxylates (NPEs) as "Priority Chemicals" under the Maine Regulation of Chemical Use in Children’s Products
While the Alkylphenols & Ethoxylates Research Council supports ensuring the safety of children, the Council and others from the Maine business community objected to the regulation of NP and NPE as Priority Chemicals on the basis that this regulation – and related legislation - are ill-founded to achieve the goal of safer children’s products and impose an unnecessary reporting burden on companies that do business in Maine.
Maine’s regulation of NP and NPE as Priority Chemicals out of concern for either human or children’s safety is out of step with other governmental conclusions and other states, which do not find these compounds to present a risk to children or adults. In addition, US EPA and other federal agencies already have programs in place to assess and regulate chemicals for their risk to children’s health
APERC Bulletin on Maine Priority Chemicals – December 17, 2010
APERC Statement on Revised CDC Results for OP – September 2010
EPA Chemical Action Plan for NP/NPE Lacks Scientific Rigor – August 19, 2010
EPA’s characterization of nonylphenol (NP) and nonylphenol ethoxylates (NPEs) as “compounds of concern” in the Agency’s recently released action plan for these compounds is not justified and does not reflect the weight-of-evidence for the extensive data available for these compounds. The Alkylphenols & Ethoxylates Research Council (APERC) looks forward to the opportunity to discuss the science related to these compounds with the Agency.
The Agency’s categorization of the NP/NPE action plan document as a “screening level review,” along with the caveat that it is based on “EPA’s initial review of readily available use, exposure, and hazard information” does not adequately excuse the lack of rigor in its development. Nor does the Action Plan provide an adequate basis for the expansive regulatory actions that it proposes. Click here to read APERC's full statement.
APERC Statement on EPA Test Results on NPEs – July 14, 2010
APERC Statement on NPEs in Oil Spill Dispersants – May 25, 2010
Last updated: February 15, 2012
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