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WHAT'S NEWOn June 22, 2007, Oregon Senate Bill 737 was enacted. The bill directed Oregon's Department of Environmental Quality (DEQ) to "conduct a study of persistent pollutants discharged in the State of Oregon and report the results of that study to an appropriate interim committee of the Legislative Assembly related to the environment by June 1, 2010." On March 2, 2009, the Oregon DEQ released a draft SB 737 Priority Persistent Pollutant List (P3L) Development Process Report for comment. APERC provided comments on March 27, 2009 regarding the prioritization methodology and criteria used by DEQ for listing compounds on the P3L and provided references for the numerous publicly available studies and governmental risk assessments that address the persistence, bioaccumulative and toxicity properties of some of the alkylphenols on the P3L, which support their removal from the P3L.
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
2009
Oregon Concludes Alkylphenols Are Not Persistent or Bioaccumulative - October 20, 2009The Oregon Department of Environmental Quality (DEQ) announced the state's final Priority Persistent Pollutant List (P3L) on October 20, 2009. All of the alkylphenol compounds that were listed on the draft P3L have been now been removed because DEQ concurred with other governmental assessments that concluded these compounds are not persistent or bioaccumulative.
The Alkylphenols & Ethoxylates Research Council submitted comments to OR DEQ on March 27, 2009 and July 31, 2009.
Additional information about the OR DEQ's decisions about alkylphenols and the final P3L is available on the OR DEQ website.
APERC Bulletin: APERC Responds to EPA Request for Comments - September 23, 2009
The Alkylphenols & Ethoxylates Research Council (APERC) submitted comments to the US Environmental Protection Agency (EPA) that support the continued safe use of nonylphenol (NP) and nonylphenol ethoxylates (NPE) in industrial laundries and other uses. A review of the extensive set of studies for NP and NPE, which are among the most comprehensively studied chemicals in commerce today, was provided.
APERC’s comments were submitted on September 15 in response to the EPA’s request for public input (Federal Register, 74, 28654-28662) on whether certain types of studies are necessary to reasonably assess the risk of NP and/or NPE to aquatic organisms. In addition, EPA asked whether exposure monitoring is necessary to assess the risk to industrial laundry workers that use detergents that contain NPE.
APERC provided a summary of the extensive ecotoxicity data set supporting the conclusion that additional testing on NP and NPE is not necessary. APERC’s comments provided a review of the recent ecotoxicity data for NP, which continue to support the ambient aquatic life water quality criteria (WQC) for NP that US EPA finalized in 2006.1 WQC are concentrations in water that, when met, will protect aquatic life.
A peer-reviewed paper by Klecka et al. (2007) found that 99% of NP concentrations in fresh surface waters are below the EPA chronic freshwater WQC and concluded that the likelihood of aggregate NP-equivalent surface water concentrations of NP, NPE, and other alkylphenol ethoxylates (APEs) exceeding the chronic EPA WQC for NP is low.2 The paper was based on data provided by 19 studies of US surface waters that were conducted over a 15 year period. The largest set of monitoring data was from studies conducted by the US Geological Survey (USGS).
APERC also submitted comments supporting the safe use of NPE in industrial laundry detergents, noting that a large majority of industrial laundries utilize automated chemical handling and delivery systems, which minimize worker contact with detergents, and therefore, also with NPE. In addition, worst-case calculations of worker exposure were provided for situations where workers manually load either liquid or granular laundry detergents into washing machines. These calculations indicated that worker exposure to NPE is very low and the corresponding safety factors are substantial, ranging from 46,000 to 30 million for worst-case exposures in the most likely exposure scenarios.
1 US Environmental Protection Agency (US EPA). (2006, February 23). Notice of availability of final aquatic life ambient water quality criteria for nonylphenol. Federal Register, 71 (36), 9337-9339. http://www.epa.gov/EPA-WATER/2006/February/Day-23/w2558.htm.
2 2 Klecka, G., Zabik, J., Woodburn, K., Naylor, C., Staples, C., & Huntsman, B. (2007). Exposure analysis of C8- and C9-alkylphenols, alkylphenol ethoxylates, and their metabolites in surface water systems within the United States. Human and Ecological Risk Assessment, 13 (4), 792-822.
On June 1, 2009, Oregon Department of Environmental Quality released its Interim Final Priority Persistent Pollutant List (P3L) as well as a report titled "Senate Bill 737: Development of a Priority Persistent Pollutant (P³) List for Oregon." Most of the alkylphenols on the original list were removed. APERC provided comments on July 31, 2009, providing data and explanations as to why 4-t-octylphenol and 2, 6-di-tert-butylphenol should also be removed from the P3L.
APERC Comments on the Connecticut Department of Environmental Protection Notice of Intent to Conduct a Triennial Review of Water Quality Standards (April 16, 2009) - Submitted July 15, 2009
APERC Bulletin: EPA Solicits Comments on Testing Needs for Nonylphenol and Nonylphenol Ethoxylates
June 17, 2009
On June 17, 2009, US EPA issued an Advance Notice of Proposed Rulemaking (ANPR) soliciting public comment on whether certain types of studies are necessary to reasonably assess the risk of nonylphenol (NP) and nonylphenol ethoxylates (NPEs) to aquatic organisms and, in certain limited circumstances, to industrial laundry workers.
This ANPR was expected as it was announced as part of EPA's response in 2007 to a Citizen's Petition filed by the Sierra Club and other nongovernmental organizations, including laundry labor unions. EPA's response at that time, which denied the majority of the requests in the Citizens' Petition, cited the extensive toxicological information already available for these compounds.
The Alkylphenols & Ethoxylates Research Council's review of the available studies for NP/NPEs continues to support our view that there is no need for additional testing to assess the risk of NP/NPEs and the Council will provide data supporting this view in comments to EPA in response to the ANPR.
EPA finalized ambient aquatic life water quality criteria (WQC) for NP in 2005.1 WQC are concentrations in water that, when met, will protect aquatic life. A peer-reviewed paper published in 2007 found that 99% of NP concentrations in fresh surface waters are below the EPA WQC of 6.6 µg/L.2 The paper by Klecka et al., presented a statistical analysis of monitoring data provided by 19 investigations of alkylphenol ethoxylates and their metabolites in US surface waters that were conducted over a 15 year period. The largest set of data was from studies conducted by the US Geological Survey (USGS). In addition, the weight-of-evidence provided by numerous existing studies on NP/NPEs in mammals support the human safety of these products in their current uses.
1 US EPA. (2005, December). Aquatic life ambient water quality criteria - nonylphenol. Final Report 822-R-05-005. Office of Water, US Environmental Protection Agency, Washington, DC, USA. http://www.epa.gov/waterscience/criteria/nonylphenol/final-doc.pdf.
2 Klecka, G., Zabik, J., Woodburn, K., Naylor, C., Staples, C., & Huntsman, B. (2007). Exposure analysis of C8- and C9-alkylphenols, alkylphenol ethoxylates, and their metabolites in surface water systems within the United States. Human and Ecological Risk Assessment, 13 (4), 792-822.
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