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WHAT'S NEW
2008
Click here to view the article published in American Laundry News titled, "APERC to Host May 8-9 Webcasts on NPE Use in Laundry Industry" on April 30, 2008.Webcast Updates on NPE Issues for Laundry Industry
April 25, 2008The Alkylphenols & Ethoxylates Research Council (APERC) will host live webcast updates on recent issues and initiatives related to nonylphenol ethoxylates (NPEs) in the laundry industry on:
The webcasts will provide participants with presentations by expert speakers as well as the opportunity to ask questions.
- May 8 at 2:00 p.m. EDT
- May 9 at 10:00 a.m. EDT
Background
NPE surfactants have been work-horse ingredients in industrial and institutional detergents for over 50 years due to their excellent technical performance and cost-effectiveness. Over the past decade, NPEs have been the subject of regulatory scrutiny in Europe and Canada. This attention has resulted in market pressures to deselect these ingredients in the United States even though the available science supports their safety in their current uses – including laundry – when used responsibly and discharged using appropriate wastewater treatment.In the United States, NPEs are not subject to any use restrictions at either the federal or state level. Late last year, EPA’s Office of Pollution Prevention and Toxics (OPPT) rejected, almost in its entirety, a citizen's petition submitted by several organizations under the Toxic Substances Control Act (TSCA) that called for testing and regulatory controls on NPEs in detergents. APERC’s position is that the rejection was appropriate since there is no evidence that these compounds present a risk to laundry workers or the environment when used and disposed of properly.
Nevertheless, pressure to deselect detergents that contain NPEs continues in the United States, driven more by market forces than any real regulatory threat or safety risk. The APERC webcasts will provide a brief overview of the science that supports the safe use of NPEs along with up-to-date information on recent US initiatives related to NPEs in the laundry industry including: the citizens’ petition under TSCA, recently proposed legislation in Connecticut that attempted to ban NPEs in laundry detergent and cleaners and the voluntary EPA Safer Detergents Stewardship Initiative.
2007
APERC Statement on Fish Shoaling Study
December 17, 2007Researchers at Mount Allison University in New Brunswick are attracting media attention after claiming that nonylphenol (NP) might affect the “sense of smell” and shoaling behaviors in fish.1 However, these experiments have only been conducted in laboratory aquariums and there is no evidence that the exposure of fish to the concentrations of NP found in the environment affects the social organization or shoaling behaviors of fish or that it impacts the health of either individual fish or fish populations as a whole.
The Canadian scientists conducted a study to determine whether brief exposures to "permissible" levels of NP could disrupt shoaling activities in banded killifish, a fish commonly found in North American lakes. Shoaling is a social behavior in which fish swim in groups in search of food and also serves as an adaptive strategy against predators. Permissible levels, or regulatory limits, for pollutants in surface waters are appropriately based on concentrations at which a compound imparts any deleterious effects on the health (e.g., survival, reproduction, fitness of offspring) of aquatic organisms. Results of a statistical study of extensive monitoring conducted in US wasters suggest that, on a nationwide basis, the incidence of concentrations of NP in US surface water exceeding the USEPA chronic Water Quality Criterion for NP is extremely low.2
The Canadian researchers concluded that fish avoided other fish that had been swimming in water containing NP. Suzie Currie, one of the researchers said “You could liken it to when you eat garlic, you can smell it from someone else.”3
No correlation has been established between this purported “avoidance” based on temporary chemical cues and any deleterious effects in individual fish or fish populations. In fact, this study found that exposure to NP did not affect either the swimming speed of fish or ability to find food. In addition, the researchers found “the results are relatively short-lived,” lasting for under 6 to 12 hours.
The study of the impact of chemical cues on fish behavior is still evolving and the implications of the results of laboratory studies for fish populations in nature are not known. The real challenge will be to conduct these types of behavioral studies in the natural environment where the water contains numerous and constantly changing constituents, both natural and man-made.
NP has been used safely for over 50 years and is used in the manufacture of other compounds, such as nonylphenol ethoxylate (NPE) surfactants, which are used in a wide variety of industrial and institutional applications as well as in some consumer products.
- Ward, A.J.W., Duff, A.J., Horsfall, J.S., and Currie, S. (2007). Scents and scents-ability: pollution disrupts chemical social recognition and shoaling in fish. Proceedings of The Royal Society B.
- Klecka, G., Zabik, J., Woodburn, K., Naylor, C., Staples, C., and 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, 792-822.
- White, N. (2007, November 20). Researchers find common chemical could harm fish. The Boston Globe. http://www.boston.com/news/local/maine/articles/2007/11/20/researchers_find_common_chemical_could_harm_fish?mode=PF
Sierra Club Challenges EPA’s Response to TSCA Petition
November 23, 2007The Sierra Club and several other environmental and union groups filed a civil action on October 24 in the US District Court for Northern California challenging EPA’s response to the their Toxic Substances Control Act (TSCA) citizen's petition. The petitioners’ complaint seeks to have the courts overturn EPA’s denial of the majority of actions sought by the petition, which called for restriction and extensive testing on nonylphenol (NP) and nonylphenol ethoxylates (NPE).
APERC maintains that EPA’s response to the citizen's petition, which found that these compounds do not represent a risk to human health or the environment under the relevant sections of TSCA, was well grounded on extensive toxicological information. The Agency denied the petitioners’ calls for restrictions on the use or to label products that contain NP/NPE. In addition, EPA denied the petitioners’ request for six out of seven categories of testing. APERC is confident that the courts will similarly find that EPA’s decision not to initiate regulatory action in these areas was justified by both science and the law.
With regard to EPA’s decision to investigate whether there is a need for additional data on the chronic toxicity of short-chain NPE biodegradation intermediates, APERC welcomes the opportunity of addressing this issue and anticipates responding to any rulemaking activities initiated by EPA. APERC maintains that extensive health and environmental effects information exist on NP and NPE, in combination with EPA’s recently adopted Water Quality Criteria for nonylphenol, that documents that current uses do not present a risk to human health or the environment.
EPA Responds to Sierra Petition on Nonylphenol and Nonylphenol Ethoxylates
September 28, 2007On September 5, 2007, the US Environmental Protection Agency (EPA) published its response to a Citizens’ Petition filed by the Sierra Club and various other groups on nonylphenol (NP) and nonylphenol ethoxylates (NPE) (72 Fed. Reg. 50954). The petition sought to prompt EPA to initiate rulemakings that would require extensive testing on NP and NPE and impose restrictions on the use of products containing these compounds.
With just a few exceptions, EPA denied most of the petitioner’s requests:
- EPA did not agree that there was a need for most of the environmental and toxicological testing sought by the petitioners since the available data "do not provide a reasonable basis to conclude that NP or NPE pose an unreasonable risk to health or the environment." In its response, EPA cited its recent Water Quality Criteria for NP1 that provides the framework for ensuring that these compounds remain below safe levels in the environment.
- EPA concluded that the call for testing of mixtures of NPE "to fill the gaps" regarding additive toxicity to aquatic organisms was not necessary.
- Similarly, EPA did not agree there was a need for mammalian/human health effects testing, concluding, "[A] combination of existing human and animal studies provides a reasonable understanding of the metabolism of NP in humans."
- EPA maintained that conventional chronic toxicity studies are adequate to address the mammalian and environmental toxicity of NPE surfactants and their metabolites — including any reproductive or endocrine effects.
- EPA rejected the specific call for an epidemiology study of industrial laundry workers. The Agency concluded that because of the "low volatility and the negligible dermal absorption of NP and NPE, these industrial laundry operations would not present significant exposure potential."
One area of agreement concerned the possible need for additional information to better assess effects to aquatic organisms from chronic exposure to "short-chain" NPE. However, due to the complexity of the issues, the Agency decided not to put forth a testing proposal but instead to solicit public comment on a variety of testing issues as part of an Advance Notice of Proposed Rulemaking (ANPR) likely to be issued in late 2008.
The Alkylphenol & Ethoxylates Research Council (APERC) is generally in agreement with EPA’s response to the petition. APERC maintains that extensive health and environmental effects information already exists on NP and NPE and that this research demonstrates that current uses do not present a risk to human health or the environment. Concerning possible additional testing on short-chain NPE, significant information already exists on these compounds. Nonetheless, APERC welcomes the opportunity of discussing these issues and anticipates responding to the technical issues as part of its comments in response to the ANPR.
- US EPA. (2005, December). Aquatic Life Ambient Water Quality Criteria — Nonylphenol. Final Report 822-R-05-005. http://www.epa.gov/waterscience/criteria/nonylphenol/final-doc.pdf
Peer-Reviewed Paper Finds Concentrations of NP/NPE in US Waters Below EPA Water Quality Criteria
August 22, 2007A study published in the peer-reviewed journal - Human and Ecological Risk Assessment1 - found that 99% of nonylphenol (NP) concentrations in fresh surface waters are below the recently adopted US Environmental Protection Agency (USEPA) Aquatic Life Ambient Chronic Water Quality Criteria (WQC) of 6.6 µg/L.
The paper by Klecka et al., presents a statistical analysis of monitoring data provided by 19 investigations of alkylphenol ethoxylates (APE) and their metabolites in US surface waters that were conducted over the past 15 years. The largest set of data was from studies conducted by the US Geological Survey (USGS). The paper found that based on the frequency of detection in surface waters, 67% of all analytes were below the analytical detection limits. In addition, the authors conducted a conservative evaluation of concentrations of nonylphenol ethoxylates (NPE) and their biodegradation metabolites (NPEM) and found that 97% of the samples contained aggregate NP-equivalent concentrations below 6.6 µg/L, suggesting that on a nationwide basis there is a low probability that even aggregate surface water concentrations of NPE and NPEM (including NP) exceed the chronic WQC.
The Alkylphenols & Ethoxylates Research Council contends that these newly published results reaffirm that NP/NPE can be safely used and there is no need to adopt controls or other deselection initiatives for these compound.
SEPA’s WQC establish surface water concentrations of NP that, when met, will protect aquatic life. The WQC for NP were finalized in December 2005 and as such reflect recent scientific information about the ecological effects of this compound. The NP WQC are also protective of effects that might occur due to the weak estrogenic activity of NP. USEPA concluded that “the ability of nonylphenol to induce estrogenic effects has seldom been reported at concentrations below the freshwater Final Chronic Value of 6.5965 µg/L."2
1 Klecka, G., Zabik, J., Woodburn, K., Naylor, C., Staples, C., and 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, 792-822.
2 US EPA. (2005, December). Aquatic Life Ambient Water Quality Criteria - Nonylphenol. Final Report 822-R-05-005. http://www.epa.gov/waterscience/criteria/nonylphenol/final-doc.pdf.
Alkylphenols Industry Opposes Sierra Club Petition
August 7, 2007The Alkylphenols & Ethoxylates Research Council (APERC) filed comments opposing a petition by the Sierra Club and other groups that seeks to direct the US Environmental Protection Agency (EPA) to initiate rulemakings on nonylphenol (NP) and nonylphenol ethoxylates (NPE). APERC views the testing and control initiatives advocated by the petition to be unnecessary and a waste of taxpayer resources given the large number of relevant studies already available on these compounds and the lack of a demonstrated need to adopt restrictions on the manufacture and use of these compounds.
The petition was filed in accordance with the section 21 citizen petition provisions of the Toxic Substances Control Act (TSCA). In accordance with the 90-day statutory deadline, EPA must either grant or deny the petition by September 4, 2007.
APERC maintains that there are sufficient studies available for NP/NPE to establish the human and environmental safety of these compounds. In addition, EPA recently completed a comprehensive assessment of the risks associated with NP in support of a new Ambient Water Quality Criteria (WQC) developed pursuant to the Clean Water Act. The NP WQC provides the framework from which EPA, states and local authorities can ensure that these compounds remain below safe levels.
Moreover, many of the issues that the petitioners have raised are not specific to NP/NPE but rather are generic scientific questions that have been and will continue to be the subject of research by EPA, industry and the scientific community.
APERC contends that EPA should deny the petition in its entirety, particularly given the significant information available and the extensive effort that EPA has already devoted to reviewing NP/NPE. Additionally, the petition provides no new information to support a conclusion that TSCA regulations are necessary to protect human health or the environment.
NPE are chemicals that function as surfactants in many applications including detergents and cleaning products. NPE have been used for over 50 years because they are high performance, cost-effective ingredients. Extensive research has demonstrated that they do not present a risk to human health or the environment when used responsibly in their current uses.
To review the comments submitted by APERC in opposition to the Sierra Club petition click here.
WEF Publishes New WWT State of Science on Alkylphenols & Ethoxylates - July 31, 2007
The Water Environment Federation (WEF) just published a monograph titled, “Wastewater Treatment of Alkylphenols and Their Ethoxylates: A State of the Science Review” by Henryk Melcer, Gary Klecka, Hugh Monteith and Charles Staples (Order No. P07012, ISBN 978-1-57278-237-2).
Alkylphenol ethoxylates have been important surfactants for more than 50 years. These compounds have been the subject of considerable regulatory attention, primarily due to concerns about their aquatic toxicity. This new monograph reviews and summarizes the state of the science on the removal of alkylphenols and their ethoxylates in wastewater treatment systems, and provides guidance on strategies for optimizing and sustaining the performance of wastewater treatment plants.
The review is available from WEF on its Market Place website.
APERC Comments on the May 9, 2007 FR Notice Regarding the Safer Detergent Stewardship Initiative (SDSI) Program - July 9, 2007
On May 9, EPA published a notice seeking public comment on a planned Information Collection Request (ICR) on SDSI. APERC, has serious reservations about the scope, content and overall benefit anticipated from the SDSI program. It is APERC’s view that EPA has not established a need for SDSI and has not shown that the use of detergents or surfactants in general, or NPE surfactants specifically, pose a risk to human health or the environment. While EPA has suggested such a program is needed to assist in complying with the newly adopted federal Ambient WQC for NP, no where within the FR notice or the associated Supporting Statement, does EPA explain the rationale for this view. In fact the available monitoring results that have been collected over the past 15 years suggests that environmental levels are by and large already below the WQC for NP. APERC recommends that in revising its ICR for submission to OMB that EPA should undertake the following:
- Clearly articulate the environmental benefit expected from SDSI. APERC advocates that DfE review the available monitoring results on surfactants and their degradates and explain how a national recognition program that promotes the deselection of NPE will enhance compliance with the NP WQC.
- EPA should explain the relationship between SDSI and the other DfE sponsored programs, (such as the Formulators Initiative and CleanGredients) with emphasis on describing the additional benefit that will accrue from SDSI that is not provided by these other programs. EPA already has several programs directed at detergents and there has been no explanation of how SDSI relates to these other initiatives. These other programs appear more robust as they focus on the entire detergent formulation and not just the surfactant.
- Given the limited resources of the DfE office, EPA should provide a more realistic and comprehensive assessment of the Agency costs associated with developing and implementing the SDSI program. Based on the estimates provided in the Supporting Statement, it appears that EPA anticipates spending on average less than 6 minutes of time reviewing and validating each SDSI application. APERC is convinced that EPA has significantly underestimated the time necessary to effectively review each application and believes that a full accounting should be presented so that they can be considered in contrast with other DfE programs and the perceived environmental benefit anticipated to result from SDSI.
If the Agency decides to proceed with SDSI, APERC advocates that EPA should limit the program to detergents and other cleaning products and not expand to include all uses of surfactants. The FR notice and associated Supporting Statement are somewhat inconsistent in their characterization of the products EPA would like to be within the scope of SDSI with the Supporting Statement implying that certain product such as paints and inks, should be outside the scope of SDSI. At a minimum, EPA needs to clearly define and justify the type of products proposed for inclusion in SDSI. Once the Agency settles on the scope of products to be covered by SDSI, EPA should refine in its ICR, the estimate of the reporting and recordkeeping burden associated with respondents that are likely to seek recognition; EPA should also factor into the ICR the greater burden estimate that is likely to accrue to the potentially large number of entities that will need to review and consider the SDSI program irrespective of whether they decide to seek recognition.
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