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Alkylphenols
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1.
Nonylphenols &Their Ethoxylates
International Nonwovens
Technical Conference
September 25, 2002
Cheryl Wizda
The Dow Chemical Company
3. Presentation Overview What are APEs?
What is the State of the Science on NP/NPEs?
What is the Regulatory Status of NP/NPE?
How Can the NPE Environmental Management Program Help ?
6. Alkylphenol Ethoxylates Highly efficient adsorption
Excellent emulsification and wetting
Excellent chemical & thermal stability, including good handling properties
Low color & odor,minimal by-products and impurities
Economical
7. Alkylphenol Ethoxylates
8.
What is the State of the Science on NP and NPEs?
9. NPEs are one of the most well-studied surfactant families Hundreds of animal toxicity studies
Various reports on human exposure
Numerous biodegradation studies under different treatment conditions
Numerous aquatic studies with NP/NPE/NPEC with dozens of species
Data on real-world environmental exposure and monitoring studies
10. Human Safety Normal exposure to NP/ NPE does not pose a significant risk to human health
No link has been established between NP/NPE exposure and any adverse effect on humans due to endocrine (hormone) disruption
11. Environmental Exposure NP/NPE are biodegradable.
NP/NPE do not build up in the food chain.
NP/NPE are not persistent, bioaccumulative and toxic (PBT) chemicals.
Preliminary assessment shows levels in biosolids should not be a concern.
12. Why is NP/NPE part of risk assessment studies? NP/NPE is a high volume surfactant family
Environmental levels of concern can exist where effluent treatment is inefficient or inadequate
NP/NPE is effectively (95%) removed from effluent in well-functioning secondary sewage treatment plants
Aquatic toxicity, not endocrine endpoints, drive risk assessment conclusions
13.
What is the Regulatory Status of NP/NPEs?
14. United States EPA Risk Management Findings
NP risk to aquatic organisms does not appear to be widespread in US waters
Wastewater treatment facilities are highly efficient in removing NP discharge
15. United States EPA Draft NP Water Quality Criteria (WQC) ~ 5.8 ppb
EPA and USGS data show levels are generally less than draft WQC
16. United States No present or pending regulatory restrictions on use
Broad approval for food contact and agrochemical applications under FDA & EPA
NP/NPE were recently removed from the Washington State PBT program
17. Japan Ministry of Environment conducted baseline environmental monitoring assessment and toxicity testing
Results consistent with other assessments
Levels found generally less than predicted no effect concentration
Concluded effects on humans is nil
Concluded more research needed
18. Canada NP/NPE declared CEPA Toxic (June 2001)
Risk Management phase in progress
EC to recommend instruments by June 2003 & finalize recommendation by December 2004
19. Canada CEPA Assessment Conclusions
Section 64(c)
No Danger to Human Health from Environmental Exposure -- NP/NPE are not considered a priority to reduce public exposure through control of sources that are addressed under CEPA
20. Canada CEPA Assessment Conclusions
Section 64(b)
No Danger to Environment on Which Life Depends -- NP/NPE are not entering the environment under conditions that constitute a danger to the environment
21. Canada CEPA Assessment Conclusions
Section 64(a)
NP/NPE are TME are entering the environment under conditions that have or may have an immediate or long-term harmful effect on the environment or is biological diversity
22. Canada CEPA Assessment Conclusions
Section 64(a)
NP and its ethoxylates from untreated or partially treated textile mills that discharge directly to the environment occur at levels that are likely to be causing harmful effects on aquatic organisms.
23. Canada CEPA Assessment Conclusions
Section 64(a)
Discharges from MWWT plants and pulp and paper mills contribute NP and NPEs to the environment at levels that are of concern at a limited number of sites.
24. Canada All risk management actions have the same environmental objective, which is to achieve ambient concentrations in Canadian waters that do not exceed the draft Canadian Water Quality Guidelines of 1.0 ug/L NP TEQ for freshwater and 0.7 ug/L TEQ for marine water, such that no adverse effects are likely to occur in the resident aquatic biota.
25. Substance and Sector Risk Management
26. ProposedRisk Management Goals NP/NPE containing products
Focus on cleaning & detergent products
Reduce use by 50% (2 yr) and 100% (5 yr)
NP/NPE in Textile Mill Effluent
Reduce use by 97 100% (Timeline TBD)
Pulp & Paper
Voluntary use reduction (Target and Timeline TBD)
Municipal Waste Water Treatment
Address NP/NPE at product level
27. EC Comments on Nonwovens processes
Given the nature of the processes involved, the water discharged from non-woven mills typically does not carry a significant pollutant load .
Pollution prevention planning will exclude mills involved in exclusively in the production of non-woven fabrics unless there are dyeing operations in the plant. Canada
28. APERC Position 100% substitution is an inappropriate goal for a compound that does not meet criteria for virtual elimination
Risk Management objectives should be based on Environmental EQGs
Environmental monitoring should be the primary measurement of risk management progress
29. APERC Position Substitution does not solve problems of poor practice and treatment
NPEs are already managed effectively in most situations
Environmental levels are generally only a problem in cases with inadequate treatment
Without adequate treatment all surfactants pose aquatic toxicity risk
30. APERC Position Technical feasibility and economic impact of reformulation has been underestimated
Higher use levels of alternatives can
Result in higher environmental bioloadings, particularly when treatment is inadequate
Result in higher cost of product, especially considering higher cost of alternatives
31. APERC Position Pollution prevention plans should be flexible rather than prescribing use reduction mandates
APERC EMP Guidelines can be used in specific high volume industries (i.e. TME, Industrial & Institutional Laundries)
APERC environmental monitoring program can be used as a risk management metric tool
32. Canada Toronto Sewer Use Bylaw
Passed by City Council June 2000
Regulates Industry Effluent Levels for NP/NPE
Drafted by WWF, not science-based
Levels based on analytical detection limit
Result is Defacto ban of NP/NPE
33. European Union EU Risk Assessment on NP/NPE
Conservative assumptions
Precautionary approach
EU Risk Reduction Strategy
Draft market and use restrictions for many NP/NPE applications in EU Parliament
Product level limits proposed
NP (0.1%), NPE (1%)
34. European Union EU Risk Reduction Strategy
35. NPEs in Nonwovens High value, high performance surfactant in nonwoven applications
Discharge to the environment from nonwoven applications estimated to be low
No restrictions expected in US
Opportunity for stakeholder input, particularly in Canada
36.
How Can the NPE Environmental Management Program Help ?
37. NPE Environmental Management Program Goals Promote Responsible Environmental Management
Provide Guidance on Pollution Prevention and Control
Complement Existing and Planned Regulations
Support the Continued Responsible Use of NPE
38. Operating Premise
Acceptable Environmental Concentrations of NP/NPE Exist and Are Achievable
In Areas Where Environmental Levels Are Below Acceptable Levels, Onerous Risk Management Measures Are Not Necessary
Substitution Will Not Solve Treatment or Practice Problems NPE Environmental Management Program
39. Alkylphenols& Ethoxylates Research Council Dover Chemical
GE Plastics
Great Lake Chemicals
Mitsubishi Chemical
Rhodia Inc. Rohm and Haas Co.
Schenectady International
Stepan Canada
Sunoco, Inc.
The Dow Chemical Co.
40. For More Information Alkylphenols & Ethoxylates
Research Council
www.aperc.org