nonylphenols their ethoxylates international nonwovens technical conference september 25, 2002 cheryl wizda the dow

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