{"id":4131,"date":"2015-01-15T16:40:19","date_gmt":"2015-01-15T21:40:19","guid":{"rendered":"http:\/\/blogs.edf.org\/health\/?p=4131"},"modified":"2024-02-12T11:01:40","modified_gmt":"2024-02-12T16:01:40","slug":"getting-under-the-surfac-tants-edf-comments-support-epa-regulations-to-limit-their-risks","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/health\/2015\/01\/15\/getting-under-the-surfac-tants-edf-comments-support-epa-regulations-to-limit-their-risks\/","title":{"rendered":"Getting under the surfac-tants: EDF comments support EPA regulations to limit their risks"},"content":{"rendered":"<p><a href=\"http:\/\/www.edf.org\/people\/lindsay-mccormick\"><em>Lindsay McCormick <\/em><\/a>is a Research Analyst<em>.\u00a0 <em>Richard Denison, Ph.D.<\/em><em>,<\/em> <\/em>is a Lead Senior Scientist<em>.\u00a0<\/em><\/p>\n<p>Today <a href=\"https:\/\/blogs.edf.org\/health\/wp-content\/blogs.dir\/11\/files\/2015\/01\/Final-EDF-Comments-on-NP-and-NPE-SNUR.pdf\">EDF submitted comments<\/a> supporting EPA\u2019s proposal to limit the use of two groups of toxic chemicals that have historically been widely used as, or to make, surfactants in consumer and commercial cleaning products.\u00a0 The chemicals, nonylphenols (NPs) and nonylphenol ethoxylates (NPEs), are produced in <a href=\"https:\/\/www.epa.gov\/assessing-and-managing-chemicals-under-tsca\/nonylphenol-and-nonylphenol-ethoxylates\">high volumes for a variety of industrial uses and consumer products, some of which have led to widespread water pollution<\/a>.\u00a0 The chemicals are highly toxic to aquatic organisms, and also pose significant potential human health risks.<\/p>\n<p>In October, EPA <a href=\"http:\/\/www.regulations.gov\/#!documentDetail;D=EPA-HQ-OPPT-2007-0490-0211\">proposed a Significant New Use Rule (SNUR)<\/a> for these chemicals that would require any company intending to begin manufacture or import of these chemicals to notify EPA prior to doing so, thereby allowing EPA to evaluate the risks associated with the proposed use of the chemical and to take action if appropriate.<\/p>\n<p>SNURs are one of the few regulatory tools that EPA has to seek to restrict the use of chemicals under the nation\u2019s outdated chemical safety law, the Toxic Substances Control Act (TSCA).<\/p>\n<p>While EDF\u2019s comments generally support EPA\u2019s proposed rule, they also raise some concerns. \u00a0Some highlights of our comments are described below. \u00a0<!--more--><\/p>\n<p><strong><em>Human health effects of NPs and NPEs<\/em><\/strong><\/p>\n<p>EPA\u2019s rationale for the proposed rule focuses exclusively on the aquatic toxicity of NPs and NPEs, despite good evidence and EPA\u2019s recognition in previous documents that these chemicals pose a risk to human health as well (see <a href=\"https:\/\/www.epa.gov\/assessing-and-managing-chemicals-under-tsca\/nonylphenol-np-and-nonylphenol-ethoxylates-npes\">here<\/a> and <a href=\"https:\/\/www.federalregister.gov\/articles\/2007\/09\/05\/E7-17542\/tsca-section-21-petition-on-nonylphenol-and-nonylphenol-ethoxylates-response-to-citizens-petition\">here<\/a>).\u00a0 NPs and NPEs are recognized as endocrine-disrupting chemicals, and data indicate they exhibit <a href=\"http:\/\/pubs.acs.org\/doi\/abs\/10.1021\/es102150z\">endocrine-disrupting properties in human cells<\/a> (in addition to aquatic species).\u00a0 NP exposure of laboratory mammals, used to model effects in humans, is also associated with <a href=\"https:\/\/www.epa.gov\/assessing-and-managing-chemicals-under-tsca\/nonylphenol-and-nonylphenol-ethoxylates\">reproductive and developmental effects<\/a>.\u00a0 Further, NP has been detected in human breast milk, blood, and urine.<\/p>\n<p>EDF\u2019s comments urge EPA to include mammalian toxicity studies and human exposure potential associated with NPs and NPEs in explaining its rationale for the proposed SNUR.\u00a0 This is needed to:<\/p>\n<ul>\n<li>provide a more robust basis for promulgating the SNUR;<\/li>\n<li>establish a broader and more defensible basis for evaluating proposed new uses of these chemicals for human health concerns; and<\/li>\n<li>highlight important data gaps for endocrine-disrupting effects in humans.<\/li>\n<\/ul>\n<p>EDF also urges EPA to prioritize steps to fill these data gaps, including through promulgation of a TSCA Section 4 test rule.<\/p>\n<p><strong><em>Taking action beyond the SNUR<\/em><\/strong><\/p>\n<p>Based on data from <a href=\"http:\/\/www.epa.gov\/cdr\/\">EPA\u2019s 2012 Chemical Data Reporting (CDR) program<\/a>, EDF has identified four NPs and NPEs that are currently manufactured in or imported into the U.S. at 25,000 pounds or more per year.\u00a0 The ongoing uses of these chemicals \u2013 by definition \u2013 cannot be addressed by the proposed SNUR.\u00a0 EDF\u2019s comments point out that their exclusion from the SNUR makes it all the more important that EPA clarifies what additional regulatory or other actions the Agency is planning to take to identify and address potential risks associated with these ongoing uses of NPs and NPEs.\u00a0 Although promulgation of a SNUR is a significant step forward, it is only one of a number of steps needed to reduce or prevent human and environmental exposure to NPs and NPEs.<\/p>\n<p>For more detailed information, please see the <a href=\"https:\/\/blogs.edf.org\/health\/wp-content\/blogs.dir\/11\/files\/2015\/01\/Final-EDF-Comments-on-NP-and-NPE-SNUR.pdf\">comments we filed today<\/a>.<\/p>\n<p>&nbsp;<\/p>\n","protected":false},"excerpt":{"rendered":"<p>Lindsay McCormick is a Research Analyst.\u00a0 Richard Denison, Ph.D., is a Lead Senior Scientist.\u00a0 Today EDF submitted comments supporting EPA\u2019s proposal to limit the use of two groups of toxic chemicals that have historically been widely used as, or to make, surfactants in consumer and commercial cleaning products.\u00a0 The chemicals, nonylphenols (NPs) and nonylphenol ethoxylates &#8230;<\/p>\n","protected":false},"author":50533,"featured_media":0,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[68,44,5009],"tags":[39986,68,39154],"coauthors":[],"class_list":["post-4131","post","type-post","status-publish","format-standard","hentry","category-epa","category-policy","category-health-science","tag-endocrine-disruption","tag-epa","tag-test-rule"],"acf":[],"aioseo_notices":[],"_links":{"self":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/4131","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/users\/50533"}],"replies":[{"embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/comments?post=4131"}],"version-history":[{"count":1,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/4131\/revisions"}],"predecessor-version":[{"id":12727,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/4131\/revisions\/12727"}],"wp:attachment":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/media?parent=4131"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/categories?post=4131"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/tags?post=4131"},{"taxonomy":"author","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/coauthors?post=4131"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}