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186 A Environ. Sci. Technol.. Vol. 28. No. 4, 1994
0013-936X/94/0927-186A$04.50/0 @ 1994 American Chemical Society
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OF P O L Y M E R S PA and regulatory agencies worldwide have published approaches to the ecological assessment of chemicals under regulations such as the US. Toxic Substances Control Act (TSCA), the U.S. Federal Insecticide, Fungicide and Rodenticide Act, and the European Economic Communities (EEC) Directive of Classification, Packaging, and Labelling of Dangerous Substances. Articles on regulatory ecological risk assessment and on determining toxicity to aquatic species have recently been published (1, 2).Regulatory guidance on aquatic risk assessment of nonpolymers such as surfactants, pesticides, or solvents is not new. However, the assessment and regulation of synthetic polymers is significantly different from that for nonpolymers. Synthetic polymers tend not to he readily absorbed by organisms, and the toxicity associated with some polymers may he substantially altered by key aquatic components. For example, the aquatic toxicity of detergent or water treatment polymers can he altered according to the levels of calcium and magnesium (3) or humic acid (4,s) typically used in laboratory tests. There is a specific need to ensue that aquatic test systems adequately represent polymer toxicity during environmental testing of new products. Recent feature articles in ESbT have outlined broad approaches to pollution prevention through life cycle assessment and ecological engineering (6, 7).In addition, “stagegate” systems for new product development have been widely adopted by manufacturing industries to manage research and development (R&D) of products such as new polymers (8).
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x t s because there are inherent .dvantages to a balanced ecological assessment program for commercial products (9).These advantages include reduced potential product liability and enhanced environmental protection throueh ” earlv orediction of unreasonable environmental product characteristics. Business rowth opportunities exist in enironmentally compatible prodicts if processes for ecological isk assessment are truly aligned vith new product R&D. Efficient ianagement of environmental ssessment is clearly prudent in light of the high cost of environmenial support. U.S. industry is spending approximately $10 billion per year overall on R&D toward environmental opportunities on top of significantly higher costs for compliance with environmental laws (10). Any process for R&D should be defined in terms of when key information should be obtained as well as what information should be obtained. A generic paradigm has been developed through joint efforts by industry, academia, and EPA to provide a framework for ecological risk assessment (1 I).Consistent with this framework, the following process outlines when information should he obtained (in this case, in coordination with husiness needs and ecological risk management) and what should he obtained (relevant aquatic toxicity and exposure information). Business resource commitments increase considerably as products are moved toward scale-up (Le,, transfer of the manufacturing process to a facility) and commercialization (Le., sales of product to customer). Figure 1 shows the sug-
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Polymers that reach aquatic hahitats in significant volumes include those used in cleaning products, as dispersing agents in detergents, as wastewater flocculants, and in water treatment products for industrial cooling towers. Stage-gate systems are based on predefined development phases (stages) as well as decision criteria (gates), which can incorporate environmental issues for polymer products. This article describes a process for aquatic risk assessment during R&D of new polymers [see box). Coordination of assessment Assessment of ecological risks during product manufacturing, use, transport, and disposal is increasingly becoming a planning tool during the development of new prod-
Rohm and Haas Company Spring House, PA 19477-0904
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JOHN D. HAMILTON KEVIN H. REINERT MICHAEL 6, FREEMAN
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Environ. Sci. Technol., Vol. 28. No. 4, 1994 187A
gested points of initiation and completion of early aquatic risk assessment during a typical (Le., generic) new product development. To align new product development with environmental testing, the assessment should begin when the new polymer is sufficiently characterized in terms of chemical structure and is considered to he a viable product from a business perspective. The assessment should he completed in time to provide information for regulatory purposes, for environmental d e c i s i o n s related to c u s t o m e r needs, or both. For example, data for EPA TSCA Section 5 Premanufacture Notice
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