Letters M PBDE information overlooked? Dear Editor: I am writing on behalf of the Brominated Flame Retardant Industry Panel (BFRIP) of the American Chemistry Council (ACC) in response to an article (“Rapidly Rising PBDE Levels in North America”) by Kellyn S. Betts that was posted December 7, 2001, on Environmental Science & Technology online (Environ. Sci. Technol. 2002, 36, 50A–52A). Betts failed to include significant information about polybrominated diphenyl ethers (PBDE) in her article, which we provided to her during an extensive interview and through supplemental background materials. For example, she did not clearly state that the term PBDE refers to an entire family of compounds that consists of more than 200 chemically unique substances. Only three PBDE-type flame retardants are manufactured and sold today, and each product has a different composition and unique applications. In addition, Betts incorrectly represented an upcoming workshop, Breast Milk Monitoring for Environmental Chemicals in the United States, as being “held” by the “industrial producers of brominated flame retardants”. In fact, the workshop is being held by the Department of Pediatrics, Pennsylvania State University College of Medicine and has received support from a broad array of interested groups, including the U.S. EPA, the Research Foundation for Health and Environmental Effects, the Nurses Leadership Council, Pennsylvania State University College of Medicine, the Department of Health and Human Services, and the Public Health Policy Advisory Board, as well as BFRIP. The commercially available PBDE products have been well studied, and additional studies are ongoing and under development. Independent bodies, both in North America and Europe, including the World Health Organization and the EPA, have compiled and evaluated a large amount of toxicology data on the commercially available PBDEs.
Moreover, the issues associated with a few of our products result from our commitment to open and credible evaluation and testing. We have conducted extensive research into the health and environmental impacts of our products and shared our findings with government agencies, the scientific community, and the public. Much of what we have learned demonstrates that our products help prevent fires with virtually no anticipated impacts on human health and the environment. Both environmental quality and fire safety are of critical importance to health and welfare. Both of these needs should and can be delivered to the consumer. Focusing on one or the other alone can lead to serious negative consequences. When action is needed, we have and will continue to work with other industries and regulatory agencies to see that the products we sell are made, used, and eventually discarded responsibly. For more information about PBDEs or other brominated flame retardants, please contact Wendy Sherman, at the American Chemistry Council; 703-741-5639; or via Wendy_Sherman@americanchem istry.com. COURTNEY M. PRICE Vice President, CHEMSTAR
In response . . . The main point raised in my article is that the levels of PBDEs in human breast milk appear to be rapidly rising in North America. Because this is not the first article Environmental Science & Technology has produced on PBDEs, it would have been inappropriate to provide a large amount of background information on the chemicals. That information is available in the older articles referenced in this latest article. KELLYN S. BETTS Associate Editor, ES&T
Industry should assist TMDL development Dear Editor: Expanding upon a previous article (“TMDLs at the Crossroads”) published in your journal (Environ. Sci. Technol. 2001, 35, 249A–255A), I wonder if the time has come for industry to step forward and assist their state agencies and EPA in completing the Total Maximum Daily Load (TMDL) backlog. Even if EPA and state officials make the changes to the TMDL process recommended in last year’s National Research Council report, Assessing the TMDL Approach to Water Quality Management, by refining designated uses, developing alternative and more appropriate water body listing procedures, and allowing adaptive management in their implementation, the remaining workload will still create monumental challenges to critical state resources needed to address watershed management issues. As EPA and other state and federal agencies contemplate next steps in the troubled TMDL program, community groups should exert pressure on industrial stakeholders to come forward and join the community in finding creative solutions where resources are scarce. With proper oversight and controls, why can’t industry assist development of TMDLs? Far too often, industry is satisfied with taking a back seat and letting regulatory agencies “do their thing”, but is regrettably quick to criticize and engage consultants or even seek judicial relief when the outcome is unfavorable or would simply cost too much. Instead, money spent on afterthe-fact consulting expertise and legal representation could be better focused on crafting a mutually beneficial solution at the start of the TMDL process. Whether it be additional focused monitoring, more sophisticated modeling that includes uncertainty analysis, or some other form of in-kind
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service, tremendous trust and good will could be generated that would serve industry well in the future. Industry, are you willing to be part of the solution or remain an element of the problem, albeit small in many cases? I’m certain that regulatory agencies would welcome the proposed partnership in the true spirit of the watershed movement. RAY C. WHITTEMORE Merrimack, NH
[email protected] Poorly functioning sewage treatment plants? Dear Editor: The Alkylphenols & Ethoxylates Research Council (APERC) is composed of manufacturers, processors, users, and raw material suppliers of alkylphenols (APs), alkylphenol ethoxylates (APEs), and other derivatives. For the past 13 years, APERC and its predecessor organization have been conducting research studies and providing sciencebased information regarding the health and environmental safety of APs and APEs, including the nonylphenol, octylphenol, and their ethoxylates mentioned in the article “Estrogenic Seafood” (Environ. Sci. Technol. 2001, 35, 356A–357A). Regarding the article, there are published data that demonstrate that nonylphenol (NP), octylphenol (OP), and their ethoxylates (NPEs, OPEs) are highly biodegradable materials that are effectively removed in wellfunctioning biological sewage treatment plants (1– 4). Where effective sewage treatment exists, levels of these materials in receiving water are low, even in streams receiving a considerable input of industrial wastewater (5–7). Studies of overloaded, and hence poorly functioning, biological treatment plants in Switzerland have demonstrated lower removals (8). Comparison of treatment plant operating performance, as measured by organic carbon removal, and NPE treatability showed a direct correlation. Consequently, finding NP and OP in the Adriatic Sea is an indication of overloaded and/or poorly functioning sewage treatment plants in the region. Inadequate sewage treatment has important public health and environmental implications because of the 90 A
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release into the environment of human pathogens and innumerable potentially hazardous substances. The report by Fulvio Ferrara on the presence of dioxins, PCBs, pesticides, and heavy metals in fish from the Adriatic Sea would appear to confirm this concern. ROBERT J. FENSTERHEIM Executive Director The Alkylphenols & Ethoxylates Research Council
References (1) Naylor, C. G. Textile Chem. Colorists 1995, 27, 29–33. (2) Naylor, C. G. Ind. Wastewater 1996, Sept./Oct., 61–65. (3) Bennie, D. T. Water Quality J. Canada 1999, 34, 103. (4) Mackay, L. G.; Croft, M. Y.; Selby, D. S.; Wells, R. J. J. AOAC Int. 1997, 80, 401–407. (5) Naylor, C. G.; Mieure, J. P.; Adams, W. J.; Castaldi, F. J.; Ogle, L. D.; Romano, R. R. J. Am. Oil Chem. Soc. 1992, 69, 695–703. (6) Naylor, C. G.; Williams, J. B.; Varineau, P.; Webb, D. Proceedings: CESIO 4th World Surfactants Congress, 1996, 4, 378–391. (7) Field, J.; Reed, R. Environ. Sci. Technol. 1996, 30, 3544–3550. (8) Ahel, M.; Giger, W.; Koch, M. Water Res. 1994, 28, 1131–1142.
In response … The state of the art on NP, and other APEs in general, is defined in the scientific literature. We believe that the “science-based” information is just that. The aim of our research was not the evaluation of the efficiency of the Italian sewage treatment plants. We were interested in the determination of APE levels in seafood, in order to assess the possible implications for human health and the environment. Furthermore, as reported in the literature, NP is a ubiquitous contaminant of water bodies, not only in Italy. NP is a compound of concern in the United States and in Europe. It has been included among the 32 priority substances for water environment within the European Union. It is also among the 11 hazardous substances, which, according to the European Directive 2000/60, will be banned within 20 years. FULVIO FERRARA AND ENZO FUNARI Istituto Superiore di Sanità Rome, Italy
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