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RE: Surfactants & "Green" Cleaners



Hi Bill,

Several of the issues you raise were addressed in the LLNL report
"Developing a Certification Protocol for Alternative Cleaning Chemistries."
We originally based the protocol on the typical de minimus levels of 1% for
noncarcinogens and 0.1% for carcinogens.  This was later changed to 0.01%
based on input from Ted Smith with the Silicon Valley Toxics Coalition.  He
stated that both the SCAQMD and the state of Massachusetts use the 0.01%
level.

As for biodegradability and residual toxicity, that will depend on where the
waste is discharged.  If you discharge to a POTW and you have enough
residence time, then the surfactants shouldn't be a problem. Even the more
toxic by-products should be eliminated.  If you are selling products for
outdoor field use, where discharge to a storm drain is likely, then you
would have a problem.  While many people who work for the POTWs will tell
you that the discharge of chemicals to the storm drain is prohibited, this
doesn't stop it from happening.

You may be interested in knowing that the USEPA and the CMA have reached an
agreement to screen and test more than 2,700 high production volume
chemicals for their health and environmental risks.  That's the good news.
The bad news is it will take six years just to conduct the screening.

As for the issue of potential endocrine disruptors and their impact on the
environment, it all centers on release and disposal.  A closed loop cleaning
system eliminates this concern.  Water and cleaner is reused, and the
removed soils can be shipped off for treatment.  However, if you have a
closed loop system, then you might want to question the whole need for
"green" cleaning agents.

Happy Holidays !

Mike.callahan@jacobs.com

> ----------
> From: 	Bill Green[SMTP:BGreen@ecolink.com]
> Reply To: 	Bill Green
> Sent: 	Sunday, December 27, 1998 1:31 PM
> To: 	p2tech@great-lakes.net
> Subject: 	Surfactants & "Green" Cleaners
> 
> We are in process of creating what we hope will be considered the "state
> of the art" line of institutional cleaners.  Of course, there are many
> opinions as to what products of this type may or may not contain (Green
> Seal, Santa Monica, State of MA, etc.).  We have studied these
> specification, and wish to pose the first of what may be many more
> questions to you, this very knowledgeable community:
> 
> It is our understanding that any ethoxylated surfactant can contain
> residual ethylene oxide or 1,4-dioxane as byproducts. These byproduct
> come not from the nonyl phenol (in the case of nonyl phenol ethoxylate
> [NPE] surfactants) or the alcohol (in the case of alcohol ethoxylate
> [LAE] surfactants) but from the ethylene oxide that is used in either
> type of surfactant. That would be true of either the nonyl phenol
> ethoxylate or an alcohol ethoxylate. 
> 
> While one option is to bypass the use of either NPE or LAE surfactants
> in favor of the sugar-derived surfactants we have run into performance
> challenges with that strategy.  Therefore we would like to utilize a
> small amount of either NPE or LAE.  Here is what we need to understand -
> 
> 
> If we DO use some nonyl phenol, and therefore end up with traces of
> ethylene oxide ( < 1 ppm) how would that be viewed by the regulatory
> community, and specifically California Prop 65?  Is there any
> distinction between an *ingredient* and a *contaminant*?  For example,
> many types of polymers contain small residual monomer (styrene, vinyl
> acetate, etc). Are these polymers all considered Prop 65 carcinogens
> just like the monomers? We do not actually know. 
> 
> What we are struggling with (and therefore asking you all to offer an
> opinion) is that there seems to be a qualitative difference between a
> deliberately added ingredient (typically in % range) and a contaminant
> (typically in ppm), especially if everything possible is done to reduce
> levels as low as possible and provided the contaminant isn't one that is
> highly persistent and bioaccumulates. 
> 
> Additionally there now appears to be evidence that nonyl phenol has been
> indicted as an endocrine disrupter.  Have any of you reviewed that data?
> Would anyone care to offer an opinion on the related biodegradability
> and aquatic toxicity issues, (apparently studies show that effluent from
> biodegraded NPE is more toxic to fish than effluent from biodegraded
> LAE, even though before degradation the LAE is *more* toxic to fish.)
> 
> While we have produced some fine cleaners without using any NPE or LAE,
> when it comes to industrial cleaning challenges, the naturally derived
> surfactants simply do not seem to do an adequate job.  We are trying
> hard to produce a line of products that exceed every adopted standard
> and set the bar for products of this type.  We welcome all of your
> comments.  TY!
> 
> Bill Green
> Ecolink
> bgreen@ecolink.com
> http://www.ecolink.com
> 770-621-8240
>