(2) Acclimation times for development of NTA biodegradation are long (weeks to months) and both acclimation times and degradation times appear to be highly variable. We should have more understanding of the factors influencing these processes.

(3) All bacteria that have been observed to degrade NTA to date, do so without the formation of long-lived intermediates (except as noted on page 14), giving ultimate products that are already present in the environment. However, the chance exists that some organism may degrade NTA by a different pathway giving an intermediate or product which is not so innocuous. (For example, see page 15.) The chance of this is increased by reliance on spontaneous development of NTA-degrading variants at each site where NTA is introduced.

(4) It is imperative that NTA be readily degradable in natural waters. The sewage studies cited in the report apply only to secondary sewage treatment plants and septic tanks. Primary plants will pass NTA right through.

(5) All of the rivers with demonstrated NTA-degrading ability are in the East Central United States. Might we be depending too much on "the nearly ubiquitous distribution of most bacterial species" (page 6)?

(6) Colonies of bacteria that can degrade NTA should be cultured before the introduction of NTA into general use. These could be used to innoculate sewage plants and natural waters as needed. This would lessen the risk of undesirable variants (item 3), should shorten acclimation times (item 2), and could insure against the possibility that some rivers cannot develop such strains on their own (item 5).

(7) Virtually nothing is known of the effect of NTA on salt water ecosystems (page 46). It has not even been established that NTA-degrading bacteria can survive under saline conditions. Until more is known, the discharge of NTA into salt water cannot be justified.

(8) No mention is made of the effects of NTA on higher plants. This could be important if NTA finds its way into the water table or if NTA-containing water is used for irrigation, both possibilities. Our files reference three such studies: J. N. Simons, R. Swidler, and H. M. Benedict, Plant Physiology, 37, 460 (1962); K. Matsuda, Nippon Dojo-Hiryogaku Zasshi, 39, 300, 305 (1968), Chemical Abstracts, 69, 105418, 105419 (1969); A. Wallace and E. M. Romney, Soil Science, 109, 62 (1970). Like other strong chelating agents, NTA influences the uptake of various metals into plants. But at relatively high dosage (above 50 ppm), NTA seems to have a growth-promoting effect not exhibited by other chelating agents. Plants studied include soybeans, rice, tomatoes, and corn. The information is too scanty to permit assessment of this effect.

(9) The arbitrary selection of projected 1975 usage makes no sense in the context of the problem. Had the Surgeon General approved NTA, the "maximal forseeable" (page 50) level of 1.25 billion pounds is a reasonable estimate of the 1975 demand for NTA. Whether production capacity could be built fast enough to satisfy this demand by then is problematic, but by 1980 usage would have almost certainly reached this level if not higher. It is senseless to talk of 500 million pounds (page 46), let alone 150 million pounds (page 1), as being environmentally safe when we have no intention of limiting use to this level.

In conclusion, the report is a good summary of most of the important material on the safety of NTA. The fact that much of this material is classified makes its presentation even more valuable.

I cannot endorse the approval of NTA for detergent use of a national basis. Considering the present evidence, I believe NTA should be approved for use in regions where wastewater is discharged into fresh water systems and, in addition, where phosphates pose a clear environmental threat. We must also continue to gather information and to periodically reassess the situation.

Yours truly,

FARLEY FISHER.

ARTHUR D. LITTLE, INC. Cambridge, Mass., November 22, 1971.

Senator MARK O. HATFIELD,
U.S. Senate Office Building,
Washington, D.C.

DEAR SENATOR HATFIELD: At the Hearing of the Subcommittee on the Environment of the Committee on Commerce chaired by Senator Spong, you introduced an ADL report on NTA into the record of the Hearings and, at that time, requested Farley Fisher, who testified before this Committee, to comment on

this report. Mr. Fisher has kindly sent me a copy of his response. If his letter is to be included, I would very much appreciate it if this communication also could be made a part of the record.

Mr. Fisher concludes that our report "is a good summary of most of the important material on the safety of NTA" and further concludes that he "believes NTA should be approved for use in detergents in regions where wastewater is discharged into fresh water systems and, in addition, where phosphates pose a clear environmental threat." In his letter he raises several questions:

With respect to the question concerning the interpretation of the last sentence in the Discussion section of our report, I thought the summary indicated that it is our opinion that the reintroduction of NTA in detergents would have a very low probability of environmental or human hazard. It is our opinion that the reintroduction of NTA should be accompanied by an environmental monitoring program to insure that the probable low levels are the real levels. Presumably the monitoring program would not need to be conducted indefinitely (except possibly in a few selected points) if the initial monitoring yields the expected low average levels of NTA in the environment.

With respect to the other issues, we would envisage a continuing research program on the safety aspects to further assure safety or, as would appear unlikely at this time, provide evidence for discontinuing the use of NTA.

Mr. Fisher seems concerned in points 1, 2, 3, 4, 5, 6, and 7 with the biodegradability of NTA. As indicated in our report, NTA has been found to be biodegradable in studies done in California, Michigan, Iowa, Canada, Sweden and in an in-use test in Suffolk County, New York. This suggests that organisms that degrade NTA are probably universally distributed. The low average levels (less than 25 ppb) found in the drinking water of Suffolk and Nassau County, Long Island, New York and the river and lake water of the Great Lake States during the use of NTA in detergents in these areas as well as similar preliminary data for Canadian water samples where NTA is in use indicate probable generally effective biodegradation on NTA in use situations.

With respect to estuarine waters, the only study we are aware of is that of Erickson, Maloney and Gentile, J. Water Pollution Control 42:R329-335, 1970 which indicated that microorganisms of estuarine water also are capable of biodegrading NTA. One of the purposes of having a monitoring program is to make sure that NTA is biodegraded in the various sections of our country and its coasts.

With respect to Mr. Fisher's point No. 8, an examination of the references listed therein indicates that the low probable levels of NTA in the water would again be without significant effect. A more detailed study in this area could, of course, be appropriately part of an on-going research program on the environmental effects of NTA.

With respect to point No. 9, Mr. Fisher agrees that the estimate of 1.25 billion lbs. by 1975 is reasonable. Adequate time for monitoring and research at the earlier lower usage levels would provide a basis for setting an upper limit of total use by 1975 if this is warranted.

In his letter he refers to the concern on possible carcinogenicity of NTA. It is indicated in our report that NTA has not been found to be carcinogenic in a long term study on rats. The Surgeon General and his advisors have indicated that the study was inadequate to prove that it was not carcinogenic which, of course, is true. It is impossible to prove even with much larger numbers of animals of several species that a material would not be carcinogenic for man. The test as done, however, would have detected the known carcinogens which are active by the oral route of administration as most of these were initially found to be carcinogenic with smaller animal populations at risk and at lower doses. As indicated in our report in the section on carcinogenicity, an experiment with NTA in another species, the mouse, is in progress using a mouse lung adenoma test system. This system has been shown to be sensitive to most of the known carcinogens studied. Preliminary indications are that NTA is negative for carcinogenicity in this test also. Thus the lack of positive evidence for NTA as a carcinogen in two species and the probable low levels in the environment suggests that this does not represent a hazard for man.

With respect to Mr. Fisher's comment in paragraph 4 concerning ADL's relationships with our clients, let me assure you that (1) we have to give them as objective and independent evaluations as possible without respect to their pos sible feeling of annoyance, and (2) compared to the National Institutes of Health and HEW, Procter & Gamble is a very minor client of ours.

71-179 72 pt. 23

I want to thank you for your kind words about ADL and, if you have any questions concerning the above matters, we shall be happy to attempt to answer them.

Sincerely yours,

CHARLES J. KENSLER, Ph. D.,
Senior Vice President.

Dr. FISHER. Let me point out that part of my statement that you quoted refers only to the carcinogenicity, not the general safety. There have been a large number of other tests done on NTA.

Senator HATFIELD. Interestingly, one section of their report deals exactly with that.

Dr. FISHER. The Proctor & Gamble study purports to demonstrate that, in fact, NTA is not carcinogenic. There are some procedural irregularities in the study to which the Surgeon General objects. I think the Surgeon General is being extremely cautious, but his objections, nevertheless, are valid. It is not my opinion that NTA is dangerous.

Senator HATFIELD. It is not?

Dr. FISHER. No; it is not.

Senator HATFIELD. I have no further questions.
Senator SPONG. Senator Baker?

Senator BAKER. Not dangerous to the environment or to people? Dr. FISHER. I believe that the data available demonstrates a reasonable degree of assurance that NTA is safe to both people and the environment, at least in inland areas. As I pointed out, there is no ironclad guarantee. In Canada, as I mentioned in my statement, where they are much more concerned with this problem of eutrophication than we appear to be here, they feel that NTA has been demonstrated safe enough to warrant the risk of using it.

I am inclined to agree with that position.

Senator BAKER. What is the relative danger to people, especially children, of NTA-based detergents and phosphate-based detergents? Dr. FISHER. The only question remaining on NTA regards the possibility that with long-term exposure, which will mean many years of use, it might prove to produce a cancer in human beings. We can do some animal studies to give us some idea of whether or not this is true, but, of course, until we actually use it on humans for many years, we will not know for sure whether or not this is the

case.

One study which was done indicated that it was safe; the objections raised to that study are valid objections. It does not mean that the conclusions of the study are necessarily erroneous. It just means that as of now they are unsubstantiated.

Senator BAKER. Two final questions: Do you foresee avenues available for the improved performance of nonphosphate detergents? and the counterpart question: do you see any avenues available for the precipitation of phosphates or recovery or neutralization of phosphates in disposal plants?

Dr. FISHER. With regard to the first question, the whole question of efficacy of a detergent is a very difficult one, because there are no accepted standards. It is a very subjective thing. Does the housewife like the way this detergent washes her clothes better than that detergent? It is one of those things which we have not been able to reduce to a more or less technical or scientific test.

Consumer organizations who are in the business of testing detergents have tested phosphate-free detergents since they first appeared on the market 2 years ago, and from the reports that I have seen, there seems to be a marked improvement in their performance over that period of time. How long this will continue. I don't know. But I think we can reasonably anticipate some improvement in the state of the art on the carbonate-based detergents. I am not trying to promote carbonate-based detergents; it is just that they happen to be what is on the market now. I certainly hope we can look for other alternatives that would be a little easier to control; it does take some care in formulating a carbonate detergent to make it safe.

I would hope the major manufacturers, who would have the resources to do this, would attempt to identify other phosphate alternatives. At the moment, only NTA is available.

With regard to the second question, the technology for phosphate removal from sewage is available. There are a few companies which are attempting to market such technology, and it can be done at reasonably low capital expenditure if you have an existing sewage treatment plant.

The operating costs for phosphate removal are relatively high compared to other sewage treatment, because it does require a chemical treatment.

Senator BAKER. How is it done in general terms? Is it the introduction of a chemical agent that would precipitate alkaline phosphate? Dr. FISHER. Effectively, it is a precipitating and coagulating agent. Senator BAKER. And I understood you to say that the capital cost if there is an existing sewage plant would be fairly small, but the operating costs for the chemical or the coagulant would be very high?

Dr. FISHER. Yes, sir.

Senator SPONG. I believe he said he was going to furnish us some information on that subject generally.

Senator BAKER. I would like to have that received and included in the record.

I would also like to include in the record a small pamphlet that I have been handed by my staff from the Whirlpool Co. which is packed with their new washing machines. It appears to provide an evenhanded comparison of the advantages of phosphate versus nonphosphate detergents.

Senator SPONG. Without objection.

(The material follows:)

"What is meant by 'phosphate pollution' of lakes and streams?"

Phosphates released into lakes and streams act as a fertilizer, stimulating the growth of algae and other water plant life. This excessive plant growth may choke the waterways and, as it dies and decays, may lower the oxygen content of the water. And lack of oxygen can kill the fish. This situation can speed up the natural aging process (eutrophication) by which lakes "die." "What are the sources of the phosphates being dumped into rivers and streams?" Leading ecology authorities indicate that in urban areas, about 25 to 50% of the phosphates are attributed to detergents; the remainder comes from agricultural fertilizers, human wastes, sewage, etc. In rural areas, the amount of phosphate pollution caused by detergents is even lower.

"Do detergent phosphates always pollute?"

Not always. If you live in an area where they are released into the ground instead of a body of water, they will fertilize the earth and aid the environment.

Also, some cities have sewage treatment equipment that will remove the phosphates and other pollutants from the water.

"What are the new 'non-polluting' detergents being sold today?"

They are detergents that do not contain phosphates. They were developed to eliminate one source of "phosphate pollution" of the nation's waterways. These non-phosphate detergents are based mainly on washing soda (sodium carbonate). "Will non-phosphate detergents clean as well as a detergent that contains phosphate?"

Laboratory tests indicate they will generally clean cottons as well as phosphate detergents if used in warm or hot water. Some of the non-phosphate detergents are not recommended for use in cold water (under 70° F.) because they are difficult to dissolve. Man-made fabrics, blends containing man-made fibers (such as polyester/cotton) and permanent press fabrics do not wash as well as they do in the phosphate detergents. These fabrics may become gray and dingy over a period of time. The exact length of time depends on water hardness and wash water temperature.

"What effects will these 'non-polluting' detergents have on my clothes?"

If your water supply has less than 31⁄2 grains of hardness, or, if you have a water softener-non-phosphate detergents should give good washing results. However, if you have hard water-and depending on the degree of hardness— non-phosphate detergents may affect your clothes in these ways:

Fading of bright colors, especially with man-made and blended fabrics such as permanent press.

• White streaks, spots, powdery residues or detergent lumps on colored items. This is especially noticeable on such items as black socks.

• A stiff, harsh feel to clothes, usually caused by a build-up of detergent precipitate which difficult to remove in hard water rinses.

• Spot fading, usually resulting from dry, non-phosphate detergent being dumped onto damp clothes as washer fills.

To avoid most of these problems, be sure detergent is completely dissolved before it touches your clothes. For best results, follow the directions on the detergent package.

"Can I use non-phosphate detergents on woolens or silks?"

It is not recommended. Most non-phosphate detergents are much more alkaline than the phosphate types. Highly alkaline wash water may felt, shrink or even dissolve woolens and silks.

"Are these non-phosphate detergents safe around children?”

Warning: keep out of the reach of children! Read the package label very carefully. Like all laundry products, these detergents must be stored where children can't touch them. Non-phosphate detergents contain soda ash which is very caustic. If swallowed, they can burn the mouth and throat and may cause permanent body damage. They can also cause permanent damage if they come in contact with the eye. So please read the label on the package and follow instructions carefully!

"If I switch to a 'non-polluting' detergent, will it affect my washer?"

It will, if you have hard water. The phosphates in detergents have been used to soften hard water. They combine with the lime and form a new material which will dissolve. This soluble lime-phosphate material will pump down the drain of a washer, leaving no deposits or scaly residue.

On the other hand, the washing soda material in non-phosphate detergents softens water by forcing the lime out of the water in the form of curd or residue. The result in your washer is a build-up of scale or powdery residue like the one you get in a tea kettle or steam iron when hard water is boiled. In this case, the scaly material builds up on the agitator, basket and other parts, as well as drain pipes.

"Can this scaly build-up cause damage?"

Definitely. First, the white deposit looks messy in an automatic washer just as it does in the tea kettle. Second, it can build up on washer parts (such as pump, agitator and filter) to the point where the parts eventually may not function properly. This scaly build-up can cause abrasion or wear of clothes as they rub against the agitator and tub.