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"What can I do about water pollution?"

Frankly, keeping our nation's waterways free of phosphate pollution by detergents and helping man win the battle against himself-has to be an individual decision. We've tried to give you the facts so you can judge for yourself. In addition, you should check for any regulations on detergents sold in your area. It comes down to this: clean water will cost more for some families than others. To summarize . . .

If you have soft water (0-31⁄2 grains)—you can get good washing results with a phosphate-free detergent with little or no effect on your clothes and without causing a scaly build-up in your washer.

If your home has hard water (over 31⁄2 grains), you should have a mechanical water softener if you want to use a non-polluting detergent and avoid any of the problems mentioned above. If you don't have soft water-your option is to use a regular or low-phosphate detergent that will meet the standards set forth by national, state or local governing bodies. Check before you buy.

Senator HATFIELD. Dr. Fisher, I have one final question. When you talk about labeling under the Hazardous Substances Act, are you familiar with the letter that Chairman Russell Train, Council of the Environmental Quality, wrote to Mr. Kirkpatrick of the Federal Trade Commission?

Dr. FISHER. Yes; I am.

Senator HATFIELD. Would you care to comment on the position taken by Chairman Train in asking that the labeling not be placed on the phosphate packages because of the danger that might develop with the use of caustic materials? Also, in the context of what you have said here this morning and your belief as to the danger of NTA or the lack of danger, how would you comment upon that?

Dr. FISHER. I believe that the labeling regulation proposed by the Federal Trade Commission is an inherently reasonable one, that is, the listing requirement that the Federal Trade Commission has proposed would require that all ingredients in a detergent, not just phosphate, shall be listed, and I think it is important. Such a listing would contain not only phosphate but would contain carbonate, if that is what the material had in it, and it would include NTA if that is what the material had in it, and the housewife who was concerned over any of these could readily identify what the ingredient of the detergent is. She cannot do this now unless the manufacturer chooses to tell her. Mr. Train seems to think that phosphate is the only thing housewives think about. I don't think that is true at all. Many housewives worry about other ingredients in detergents besides phosphates. Many people have complained to me, for example, that they are sensitive to enzymes, and how can they tell whether or not a detergent has enzymes. Some boxes say "with enzymes" or "without enzymes" in big letters on them. But if a box doesn't mention the fact, you cannot tell; maybe it does and maybe it doesn't.

I, therefore, think that Mr. Train has completely missed the point. The point is the consumer does have the right to know what he is buying and, therefore, the ingredients should be listed.

The Federal Trade Commission has also proposed a rather stern warning with regard to phosphate on boxes and there have been a lot of quarrels before the Commission as to the wording of that warning. I think this is a much more debatable question, and I am not really that anxious to single out phosphates as the only culprit in the world. But I do think that phosphate content should be listed along with the amount of everything else which is in the detergent.

Senator HATFIELD. Dr. Fisher, it goes beyond the question of the listing of the ingredients. It is a question of whether or not there is a warning to the consumer. Mr. Train feels that because phosphates are not the limiting nutrient-and in certain important types of water bodies phosphates are rarely the limiting nutrient, in salt waters and rapidly flowing rivers, and, therefore, if any warning statement were made, it would need to be set out in sufficient detail to describe accurately a very complex number of factors that cause eutrophication.

So, going beyond the question of whether this box includes enzymes or phosphates or whatever, let's get to this point of the warning to the potential customer. How would you respond to the rationale set forth here by Mr. Train?

Dr. FISHER. Mr. Train's objection is one which I have also raised in my statement; namely, there are many parts of the country where phosphates are not a serious problem and there is no reason for persons in these areas not to use phosphate detergents. If a warning is placed on a box, it perhaps should caution people that there are many areas where phosphate is innocuous, but there are also areas where the danger from phosphate use is serious. I think most people who live in one of these latter areas, at least where the problem is far advanced, are fully aware that they live in such an area.

I don't think that one need to go so far as to put a map of the United States delineating these areas on each package. A warning to the effect that phosphates may, which is what the FTC has proposed, or that in some areas phosphates do, would be an adequate qualification.

Senator HATFIELD. I have nothing further.

Senator SPONG. Senator Baker?

Senator BAKER. No further questions.

Senator SPONG. Thank you very much for your testimony.

The next witness will be the Honorable Jesse L. Steinfeld, Surgeon General, U.S. Public Health Service.

Dr. Steinfeld, we are very pleased to have you with us this morning.

STATEMENT OF HON. JESSE L. STEINFELD, M.D., SURGEON GENERAL, U.S. PUBLIC HEALTH SERVICE

Dr. STEINFELD. Thank you, Mr. Chairman.

Mr. Chairman and members of the committee, it is a pleasure to meet with you today to discuss recent actions taken to protect public health and the quality of the environment-actions which influence the choice of home laundry products available to the American housewife. In a period when product safety and consumer protection are rightfully-of deep concern to the people of this country, the subject of what goes into these laundry products and what effect these products have on people and their environment commands and deserves major attention.

Senator BAKER. The record ought to show that the Surgeon General moved the ash tray.

Dr. STEINFELD. The contents of home detergent products first became an issue when much of the blame for accelerated eutrophication or aging of lakes and streams was generally attributed to phos

phates as the most controlling nutrient and when it was determined that phosphates in detergent products were the most readily controlled source of this chemical.

Man's intervention in the natural process of eutrophication has caused a startling increase in the rate of deterioration. No one who lives near or depends on a body of water that is being destroyed in this way can be indifferent to it.

Far-reaching public action against phosphate detergents has resulted; and no-phosphate and low-phosphate home laundry products have burgeoned on the market, joining already available soap and washing soda products.

The Federal Government has always recognized that eutrophication, the role of detergent phosphates in eutrophication, and the potential hazards of alternative chemicals in home laundry products are complex issues. It is also evident that there is not a single cause of eutrophication of lakes and streams, nor a single solution. All avenues of potential solution to retard eutrophication must be explored; reduction of phosphates or elimination of phosphates in detergent products is but one of those avenues.

It is an oversimplification to equate the removal of phosphates from such products with an end to eutrophication and the death of our lakes and streams. Manufacturing, chemical fertilizers, and human waste are other major sources of this chemical.

The problem is not phosphate detergents; the problem is eutrophication of our environment.

Turning specifically to the content of the box that sits beside the washing machine at home, enlightened concern over pollution problems led to attempts to find acceptable substitutes for phosphates in household detergents. One such substitute is nitrilotriacetic acid (NTA).

Industry undertook a program to use NTA as a substitute for phosphates. However, although NTA was subjected to extensive testing, studies of the biological activity of NTA combined with heavy metals raised concern that projected uses of NTA-millions to billions of pounds a year-could constitute a hazard to human health. As a consequence, the major household laundry product manufacturers voluntarily discontinued use of NTA in the manufacture of detergents last December, pending further tests and review of animal studies. They should be commended for their concerned and responsible action.

Since that action, the Public Health Service has completed a review of all data available on NTA. This review included general toxicological studies with emphasis on possible mutagenic, teratogenic, and carcinogenic potential of NTA. Government and industry scientists have cooperated fully on the review and analysis of available data.

In summary, additional data have reinforced the conclusion that NTA is not now considered a mutagen. NTA does appear to enhance the teratogenicity of methyl mercury under certain circumstances, but since methyl mercury is such a potent teratogen in its own right, this enhancing effect is not considered by our scientists to be significant. Review of the data available on the carcinogenicity of NTA leaves a number of questions unanswered. The effect of NTA on the uptake and distribution of heavy metals in man and those species of animal and plant life which he uses for food also remains to be investigated.

Based upon all of these considerations, and until these questions can be resolved, NTA should not be used as a builder in detergents. Any other recommendation would not be in the best interests of the health of the American public. However, the question of the use of NTA in detergent products is not closed; we will continue to work with industry on additional studies in these areas of concern, and we will continue to conduct research within the NCI on the carcinogenicity of NTA.

In response to the demand for no-phosphate or low-phosphate detergents, and with the temporary suspension of use of the most promising substitute for phosphates in home laundry products, many manufacturers turned to carbonates and silicates as builders in their products. These substances can be used in such a way that the product containing them is highly toxic thus posing serious accident hazards, especially to small children. These caustic formulations have the capability to burn, eat away, or destroy living tissue by chemical action. Let me amplify my concern with respect to caustic materials. Such materials, particularly in pellet or granular form, measured in quantities as little as a fraction of a teaspoon, may cause severe damage to the skin, eye, mouth, throat, larynx, esophagus or stomach upon contact. Caustic materials quickly take up the available moisture on these membranes, setting off a chemical reaction leading almost immediately to destruction of tissues at the site. Anyone who has spilled strong alkali on his skin will remember that the reaction is virtually immediate and that removal of the offending material requires prompt and vigorous action, either by flooding with water or application of a weakly acidic material.

Everyone here knows that youngsters explore their environment vigorously long before they are able to read and comprehend fully either written or spoken warnings. Those of us who have raised children are fully aware of the difficulties of adequately protecting the toddler on his forays into the kitchen and laundry storage areas, and yet failure to do so when those areas contain highly caustic materials exposes the child to serious risk of irreversible loss of sight, loss of voice, ulcerations and blockage of the esophagus, severe skin "burns” and even death.

Senator BAKER. Mr. Chairman, let me interrupt to ask the Doctor how his remarks about caustic substances relate to detergents?

Dr. STEINFELD. The detergent formulations vary widely, as you know. A detergent formulation that was high in metasilicate and carbonate could have this reaction. There are a number of factors: the pH of the material, its reserve alkalinity; the structure, either granular, or finely powdered, and so forth. Some of the detergents on sale in this country do have these properties.

Senator BAKER. Do phosphate detergents have these properties?

Dr. STEINFELD. Some of the phosphate detergents depending on the other materials formulated with them could contain sufficient carbonate and metasilicate to have similar properties. Generally, however, the phosphate detergent is a milder detergent in terms of pH and so forth. This generalization is not always true, however, as the previous witness indicated.

Senator BAKER. Thank you.

Dr. STEINFELD. The mother who is called to the telephone or to the door may be unaware that her child has had an accident with such a material and lose critically important time in attempting to prevent serious injury. Even where the mother discovers the accident promptly, precious time may be lost in attempts to gain medical advice or assistance. When asked by the housewife with small children, I would recommend she not use detergents which require labeling under the Hazardous Substance Act.

To suggest that a frequently used household item that is bulky can be stored assuredly out of reach of youngsters is to be unrealistic. Statistics on accidental exposure to dangerous substances in the household lead me to believe that any action which results in widespread incorporation of caustic materials in detergents may also be expected to result in many additional serious injuries to children. The Hazardous Substances Act requires that packages containing such materials bear appropriate warning labels, but warning labels place the entire burden of protection on the shoulders of the parents. Where it is believed that the warning label does not provide sufficient protection, and if the child-proof packaging does not provide sufficient protection, then we will consider banning the material from interstate commerce under the provisions of the Hazardous Substances Act.

Action was taken by the Food and Drug Administration in March of this year to remove two such products from the market until warnings were placed on the containers. Recognizing that there was a need for a fuller understanding of the nature and extent of this problem, a detergent survey was undertaken by the FDA beginning that same month. A total of 39 phosphate and nonphosphate detergent products was sampled and examined, to determine both the chemical and toxicological characteristics of each product. As a result, the manufacturers of 16 of the detergents were asked to relabel all outstanding stocks of their products with adequate cautionary information. Nine other firms were asked to begin proper cautionary labeling of packaged detergent products being produced. Fourteen other products were deemed to be either adequately labeled or not unduly hazardous.

Let me take this opportunity to make it clear that not all low-phosphate or no-phosphate home laundry products are highly caustic. Soap, for example, while extremely irritating to eye tissues, is an acceptable alternative home laundry product from a human health point of view; whereas with some of the detergents, because of their alkalinity fixed to the tissues, it is much more difficult to remove them.

However, carbonate and/or silicate substitutes increase the total alkalinity of products using them; the greater the volume of such substitutes in the product, in general, the greater is the degree of possible hazard. The Food and Drug Administration is in continuous communication with the detergent industry regarding all requirements with the Federal Hazardous Substances Act, and plans to continue to work with the industry along three lines: product reformulation; adequate labeling; and under the provisions of the recently enacted Poison Prevention Packaging Act, requiring that substances capable of causing serious injury or illness to children be packaged in containers which are designed to be difficult, if not impossible, for children to open.

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