had to say, to supplement that testimony here today and we look forward to your reply. I wish that the time allowed me to question you immediately, but we have adopted that rule this afternoon, to try to get through here. I look forward to your responses, sir. Dr. COMMONER. I will be very happy to do that. I think one of the difficulties is that we have not had a sufficient dialog between those of us in the independent scientific community and those scientists connected with industry, and I think the public has suffered as a result. I think the confusion over the phosphate-nonphosphate problem could have been cleared up a long time ago if you held here a confrontation between the two sides, because that is how we get at the truth. Senator SPONG. I may very well do that. Dr. COMMONER. I think that would be very helpful and I would like to see that also as a test of our ability to deal with environmental problems. People don't understand how science gets at the truth. We don't get at the truth because we are more truthful than other people or even that we are more careful than other people. We make as many mistakes as other people. I am sure scientists lie as often as other people. But science gets at the truth. But the reason is that we make our mistakes in public where we can be recognized. One of the major probems here is the lack of public confrontation on both sides, and that is the quickest way to get at the truth, and I hope the Congress will help us do it. Senator SPONG. Thank you, Dr. Commoner. Dr. COMMONER. Thank you. (The following information was subsequently received for the record :) Dr. BARRY COMMONER, St. Louis, Mo. NOVEMBER 12, 1971. DEAR DR. COMMONER: Thank you for your testimony on October 29 before the Commerce Subcommittee on the Environment. As I said at that time, I am submitting to you in writing questions to be answered for the record. (1) Mr. Krumrei of Procter and Gamble testified that soap is not an acceptable alternative to phosphate detergents in hard water areas or with heavy wash loads of very dirty clothes. In light of your feelings, about soap, would you respond to his observation? (2) Mr. Krumrei also said that the making of soap uses more chlorine than the making of detergent and that this fact may result in more mercury being discharged into the environment. Is he right, or can you document the claim that you made in your article in the October 2 New Yorker that "In its substitution of manmade chemical processes for natural ones, detergent manufacturer inevitably produces greater environmental stress than the manufacture of soap does" with regard to the use of chlorine (and the resultant mercury)? (3) Please submit any information not covered in your statement on the desirability and effects of returning to soap which you feel would be of value to the Committee in its consideration of the whole detergent question. The Committee would appreciate it if you could answer these questions within a week. Sincerely, WILLIAM B. SPONG, Jr. Subcommittee on the Environment. CENTER FOR THE BIOLOGY OF NATURAL SYSTEMS, WASHINGTON UNIVERSITY, Senator WILLIAM B. SPONG, Jr., DEAR SENATOR SPONG: This is in response to your letter of November 12, 1971, regarding the questions raised by Mr. Krumrei concerning the feasibility of returning to the use of soap in washing machines and regarding the use of chlorine in soap manufacture. I am pleased to offer the following reply to these inquiries. (1) The feasibility of using soap in (clothes) washing machines.-Machinewashing of clothes was common, and effective, well before the introduction of synthetic detergents into the market. This is shown in the attached figure. As this figure indicates, the rise in production of washing machines began around 1931, when detergent production was negligible. (As early as 1935 Printers Ink was carrying tips for selling washing machines, and washing machine agitators were the subject of discussion in Product Engineering in 1942.) By 1946, washing machines were widespread, and production was still growing, especially in the realm of the new automatic washers. Yet at this time detergent production still remained negligible. These data show that in a period when only soap was used in them, washing machines were introduced, and achieved a level of production not very different from that at present, taking into account the rise in population. This means that they must have been found to be effective, in practice, with soap as the washing agent. There are several reasons why soap can be effective in washing machines, even in hard water. First, soap itself can be used as a water-softener-i.e., as a means of removing the calcium and other metallic ions which are present in hard water, and which interfere with the cleansing action of soap by forming an insoluble metal-soap curd. Thus, if extra soap is used, some of it forms a curd with the metallic ions, removing them from solution, so that the additional soap can then remain in solution and act effectively as a cleanser. This has the disadvantage of requiring the use of additional soap. Also, the metal-soap curd needs to be dealt with. The curd is a problem primarily in the rinse cycle of present automatic washers, in which wash water is drained off through the clothes, so that the clothes catch the suspended curd which then remains in them. In other words, in modern machines, the clothes act as a filter and would naturally pick up soap-curd (and any other suspended materials) as the water passes through them to the drain via the basket's bottom. However this difficulty did not arise in early washing machines, because they were designed to get rid of the curd without trapping it in the clothes. Some early washing machines, for example, drained rinse water by an overflow process that would remove the curd from the top of the washing basket. Other predetergent machines were constructed with a separate spinning basket in which the clothes were rinsed and spun dry. Since the clothes were lifted out of the original wash water when they were transferred to the second basket, curd and other suspended materials were left behind. Also, the wringer insured that no soap curd would be left on clothes after rinsing. Thus, the construction of modern washing machines represents a change from earlier ones, which had been carefully designed to take into account the particular behavior of soap in the washing process, including that in hard water. When detergents were introduced it became possible to alter the design of washing machines, and to take advantage of the different properties of detergents-especially that they do not tend to form curds. On this basis, it was possible to redesign the machines so that wash and rinse water was drained through the clothes. (It would be interesting to determine to what extent this new design tends to trap other particulate matter, such as grit, in the clothes.) This design change was actually predicted in industrial publications. For example, the staff of Chemical Industries in a 1946 report (Chem. Ind., June 1946, p. 965) stated that "... industrial processes of long standing (such as washing machines) were worked out with soap's limitations in mind. In order to take advantage of synthetic detergents, inertia will have to be overcome to introduce new techniques." One of these "new techniques" is the design of the modern washing machine and accounts for the poor performance of soap (relative to detergent) in them, unless the water is first softened. 71-179 O 72 pt. 2 24 Soap can, of course, be used in washing machines if the water is first softened where necessary. One approach is to use conventional water softener devices in the home water system. Such devices could also be built into washing machines. Another approach is to add a softener such as washing soda to the wash water. Thus Consumer Reports (October 1971) shows that soap and washing soda used together are as effective as phosphate-containing detergents as washing machine cleansers in hard water. Finally, new types of non-curd forming soaps can be used. For example, the development of soap-lime-soap cleansing agents by the USDA Agricultural Research Service has yielded a product which is 70-80% soap combined with a lime-soap dispersing agent similar to compounds that have a recent record of success in shampoos and dishwashing detergents. At least in the test stage, these soap-lime-soaps have proved to be more effective detergents than the synthetics and leave no curd; in addition, they are totally biodegradable in surface waters and are produced from natural fats, a renewable resource, rather than from a non-renewable one such as petroleum. For all of these reasons, I believe that machine clothes-washing can be carried out effectively, in hard water, with soap. (2) The use of chlorine soap production.-Chlorine is not an essential ingredient of soap, which is manufactured by reacting naturally occurring fats with an alkali such as sodium hydroxide. According to Encyclopedia of Chemical Technology chlorine may be used only in the bleaching process of some soap preparations in the form of sodium hypochlorite (sodium hydrosulfite may also be used). The standard industrial electro-chemical process for producing sodium hydroxide, however, has as a coproduct chlorine; this process has in the past been based on mercury electrodes (which can lead to water pollution by mercury), although they are now being replaced. I shall be glad to supply further information on these matters as needed. MONSANTO Co., INORGANIC CHEMICALS DIVISION, St. Louis, Mo., November 15, 1971. Hon. WILLIAM B. SPONG, JR., U.S. Senate, Washington, D.C. DEAR SENATOR SPONG: I would like to offer the following information, taken from the open scientific literature to correct some errors in fact introduced into the hearing record (perhaps inadvertently) by the testimony of Dr. Barry Commoner on October 29, 1971 following my testimony of the same date. Regarding the pollution potential of detergents in general, Dr. Commoner quoted from a 1966 text by R. M. Stephenson : Even if the (detergent) side chains degrade completely this still leaves nonbiodegradable benzene and phenol to contaminate the water. That this statement is at complete variance with the entire body of scientific literature is attested to by the fourteen journal articles and textbook referenced in the attached letter by Dr. R. S. Swisher, author of the recent text "Surfactant Biodegradation" (1970). Copies of these articles which date from 1957 [when the "completely destroyed" character of linear alkylbenzene sulfonates (LAS) was first demonstrated at the Purdue Conference] to 1970 are attached for your information or inclusion in the record as you see fit. Further, Dr. Commoner's charge that all detergents necessarily cause secondary pollution since the surfactant production requires chlorine which in turn adds mercury to the waterways, was accurately rebutted by the Procter and Gamble testimony of the same day. They noted that we would see an intensification of the same "problem" should we return (at his suggestion) to soap, since soap production requires even more chlorine. Further, we would like to point out for the record that Monsanto (which produces roughly 1% of the U.S. supply of LAS) uses no chlorine at all in the surfactant process. This process is well known in the literature. This addendum to the record is not intended to impugn Dr. Commoner's motives in any way. His sincere dedication to the environment is not in question. Rather, we wish to exercise the self-correcting aspect of open scientific debate, which he also espoused before your committee. We do feel that his thesis of "return to soap" is supported by factual errors which leaves the validity of the thesis open to serious question. Sincerely, Enclosure. IRA D. HILL, Ph. D., Manager, Research and Development, (The following information was subsequently received for the record :) Hon. WILLIAM B. SPONG, Jr., FMC CORP., INORGANIC CHEMICALS DIVISION, U.S. Senate, Committee on Commerce, Subcommittee on the Environment, Washington, D.C. DEAR SENATOR SPONG: On October 29, 1971, Dr. Barry Commoner, testified before your Subcommittee on the Environment, and made several statements which I believe require clarification for better understanding of the role of detergent phosphates in our environment. I am respectfully submitting the following comments for your consideration. Comment No. 1.-Dr. Commoner raised the question of the supply of phosphate in the world and stated that, "we shouldn't be wasting phosphates in detergents because they are needed to produce food." He cited as his reference a recent study by the Institute of Ecology in which they computed that at the present rate of utilization of phosphates for agriculture in the world we have only a 400 year supply of phosphate ore, and that if the rate of use increases because of increase in population (and increase in per capita use), the supply will last only 60 years. The Institute of Ecology, which was incorporated in February, 1971, held a two-week Workshop at the University of Wisconsin in June 1971 to draft a position on a number of ecological subjects. Their predictions on the supply of phosphates were extremely pessimistic because they limited their comments to the "known" (proven, economically recoverable) phosphate reserves not realizing that companies can rarely justify spending money to "prove" reserves more than 30 years in advance. For example in the United States the "known" and identified "potential" reserves combined are about seven times as great as the "known" or "proven" reserves. The U.S. Bureau of Mines has estimated the known and potential reserves of phosphate rock in the world to be equal to 21.8 billion short tons of phosphorus, which at present rates of use for fertilizers would last over 2600 years. Increased population and increased use per capita will of course decrease this time. However, the President's Science Advisory Committee, Panel on World Food Supply noted in 1967 with regard to reserves of phosphate that: "Even with marked expansion in mining, lack of minable reserves should cause little concern for at least the next century or two. In addition, vast new deposits are being discovered at frequent intervals and further improvements can be made in the recovery of the phosphate from the ores that are mined." (Ref: The World Food Problem, Vol. III, p. 108, U.S. Gov. Printing Office, 1967.) Finally, the leading experts on this subject are the editors on the subject of world reserves of phosphate rock. The British Sulfur Corporation, Limited, has just issued its Third Edition of The World Survey of Phosphate Deposits and have noted that the presently identified world-wide reserves of phosphate rock total 130 billion metric tons of rock. At an assumed concentration of 12% average phosphorus in phosphate rock (same assumption used by the Institute for Ecology), this calculates to 15.6 billion metric tons (17.2 billion short tons) of phosphorus in presently identified known and estimated reserves. This number is somewhat lower than that published by the U.S. Bureau of Mines because no "estimates" were included for a number of Eastern countries. In summary experts on the subject of world phosphate rock reserves disagree greatly with the dire predictions of the Institute for Ecology quoted by Dr. Commoner. For the record it should be noted that less than 15% of total phosphorus consumed in the U.S. each year is used in manufacture of household detergents and industrial cleaning agents. Comment No. 2.-Dr. Commoner noted that between 1946 and 1966 the detergent phosphates introduced into sewage increased from essentially zero to 150 million pounds. He concluded that these 150 million pounds of detergent phosphates "account for the bulk of the phosphate increase in surface waters." As noted in my testimony of October 29, in highly urbanized areas of this country such as the Lake Erie drainage basin, detergents account for about one-third of the phosphates entering Lake Erie, another third is assignable to human excrement and kitchen food wastes, and the last third to land run-off. However, as many eminent scientists have repeatedly noted, there is no correlation between phosphates added to a lake and the amount found in the lake water. (Ref: "Factors Affecting the Transfer of Materials Between Water and Sediments," by G. Fred Lee, University of Wisconsin, July 1970.) Although sodium and potassium phosphates are completely dissolved when added to a lake, they are rapidly converted to insoluble calcium, magnesium, iron and manganese phosphates which are deposited in the lake sediments. Also the clays and silts which are washed into a lake may either release phosphate to the water or extract soluble phosphate by adsorption to the clay which is also deposited in the lake sediments. As examples, in Lake Minnitonka, near Minneapolis, it was found that less than 7% of the phosphate entering the lake each year remains dissolved in the water. In Lake Michigan only 5% of the incoming phosphate remains in the water, but in Lake Erie over 25% remains dissolved in the water. There are many physical, chemical, and biological factors which determine how much of the incoming phosphate remains in solution and how much is deposited in the lake sediments but it appears that the amount of biological activity, i.e., the degree of eutrophication, is a major factor in retaining phosphates in the water and preventing their deposition in the lake sediments. Thus, it appears that any time we find increased concentrations of phosphate in a body of water it is a |