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The number of possibilities for greatly decreasing the flow of phosphates into surface waters is relatively limited. These possibilities are (1) controlling the source of phosphates, which largely involves controlling the phosphate content of detergents, and (2) removing phosphates from sewage by advance sewage treatment processes before it is discharged into the lakes and streams. A costeffective approach to the phosphate problem probably will involve a combination of both approaches so as to achieve the desired levels of control.

Certainly, the Department of Health, Education, and Welfare fully supports the effort to retard eutrophication of our surface waters. We do urge, however, that this important and highly commendable goal be achieved by means which are not hazardous to human health and welfare.

In respect to efforts to displace phosphates from detergents, it should be realized that tests conducted thus far indicate that some of the currently used substitutes for phosphates are clearly toxic or caustic and pose serious accident hazards, especially to children. Other substitutes not yet fully tested may also be toxic and/or caustic. Intensive research on this problem currently is underway by both Government and industry. Much is unknown, particularly of the long term biological effects of components of detergents. Of course, some of the substitutes may not be harmful, but we must be certain of this before large scale exposure of society to them is permitted.

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 gotten lye 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. 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.

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, the Hazardous Substances Act permits the material to be banned entirely from interstate commerce. If our experience in the months ahead bears out the concerns which I have expressed, it may be neecssary for us to take drastic action against those detergents which are found to have extremely caustic properties.

Several years ago the detergent industry began seeking alternatives to phosphates which would be safe for both man and his environment. Nitrilotriacetic acid (NTA) was introduced and found to be highly satisfactory as a laundry agent, and not harmful to the environment. However, tests conducted within the past year raised a danger signal with respect to human health hazard. Use of NTA was discontinued voluntarily by the industry after discussions with us in December 1970, and I want to commend the industry for this prompt action in the face of a potential health threat. Since that time industry and government have collaborated in efforts to clarify the health aspects of NTA. In the months ahead we shall try to reach a definitive conclusion on this matter.

In summary, I believe that we must pursue a balanced public policy and an ordered approach to the solution of these problems.

In responding to one environmental problem great care must be exercised to assure that the alternative does not create equal or greater hazards to the environment or to human health. This is certainly the case with detergents in view of the massive quantities produced and ubiquitous nature of their distribution. Because of the real and not only potential health hazards of some of the identified phosphate substitutions, environmental protective regulatory efforts by Federal, State and local officials must be conducted carefully and intelligently, with full awareness of secondary health and biological effects of those efforts.

Finally, because scientifically much is still unknown, we must conduct additional research on phosphate substitutes to ascertain their place and the place of labelling in an effective overall program.

The U.S. Public Health Service therefore urges the Federal Trade Commission to defer making a decision regarding labelling at this time.

Caution Labels on new non-phosphate detergents.-Most if not all dry nonphosphate detergents introduced to date contain ingredients which are more caustic to human skin and must carry caution labels. The following statements are typical of those which meet the FDA labelling requirements.

"Caution: May be harmful if swallowed. Keep out of reach of children. See Cautions elsewhere on label."

"Caution: Contains sodium metasilicate and ethoxylated alcohols. Avoid contact with eyes and mucous membranes.

Antidote: External-Flush with water. If eye or other irritation persists, contact physician.

Internal-Give one or two glasses of milk or water and follow with diluted vinegar, lemon or other citrus fruit juice and contact a physician."

"Danger. May cause burns. Harmful if swallowed. Eye irritant. Contains sodium metasilicate. Avoid contact with skin, eyes and mucous membrane.

"In case of external contact, flush with water. For eyes, flush with water for 15 minutes and get immediate medical attention. If swallowed, give large quantities of water or milk, follow with citrus juice or diluted vinegar. Call physician immediately.

"Keep out of the reach of children."

[From Newsday, Sept. 7, 1971]

CLEANING PRODUCTS: STORE WITH CARE

(By Frances Cerra, Newsday Consumer Writer)

Every good parent knows that medicines should be stored out of the reach of children. But what about furniture polishes and dishwasher and laundry detergents? Most people store such cleaning products under the kitchen sink.

The recent death of a 15-month-old Connecticut girl showed that these products deserve as much care in storing as medicines. The child so far unidentified, died Aug. 11, six days after she swallowed some Arm & Hammer nonphosphate laundry detergent, according to an elder of the Food and Drug Administration. Yet this product is apparently not unusually toxic for a laundry detergent, and is less dangerous than some dishwasher detergents and furniture polishes.

Government statistics show, in fact, that deaths from such cleaning products are not uncommon. In 1965, the latest years for which statistics have been compiled, 13 children under 5 years of age died from swallowing such products, and these figures are probably far below the actual number. Most cases of poisoning go unreported, and some estimates of the number of serious injuries from such products run into the thousands.

So dangerous are some household cleaning products that Consumers Union recently charged the federal government with negligence for failing to ban some of them from the market. The current issue of Consumer Reports also criticizes manufacturers for making the products easy for children to open.

Details about the death of the Connecticut girl are not yet available, but early reports indicate that she died of suffocation caused by damage to her respiratory tract from the detergent. Arm & Hammer nonphosphate laundry detergent is a hazardous substance, according to federal definitions, and is therefore labeled that it "may be harmful if swallowed." Tide, for example, which is a phosphate detergent, is not so labeled and is less dangerous than Arm & Hammer.

In general, nonphosphate detergents are more dangerous than phosphate detergents, according to Jerome Donovan, deputy director of FDA's division of hazardous substances and poison control. But Ed Miller, project engineer in the chemistry division of Consumers Union, said that recent tests by that independent testing organization showed that Arm & Hammer is less toxic than three other nonphosphate detergents.

A spokesman for Church & Dwight Inc., manufacturer of Arm & Hammer, said, "Quite extensive research on this product confirmed that like most detergents Arm & Hammer won't cause injury when used as directed." Miller pointed out that there is, in fact, no detergent on the market that is at the same time nonpolluting, effective in cleaning and truly safe. Parents should realize, he said, that "if they use detergents of any kind, they are playing with fire." His advice is to use soap, which he says does meet all three criteria.

On the subjects of dishwasher detergents, petroleum-based furniture polishes and liquid drain cleaners, Consumers Union had particularly harsh criticism of Health, Education and Welfare Secretary Richardson. Consumers Union pointed out that the secretary has the power to ban substances that are so dangerous that warning labels are insufficient protection. The consumer group said it is clear that petroleum-based furniture polishes fall into this category because they instantly saturate the lungs, causing a chemical pneumonia that can not be reversed. Most furniture polishes are not petroleum-based.

[From the Cincinnati Post, Sept. 16, 1971]

CHILD'S DEATH KEY TO MOVE

WASHINGTON.-The death of a 15-month-old girl in Putnam, Conn., played a key role in the government's decision to clear the way for continued production of detergents made with phosphates, federal officials today.

The child died because she accidentally swallowed a laundry detergent in which caustic materials replaced phosphates as a cleaning agent.

Other children in recent months have been severely burned by no-phosphate caustic detergents; one child has undergone repeated surgery for burns on his esophagus, and a child in California reportedly was blinded by a caustic nophosphate detergent earlier this month.

In the above experiment the effect on algal growth of soap, a non-phosphate detergent and a phosphate-based detergent are compared. The green algae, Selenastrum capricornutum is shown growing in a nutrient-rich medium (modified Gorham's medium) containing all nutrients essential for algal growth, inclusive of 7 mg/1 phosphorus, but excluding the inorganic sodium carbonate. Also the non-biodegradable ethylene diamine tetraacetic acid (EDTA) was employed as the trace metal sequestrant in place of the normal biodegradable sodium citrate/citric acid.

The medium in each flask after sterilization by autoclaving was innoculated with 1000 cells of Selenastrum per milliliter and with soap, a non-phosphate detergent, a phosphate-based detergent and sodium bicarbonate in flasks 2 to 5, respectively.

It is seen that after 18 days growth under identical conditions of lighting, temperature and agitation, as specified in the PAAP test, algal growth was six times greater in the flask containing the non-phosphate detergent and 33 times greater in the flask containing the soap. The flask to which the phosphate-based detergent was added had essentially the same algal growth as the control flasks. The differences seen here are attributed to the differences in amounts of organic and inorganic carbon compounds in soap, non-phosphate detergents and phosphate-based detergents.

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EFFECT OF SOAP AND A NON-PHOSPHATE DETERGENT

ON ALGAL GROWTH, COMPARED TO A PHOSPHATE-BASED DETERGENT

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[Reprinted from Nature, vol. 215, No. 5107, pp. 1277-1278, Sept. 16, 1967] EFFECT OF CARBOHYDRATES ON THE SYMBIOTIC GROWTH OF PLANKTONIC BLUEGREEN ALGAE WITH BACTERIA

Phosphorous and nitrogen have been suggested to be limiting agents in the unwanted growth of Cyanophyta. Removal of phosphorous from sewage effluents is being considered as the preferred method to control eutrophication. The significance of organic matter in lake water has been largely disregarded, although carbonaceous material is always found in productive lakes, for example, from 22 mg to 99 mg/l. of dissolved organic matter in the Great Lakes.1 Massive growths of blue-green algae have been documented before the use of industrial phosphates and they probably occurred always after a heavy influx organic matter. Maximum growth of phytoplankton does not require high concentrations of phosphorus. As little as 0.02 mg of phosphorus/1. in natural lake may sustain it. Additional phosphorus alone does not increase growth because algal growth will depend on the presence and availability of not less than fifteen essential elements.

1 Received January 7, 1970; revised May 5, 1970.

2 This work was supported by a grant from the Soap and Detergent Association, New York.

Planktonic Cyanophyta are always associated with bacteria, and I have found that abundant algal growth results from a symbiotic relationship within their systems. In particular, the results reported here suggest that the bacteria assimilate added carbonaceous material and produce carbon dioxide which accelerates algal photosynthesis. The addition of a source of carbon also apparently delays the bacterial assimilation of organic chelating agents which are necessary if nutritional elements are to remain acessible at a high pH. Reports are consistent with various findings and, as a whole, support my conclusions.

I have grown the algae in Zehnder and Gorham's medium No. 11 (ref. 11) which contains, among other minerals, 609 mg of phosphorus/1., 81.7 mg of nitrogen/1. and only 607 mg of carbon/1. Half of the heavily inoculated growth medium was mixed with an aqueous solution of sucrose, the other half (the control) received an identical volume of distilled water. Quantities of 50 ml. of the two cultures were placed in 250 ml. Erlenmeyer flasks which were loosely capped with aluminum foil. The flasks were exposed to fluorescent illumination of 50 ft. candles (540 lux) in a 16-8 h cycle of light and dark at 22° C.

Tanner's Council Laboratory,
University of Cincinnati,
Cincinnati, Ohio.

CYANOPHYTA-BACTERIA SYSTEMS: EFFECTS OF ADDED CARBON COMPOUNDS OR
PHOSPHATE ON ALGAL GROWTH AT LOW NUTRIENT CONCENTRATIONS
(By Willy Lange, Tanner's Council Laboratory, University of Cincinnati,
Cincinnati, Ohio)

SUMMARY

Planktonic blue-green algae are known to be always associated with bacteria. Earlier work has shown that the adidtion of a bacteria-assimilable carbon source to a normal Zehnder-Gorham culture medium (No. 11) will produce enhanced growth of these algae when atmospheric CO2 has become the limiting factor. In new work, phosphate-rich culture media were diluted so that they simulated nutrient levels found in the Great Lakes, e.g., Lake Erie. At these low concentrations and when atmospheric CO2 was not available in a sufficient supply, the addition of sucrose to either a 1/100 or a 1/1000 diluted Z-G medium (10 mg or 2 mg of sucrose, respectively) also produced enhanced growth of the tested bluegreen algae. The stimulation of algal growth was apparently due to an increased bacterial production of CO2 and possibly other carbon compounds approaching the composition of the CO2 molecule. The literature suggests that during vigorous algal growth in lakes, atmosphere CO2 will be severely limiting. Productive lakes always contain nonliving organic matter. The presence of bacteria-assimilable matter is probably one of the important factors leading to algal bloom.

INTRODUCTION

The increasing nuisance growth of planktonic bule-green algae in our lakes has focused general attention on the role played by nitrogen compounds and particularly by phosphates as nutrients (9). Mackenthun & Ingram (8) have joined others in pointing out, however, that the growth of algae is influenced by many and varied factors, and some of these may be of equal importance to the major nutrients in influencing the production of nuisance algal bloom. A committee of the American Chemical Society (1) stated that the soundness of decisions relative to phosphates would benefit from further knowledge of the relative importance of phosphorus in promoting algal growth.

It has long been known that in full sunlight the concentration of CO2 in the atmosphere may become the limiting factor for photosynthesis in land plants, and the yield of crops may be increased up to three-fold by raising the concentration of CO2 in air (2). It is to be expected that during vigorous algal growth n lakes, atmospheric CO2 will be severely limiting because of its lower difusivity in liquid water than in air. That this is indeed the case is suggested y published observations and a detailed literature review by Kuentzel (4). The matter has been discussed by Legge & Dingeldein (7). Although it is comnonly known that planktonic Cyanophyta are always associated with bacteria,

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