Environmental Management Strategies for Biodegradable Nonylphenol Ethoxylates in Agricultural Products

1. Environmental Management Strategies for Biodegradable Nonylphenol Ethoxylates in Agricultural Products Ellen Mihaich, Ph.D., DABT Carter Naylor, Ph.D. Rhodia Inc. Huntsman Corporation Charles Staples, Ph.D. Assessment Technologies, Inc. I want to thank you for allowing me to talk to you today about an exciting new proactive program to manage the use of biodegradable compounds. I will be speaking today primarily about nonylphenol ethoxylate based products and the Environmental Management Program developed to ensure continued safe use of these compounds. While this program focuses on NPE and its degradation intermediates, the approaches and technologies used are applicable for most organic compounds and should be an integral component of best management practices. Before I get started I would like to acknowledge my coauthors Carter Naylor from Huntsman Corporation and Charles Staples from Assessment Technologies Inc., as well as the other members of the Alkylphenols & Ethoxylates Research Council, the group doing so much research on these compounds and implementing the EMP. I would also like to acknowledge my past colleagues from Aventis, namely Roy Chen, Bob Ligon and David Long for their patience and guidance in working through the environmental management program for the agricultural industry with me. I want to thank you for allowing me to talk to you today about an exciting new proactive program to manage the use of biodegradable compounds. I will be speaking today primarily about nonylphenol ethoxylate based products and the Environmental Management Program developed to ensure continued safe use of these compounds. While this program focuses on NPE and its degradation intermediates, the approaches and technologies used are applicable for most organic compounds and should be an integral component of best management practices. Before I get started I would like to acknowledge my coauthors Carter Naylor from Huntsman Corporation and Charles Staples from Assessment Technologies Inc., as well as the other members of the Alkylphenols & Ethoxylates Research Council, the group doing so much research on these compounds and implementing the EMP. I would also like to acknowledge my past colleagues from Aventis, namely Roy Chen, Bob Ligon and David Long for their patience and guidance in working through the environmental management program for the agricultural industry with me.

2. Presentation Overview Product Overview State of the Science Regulatory Status NPE Environmental Management Program Best Industry Practices First I will give you a brief product overview and then we will talk a bit about the state of the science today. Then I would like to tell you about the regulatory status of these compounds and why the APE Research Council has decided to take a proactive stance and implement the NPE Environmental Management Program. Then I will finish with some specific goals and objectives and how these fit in with what is currently happening in the agricultural industry.First I will give you a brief product overview and then we will talk a bit about the state of the science today. Then I would like to tell you about the regulatory status of these compounds and why the APE Research Council has decided to take a proactive stance and implement the NPE Environmental Management Program. Then I will finish with some specific goals and objectives and how these fit in with what is currently happening in the agricultural industry.

3. Product OverviewNonylphenol Based Products High performance, cost effective compounds with broad regulatory acceptance Safe for the environment when used as intended, handled and disposed of properly Not a risk to human health through normal use and exposure Alkylphenol based products have been safely used for more than 50 years, in part due to inherent properties that make them a high-performance and cost effective choice in a wide range of applications. When used, handled and disposed of properly, they pose no known risk to human health or the environment. Alkylphenol based products have been safely used for more than 50 years, in part due to inherent properties that make them a high-performance and cost effective choice in a wide range of applications. When used, handled and disposed of properly, they pose no known risk to human health or the environment.

4. Product OverviewNPE Applications Household, Industrial & Institutional cleaners Textile manufacturing Paper and pulp processing Metal processing Emulsion polymerization Agricultural products Alkylphenol ethoxylates, often referred to as the �workhorse surfactants�, are the preferred surfactant in many applications because of their inherent chemical and physical properties which make them outstanding dispersants, wetting agents and emulsifiers. Their phenolic nature also provides excellent chemical stability in extreme processing conditions. In addition and very importantly, they are perhaps the most �studied� surfactant family available, the subject of literally hundreds of toxicity and fate studies. Due to their reputation as high value, high performance surfactants, alkylphenol ethoxylates are found in a broad range of applications from household, industrial and institutional cleaners, to processing aids in the manufacture of textiles and pulp and paper, to the manufacture of latex polymers for water-based paints through emulsion polymerization technology and, as you know, as surface-active compounds in pesticide formulations and adjuvants.Alkylphenol ethoxylates, often referred to as the �workhorse surfactants�, are the preferred surfactant in many applications because of their inherent chemical and physical properties which make them outstanding dispersants, wetting agents and emulsifiers. Their phenolic nature also provides excellent chemical stability in extreme processing conditions. In addition and very importantly, they are perhaps the most �studied� surfactant family available, the subject of literally hundreds of toxicity and fate studies. Due to their reputation as high value, high performance surfactants, alkylphenol ethoxylates are found in a broad range of applications from household, industrial and institutional cleaners, to processing aids in the manufacture of textiles and pulp and paper, to the manufacture of latex polymers for water-based paints through emulsion polymerization technology and, as you know, as surface-active compounds in pesticide formulations and adjuvants.

5. State of the ScienceEnvironmental Exposure NP and NPE are biodegradable NP and NPE are effectively removed in well-functioning sewage treatment plants Removal rate of NPE from wastewater treatment is on average 95% NP and NPE do not bioaccumulate Most of the scientific research on environmental exposure to alkylphenol-based products has focused on nonylphenol and nonylphenol ethoxylates, since they are the most commercially relevant of these compounds. Nonylphenol and nonylphenol ethoxylates are biodegradable in both water and sediment, although degradation occurs at a slower rate in sediment than in oxygen-rich environments. These compounds and their breakdown products are ultimately converted into two simple compounds - carbon dioxide and water. Wastewater treatment facilities have proven very effective in removing organic compounds, including nonylphenol and nonylphenol ethoxylates. In the US, a number of studies have shown that treatment plants remove on average 95% of nonylphenol and its ethoxylates from wastewater. So, in a properly functioning wastewater treatment facility, only trace amounts of nonylphenol and nonylphenol ethoxylates are discharged to the environment. Studies have shown that nonylphenol and nonylphenol ethoxylates have a low potential to bioaccumulate in the bodies of fish and other animals so they do not become a permanent part of the food chain. Most of the scientific research on environmental exposure to alkylphenol-based products has focused on nonylphenol and nonylphenol ethoxylates, since they are the most commercially relevant of these compounds. Nonylphenol and nonylphenol ethoxylates are biodegradable in both water and sediment, although degradation occurs at a slower rate in sediment than in oxygen-rich environments. These compounds and their breakdown products are ultimately converted into two simple compounds - carbon dioxide and water. Wastewater treatment facilities have proven very effective in removing organic compounds, including nonylphenol and nonylphenol ethoxylates. In the US, a number of studies have shown that treatment plants remove on average 95% of nonylphenol and its ethoxylates from wastewater. So, in a properly functioning wastewater treatment facility, only trace amounts of nonylphenol and nonylphenol ethoxylates are discharged to the environment. Studies have shown that nonylphenol and nonylphenol ethoxylates have a low potential to bioaccumulate in the bodies of fish and other animals so they do not become a permanent part of the food chain.

6. State of the ScienceEnvironmental Exposure Monitoring studies in North America show low environmental levels of NP and NPE Environmental levels of concern exist where effluent treatment is inefficient or inadequate Numerous environmental monitoring studies have been conducted. In North American waterways, environmental concentrations of nonylphenol and nonylphenol ethoxylates are very low or below detectable levels. Where NP and NPEs are typically detected in Canadian and US waters (i.e. near production facilities or in waters receiving sewage) the concentrations are also very low, below the levels known to pose a risk to fish or other aquatic organisms. In a major US study of 30 rivers, NP concentrations were all measured well below 1 ppb. Environmental levels of concern can and do exist where effluent treatment is inefficient or inadequate which is why appropriate product stewardship is required. Numerous environmental monitoring studies have been conducted. In North American waterways, environmental concentrations of nonylphenol and nonylphenol ethoxylates are very low or below detectable levels. Where NP and NPEs are typically detected in Canadian and US waters (i.e. near production facilities or in waters receiving sewage) the concentrations are also very low, below the levels known to pose a risk to fish or other aquatic organisms. In a major US study of 30 rivers, NP concentrations were all measured well below 1 ppb. Environmental levels of concern can and do exist where effluent treatment is inefficient or inadequate which is why appropriate product stewardship is required.

7. State of the ScienceEnvironmental Effects Aquatic studies with NP dozens of species covering fish, amphibians, mollusks, insects, annelids, crustaceans, algae, protozoa, and microorganisms Aquatic studies with NPE and NPEC acute and chronic data for fish and crustaceans NP and NPE have been extensively tested for their effect on a wide range of aquatic species; therefore we have a good understanding of their potential impact if they are released to the environment. In most aquatic organisms, these compounds result in acute or immediate toxicity at concentrations much higher than those detected in the environment. NP is generally more toxic than its ethoxylates. It is also more toxic than breakdown intermediates, which are formed during the biodegradation of NPE in the environment. An ambitious research project of the USEPA studied the effects of NP on many classes of aquatic organisms in a pond enclosure over a period of months. The study found no measurable effects below 76 ppb. Typical concentrations of NP range from non-detect to 0.64 ppb. Tests conducted on NP cover many potential mechanisms of toxicity and assess effects ranging from acute mortality to long-term growth and reproduction, biochemical (such as hormonal changes) and behavioral. As I am sure many of you are aware, endocrine or hormonal effects are certainly �big business� nowadays and with NP and NPE the endocrine issue is well understood. While some APs have weak estrogenic activity in in vitro studies (i.e. they bind to receptors), commercial APEs do not show any such estrogenic activity. What has been found is that it is overt toxicity and not endocrine-specific effects that drive the risk assessment conclusions. While I haven�t mentioned it on the slide there is also an avian study on NP showing that there is no effect at the limit of the test which was 5000 ppm in the diet.NP and NPE have been extensively tested for their effect on a wide range of aquatic species; therefore we have a good understanding of their potential impact if they are released to the environment. In most aquatic organisms, these compounds result in acute or immediate toxicity at concentrations much higher than those detected in the environment. NP is generally more toxic than its ethoxylates. It is also more toxic than breakdown intermediates, which are formed during the biodegradation of NPE in the environment. An ambitious research project of the USEPA studied the effects of NP on many classes of aquatic organisms in a pond enclosure over a period of months. The study found no measurable effects below 76 ppb. Typical concentrations of NP range from non-detect to 0.64 ppb. Tests conducted on NP cover many potential mechanisms of toxicity and assess effects ranging from acute mortality to long-term growth and reproduction, biochemical (such as hormonal changes) and behavioral. As I am sure many of you are aware, endocrine or hormonal effects are certainly �big business� nowadays and with NP and NPE the endocrine issue is well understood. While some APs have weak estrogenic activity in in vitro studies (i.e. they bind to receptors), commercial APEs do not show any such estrogenic activity. What has been found is that it is overt toxicity and not endocrine-specific effects that drive the risk assessment conclusions. While I haven�t mentioned it on the slide there is also an avian study on NP showing that there is no effect at the limit of the test which was 5000 ppm in the diet.

8. State of the ScienceEffect Levels for Risk Assessment USEPA draft AWQC for NP = 5.9 �g/L Toxicity of NPE biodegradation intermediates relative to NP (from Environment Canada) - NP vs. NPE1,2 = 2X NP vs. NPE9 = 200X NP vs. NPEC1,2 = 200X Criteria for NPE and metabolites in water NP = 5.9 �g/L NPE1,2 = 11.8 �g/L NPE3-16 = 1180 �g/L NPEC1,2 = 1180 �g/L In the US, the EPA has proposed a draft national ambient water quality criteria of 5.9 ppb for the long-term protection of freshwater aquatic life. The draft criteria for protection against short term exposures is about 22 ppb for NP. These draft criteria are still under review but they will be used to illustrate how they will aid the Environmental Management Program. In Canada, the recent risk assessments for NP and NPE, which we will talk about in a minute, developed criteria for the long-term protection of aquatic life in a slightly different way from the US, although they developed a fairly similar guideline. In addition, they reviewed the available data for the low mole ethoxylates, NPE1,2, NPE 3 and higher ethoxylates and for NP ether carboxylates, all breakdown intermediates of NPE. Using the concept of toxic equivalency, they concluded that proportionally, NPE1,2 were two-fold less toxic than NP, NPEC and NPE3 and above were all 200-fold less toxic than NP. Since NPE is easily biodegraded into mainly low mole ethoxylates and ether carboxylates, it is prudent to develop voluntary guidelines for these compounds also. Based on the USEPA proposed guideline you can see what the voluntary water quality criteria would be for these other products.In the US, the EPA has proposed a draft national ambient water quality criteria of 5.9 ppb for the long-term protection of freshwater aquatic life. The draft criteria for protection against short term exposures is about 22 ppb for NP. These draft criteria are still under review but they will be used to illustrate how they will aid the Environmental Management Program. In Canada, the recent risk assessments for NP and NPE, which we will talk about in a minute, developed criteria for the long-term protection of aquatic life in a slightly different way from the US, although they developed a fairly similar guideline. In addition, they reviewed the available data for the low mole ethoxylates, NPE1,2, NPE 3 and higher ethoxylates and for NP ether carboxylates, all breakdown intermediates of NPE. Using the concept of toxic equivalency, they concluded that proportionally, NPE1,2 were two-fold less toxic than NP, NPEC and NPE3 and above were all 200-fold less toxic than NP. Since NPE is easily biodegraded into mainly low mole ethoxylates and ether carboxylates, it is prudent to develop voluntary guidelines for these compounds also. Based on the USEPA proposed guideline you can see what the voluntary water quality criteria would be for these other products.

9. Using the information from the many monitoring studies performed in the US, we can illustrate the impact that the combination of the various products would to the hazard quotient. Remembering that when determining the possible risks posed by any substance to the environment there are two components of the risk assessment formula: hazard or effect and exposure. By considering both hazard and exposure, we can determine whether the levels of a substance found in the environment pose a risk to the environment. The hazard quotient is developed by summing the ratio of surface water concentrations and water quality criteria (which is the measure of safe exposure or the no effect - which is our hazard component for the assessment). This is done for all the compounds of interest in order to get a cumulative hazard quotient. The data above come from an assessment of 30 US rivers chosen by EPA as being a probable worst-case situation, a study of the Fox river and various other work where detectable concentrations were identified. From this graph you can see that to date, using this voluntary hazard quotient approach for NPE and all biodegradation intermediates that a hazard quotient equal to or greater than 1 is not reached. For concern, the HQ would need to be 1 or greater suggesting that the concentration in the surface water exceeds a safe level for a particular aquatic organism. It is this kind of information that is used by regulatory authorities to determine if there is a concern.Using the information from the many monitoring studies performed in the US, we can illustrate the impact that the combination of the various products would to the hazard quotient. Remembering that when determining the possible risks posed by any substance to the environment there are two components of the risk assessment formula: hazard or effect and exposure. By considering both hazard and exposure, we can determine whether the levels of a substance found in the environment pose a risk to the environment. The hazard quotient is developed by summing the ratio of surface water concentrations and water quality criteria (which is the measure of safe exposure or the no effect - which is our hazard component for the assessment). This is done for all the compounds of interest in order to get a cumulative hazard quotient. The data above come from an assessment of 30 US rivers chosen by EPA as being a probable worst-case situation, a study of the Fox river and various other work where detectable concentrations were identified. From this graph you can see that to date, using this voluntary hazard quotient approach for NPE and all biodegradation intermediates that a hazard quotient equal to or greater than 1 is not reached. For concern, the HQ would need to be 1 or greater suggesting that the concentration in the surface water exceeds a safe level for a particular aquatic organism. It is this kind of information that is used by regulatory authorities to determine if there is a concern.

10. Regulatory StatusUnited States No present or pending regulatory restrictions EPA Risk Management Findings - NP risk to aquatic organisms does not appear to be widespread in US waters Broad approval for food-contact applications EPA to establish water quality criteria for nonylphenol So, speaking about regulations, there are currently no present or pending regulatory restrictions on the use of alkylphenol-based products in the US. Recently, the EPA reviewed the science on NP and concluded that there is not a widespread risk to aquatic organisms from NP exposure in US waters. The US Food and Drug Administration has regulatory authority for those APEs in food-contact applications and they have issued broad approval for their use. They also have wide acceptance for use on both food and non-food crops under the Federal Insecticide, Fungicide and Rodenticide Act. The USEPA is currently drafting guidelines for nonylphenol that will establish safe environmental levels for the compound in water. If the USEPA maintains its current target guidelines, normal and reasonable treatment practices will likely suffice to assure user compliance with the forthcoming regulations.So, speaking about regulations, there are currently no present or pending regulatory restrictions on the use of alkylphenol-based products in the US. Recently, the EPA reviewed the science on NP and concluded that there is not a widespread risk to aquatic organisms from NP exposure in US waters. The US Food and Drug Administration has regulatory authority for those APEs in food-contact applications and they have issued broad approval for their use. They also have wide acceptance for use on both food and non-food crops under the Federal Insecticide, Fungicide and Rodenticide Act. The USEPA is currently drafting guidelines for nonylphenol that will establish safe environmental levels for the compound in water. If the USEPA maintains its current target guidelines, normal and reasonable treatment practices will likely suffice to assure user compliance with the forthcoming regulations.

11. Regulatory StatusCanada Canada NP and NPE included in second Priority Substances List (1995) Draft Assessment report published (4/2000) Final risk determination required by CEPA (12/2000) CEPA �toxic� - identify and implement risk management options to reduce or eliminate the risks that the substances pose to human health and the environment In Canada, the most significant regulatory development has been the release of Environment and Health Canada�s assessment on NP and its ethoxylates. The agencies found that in most circumstances, these compounds are not a concern for human health (64C) or the environment (64B). However, Environment Canada determined that in a few locations, concentrations of NP and NPE in the environment could exceed �safe levels� due to inefficient or nonexistent treatment. As a result, the agency has proposed classifying NP and its ethoxylates as �toxic� under the CEPA. Once Environment Canada finalizes its assessment, it will determine whether control actions are needed. As was stated before, normal and reasonable treatment practices will likely suffice to assure user compliance with the forthcoming regulations. Specific findings from the assessment were that: -NP and its ethoxylates from untreated or partially treated textile mills that discharge directly to the environment occur at levels that are likely to be causing harmful effects on aquatic organisms. -Discharges from municipal wastewater treatment plants and pulp and paper mills contribute NP and NPEs to the environment at levels that are of concern at a limited number of sites. So you can see that it is a select few instances where issues occur but these few instances were sufficient to trigger a label of �toxic� to be applied to this compound.In Canada, the most significant regulatory development has been the release of Environment and Health Canada�s assessment on NP and its ethoxylates. The agencies found that in most circumstances, these compounds are not a concern for human health (64C) or the environment (64B). However, Environment Canada determined that in a few locations, concentrations of NP and NPE in the environment could exceed �safe levels� due to inefficient or nonexistent treatment. As a result, the agency has proposed classifying NP and its ethoxylates as �toxic� under the CEPA. Once Environment Canada finalizes its assessment, it will determine whether control actions are needed. As was stated before, normal and reasonable treatment practices will likely suffice to assure user compliance with the forthcoming regulations. Specific findings from the assessment were that: -NP and its ethoxylates from untreated or partially treated textile mills that discharge directly to the environment occur at levels that are likely to be causing harmful effects on aquatic organisms. -Discharges from municipal wastewater treatment plants and pulp and paper mills contribute NP and NPEs to the environment at levels that are of concern at a limited number of sites. So you can see that it is a select few instances where issues occur but these few instances were sufficient to trigger a label of �toxic� to be applied to this compound.

12. NPE Environmental Management Program Program goals: Responsible environmental management Provide guidance on pollution prevention and control Complement existing and planned regulations Support the continued use of NPE The NPE Environmental Management Program is sponsored by the APE Research Council. The program is designed to promote the safe use and disposal of NP and its ethoxylates through effective treatment and control. As we have discussed, it has been shown that where effective wastewater treatment exists, almost all NP-based products are removed from the effluent and therefore do not enter the environment at levels of concern. Proper wastewater treatment obviously also prevents the release of other compounds to the environment. This type of pollution prevention results in measurable environmental improvement no matter what compound is being controlled. The EMP will assist companies in complying with forthcoming water quality guidelines in US and Canada. It provides an opportunity for users to continue using these well studied, high value, high performance products with the knowledge that they are handling them responsibly and in compliance with regulations.The NPE Environmental Management Program is sponsored by the APE Research Council. The program is designed to promote the safe use and disposal of NP and its ethoxylates through effective treatment and control. As we have discussed, it has been shown that where effective wastewater treatment exists, almost all NP-based products are removed from the effluent and therefore do not enter the environment at levels of concern. Proper wastewater treatment obviously also prevents the release of other compounds to the environment. This type of pollution prevention results in measurable environmental improvement no matter what compound is being controlled. The EMP will assist companies in complying with forthcoming water quality guidelines in US and Canada. It provides an opportunity for users to continue using these well studied, high value, high performance products with the knowledge that they are handling them responsibly and in compliance with regulations.

13. NPE Environmental Management Program Program elements Communication and Education Water Quality Criteria/Guidance Toxicity Equivalencies for NPE and derivatives Liaison with Regulatory Agencies Monitoring program and identification of �hot spots� Most of the elements of this program center around communication and education. We are targeting the various sector users and letting them know that the APE Research Council is a resource. We are preparing sector specific information and guidelines. We are explaining about the pending water quality guidelines, we are providing means to determine how much NP/NPE is in effluent, we describe proper wastewater treatment methods for particular industries and we can help analyze for the fail-points in the use and treatment of the compounds. We have also established, as I explained earlier, voluntary guidance for total toxic equivalents to ensure that concentrations of NPE and all of the breakdown products, when taken together are within safe levels in the environment. We are liaisoning with regulatory authorities in both the US and Canada to encourage the use of the EMP in pollution prevention programs rather than the implementation of significant restrictions and bans on the product. This teaming with regulatory authorities also allows us to develop appropriate monitoring programs with targeted industries in areas identified as �hot spots� or of concern to the regulatory agency.Most of the elements of this program center around communication and education. We are targeting the various sector users and letting them know that the APE Research Council is a resource. We are preparing sector specific information and guidelines. We are explaining about the pending water quality guidelines, we are providing means to determine how much NP/NPE is in effluent, we describe proper wastewater treatment methods for particular industries and we can help analyze for the fail-points in the use and treatment of the compounds. We have also established, as I explained earlier, voluntary guidance for total toxic equivalents to ensure that concentrations of NPE and all of the breakdown products, when taken together are within safe levels in the environment. We are liaisoning with regulatory authorities in both the US and Canada to encourage the use of the EMP in pollution prevention programs rather than the implementation of significant restrictions and bans on the product. This teaming with regulatory authorities also allows us to develop appropriate monitoring programs with targeted industries in areas identified as �hot spots� or of concern to the regulatory agency.

14. Best Industry Practices NPE products represent approx. 17% of surfactants used in ag. industry At manufacturing/formulation sites BMPs include: waste minimization loss prevention programs recycling wastewater treatment monitoring NPE products represent approximately 17% of the surfactants used in the agriculture industry since they are cost effective and high performing. There are two distinct types of emissions to the environment from the use of NPE based products that requires us to consider the possible consequences separately. The first is from facilities that manufacture or formulate products. Release from manufacturing or processing facilities may occur via permitted effluents following onsite treatment or via treatment in municipal treatment plants and occasionally through spills or accidental releases. In a survey of pesticide manufacturers and formulators, the majority reported using either partial or full recycling of wastewater from their plants. In particular, the waste streams containing the pesticide active ingredient and �inerts� are usually recycled back into the process or stored on-site until the next manufacturing campaign. This serves both to prevent the release of the active ingredient into the environment and to gain economic efficiencies. The chief concern of the formulator is typically the prevention of inappropriate releases of the active ingredient. Nevertheless, careful handling and use of the inerts, in this case NPE based compounds, minimization of product use through efficiency analysis within the process and recycling practices, use of onsite treatment and at least secondary if not tertiary treatment prior to discharge into a waterbody will all minimize release and ensure safe concentrations of these compounds entering the environment. In situations where there is a concern that treatment is not effective or when a material balance (the material going into the process doesn�t seem to match what you know is coming out) then monitoring of the effluent or receiving water body might be necessary.NPE products represent approximately 17% of the surfactants used in the agriculture industry since they are cost effective and high performing. There are two distinct types of emissions to the environment from the use of NPE based products that requires us to consider the possible consequences separately. The first is from facilities that manufacture or formulate products. Release from manufacturing or processing facilities may occur via permitted effluents following onsite treatment or via treatment in municipal treatment plants and occasionally through spills or accidental releases. In a survey of pesticide manufacturers and formulators, the majority reported using either partial or full recycling of wastewater from their plants. In particular, the waste streams containing the pesticide active ingredient and �inerts� are usually recycled back into the process or stored on-site until the next manufacturing campaign. This serves both to prevent the release of the active ingredient into the environment and to gain economic efficiencies. The chief concern of the formulator is typically the prevention of inappropriate releases of the active ingredient. Nevertheless, careful handling and use of the inerts, in this case NPE based compounds, minimization of product use through efficiency analysis within the process and recycling practices, use of onsite treatment and at least secondary if not tertiary treatment prior to discharge into a waterbody will all minimize release and ensure safe concentrations of these compounds entering the environment. In situations where there is a concern that treatment is not effective or when a material balance (the material going into the process doesn�t seem to match what you know is coming out) then monitoring of the effluent or receiving water body might be necessary.

15. Best Industry Practices Application sites small concentrations of surfactant are used per acre degradation and dispersion minimizes possible environmental exposure set-backs and buffer zones, recommended for many products primarily due to the active pesticide ingredient, will effectively reduce any aquatic exposure The second way compounds enter the environment is from the intended use of the agricultural product in the environment. For the actual pesticide application, only 5-7% of the formulated product is typically made up of surfactant. In order to minimize the volume for packaging, inventory and transportation, the smallest effective concentration of surfactant is typically used. The 5-7% surfactant that is in the formulated product is further diluted in the final spray tank mixture that is applied to the field by the farmer or applicator. The final concentration of APE in the spray tank is approximately 0.1% to 0.2% with adjuvant added. This results is an extremely small concentration of surfactant applied per acre. In addition, degradation further minimizes environmental exposure. Biodegradation of NPE in soil has been well studied, primarily from use of higher concentrations of NPEs and metabolites in sludge application to fields as nutrient amendments. Looking at the available data, the conclusion from the Canadian assessment that I talked about early was that NP and the lower carboxylates do not appear to be persistent in soil under aerobic conditions. As a final check on minimizing surfactant migration to aquatic systems, many pesticides have label requirements for setbacks, buffer zones, or at the minimum restrictions on overspraying water bodies to prevent the active ingredient from entering aquatic habitats. These restrictions would obviously prevent the other formulation ingredients from entering these habitats also. The second way compounds enter the environment is from the intended use of the agricultural product in the environment. For the actual pesticide application, only 5-7% of the formulated product is typically made up of surfactant. In order to minimize the volume for packaging, inventory and transportation, the smallest effective concentration of surfactant is typically used. The 5-7% surfactant that is in the formulated product is further diluted in the final spray tank mixture that is applied to the field by the farmer or applicator. The final concentration of APE in the spray tank is approximately 0.1% to 0.2% with adjuvant added. This results is an extremely small concentration of surfactant applied per acre. In addition, degradation further minimizes environmental exposure. Biodegradation of NPE in soil has been well studied, primarily from use of higher concentrations of NPEs and metabolites in sludge application to fields as nutrient amendments. Looking at the available data, the conclusion from the Canadian assessment that I talked about early was that NP and the lower carboxylates do not appear to be persistent in soil under aerobic conditions. As a final check on minimizing surfactant migration to aquatic systems, many pesticides have label requirements for setbacks, buffer zones, or at the minimum restrictions on overspraying water bodies to prevent the active ingredient from entering aquatic habitats. These restrictions would obviously prevent the other formulation ingredients from entering these habitats also.

16. Conclusions Alkylphenol-based products are safe for the environment when used as intended and disposed of properly Agriculture Industry well positioned for continued use of NPE surfactants Appropriate product stewardship protects the environment Proactive measures further ensure safe use and encourage rational regulation So, in conclusion, you can see that the extremely well-studied alkylphenol-based products are safe for the environment when used as intended and disposed of properly. The agriculture industry is well positioned based on their current product stewardship practices to be able to successfully meet proposed water quality criteria. However, appropriate product stewardship is an ongoing activity and should not be taken for granted. Constant vigilance is needed to police our practices and to make changes when they are necessary. We must act proactively to ensure the protection of the environment, which in the end allows for and encourages rational regulation. Thank you for your attention, and I would be happy to take any questions you might have.So, in conclusion, you can see that the extremely well-studied alkylphenol-based products are safe for the environment when used as intended and disposed of properly. The agriculture industry is well positioned based on their current product stewardship practices to be able to successfully meet proposed water quality criteria. However, appropriate product stewardship is an ongoing activity and should not be taken for granted. Constant vigilance is needed to police our practices and to make changes when they are necessary. We must act proactively to ensure the protection of the environment, which in the end allows for and encourages rational regulation. Thank you for your attention, and I would be happy to take any questions you might have.