Document DMq3OZ4b7XoVOpwnjoYEGEEVB

Interoffice Communication TO: FROM: DATE: SUBJ : Mike Hayes-LCCP T. G. Grumbles May 2, 1989 T66: XF: X >. SARA 313 REPORTING ALCOHOL ETHOXYLATES : m. RF VIS1A Attached is correspondence from SDA regarding a recent opinion that certain alcohol ethoxylates meet the Glycol Ether definition for SARA 313 reporting. Please review and comment on the following: 1. Plant impact of reporting those ethoxylates affected. 2. Any feel for expected emissions, disposal included. 3. Any suggested additions to the arguments list. I need your input by Friday so I can call SDA with our input. There will be an administrative burden in terms of 313 supplier notifications and MSDS revisions. T. G. Grumbles dlj Attachment cc: W. L. McClain, M. M. Goodreau, J. A. DeBernardi J. Friend, C. Taylor-LCCP vvv 000010422 The Soap and Detergent Association TO: RE: April 28, 1989 THE SDA RISK ASSESSMENT SUBCOMMITTEE Glvcol Ethers You should have seen the enclosed Environmental Legislation Report on glycol ethers by now. The next step for SDA is to meet with EPA staff on the matter sometime during the week of May 15, 1989 to review in depth the reasons why the one, two and three-mole ethoxylate content of alcohol and alkylphenol ethoxylates are not subject to the reporting requirement of SARA fi 313. An outline of the arguments that could be presented is enclosed. Please let me know by Mav 10. 1989 what modifications or additions need to be made to the list of arguments. Please provide me with documentation in support of the arguments. I will need assistance during the proposed meeting with EPA from one or two toxicologists. By May 10, please let me know who you recommend for this job. Very truly yours, Enc. Keith A. Booman, Ph.D. Technical Director vvW 000010423 - t*: 475 Parte Avenue South, New York, N.Y. 10016 (212) 725-1262 t Wd8S:T ^0--6T_6 t*:A0 1N3S ENVIRONMENTAL LEGISLA T/ON REPORT ER-76 ALERT IMPORTANT <fttcr: Mry P. Klleoyne April 24, 1989 NOTICE FEOERAL LEVEL SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT (SARA) Emergency Planning and Community Rtqht-to-Know Act (EPCRA) Section 313 - Title III - Release Reporting Requirements GLYCOL ETHERS Annual reporting of glycol ethers is required under SARA $ 313. Glycol ethers are defined as ^"(OCHjCHjJn-OR and R-(OCH,CH,)0-OH# where R is alkyl or aryl (not further specified) and n Is 1,2 or 3, The definition specifically excludes polymers, A telephone contact with an EPA official Indicates that EPA staff believes that alcohol ethoxylates come within this definition of glycol ethers and should be reported. The chemical industry does not use the term "glycol ether" In referring to al cohol ethoxylates and related surfactants. The uses of glycol ethers and alco hol ethoxylates (ami related surfactants) are distingulshably different. Al cohol ethoxylates are more corwnonly considered polymers for which reporting Is not required. Moreover, alcohol ethoxylates do not have the toxicological characteristics that lead to the reporting requirements for glycol ethers. Nevertheless, reporting of the one, two and three-mole ethoxylate content of alcohol ethoxylates and related nonionic surfactants will be required under EPA staff's interpretation. The Chemical Manufacturers Association on glycol ethers will be reviewing this matter on Wednesday, April 26, 1989. SDA will report any further developments in future Environmental Legislation Reports. vvv 00104?4 April 27, 1989 GLYCOL ETHERS: POSSIBLE REASONS FOR NOT REPORTING ALCOHOL AND ALKYLPHENOL ETHOXYLATES UNDER SARA 313 Alcohol and alkylphenol ethoxylates are polymers and are specifically excluded from reporting by regulation. Alcohol and alkyl phenol ethoxylates do not have the toxicological characteristics (reproductive toxicity) that motivated the listing of glycol ethers. Alcohol and alkylphenol ethoxylates have significantly different uses and consequently significantly different human exposure. Reporting alcohol and alkylphenol ethoxylates as glycol ethers will confound terminology in common use in industry. Because of distinctly different structure, properties and use, "glycol ether" and "alcohol ethoxylate" or "alkylphenol ethoxylate" have never been considered synonymous, and it is inconceivable that they ever would. Reporting alcohol ethoxylates and alkylphenol ethoxylates as glycol ethers will confound the resulting compiled information. It will provide misleading conclusions concerning glycol ether exposure which could not be used for guiding future action, as congress intended. .CUiLl. J2..I J. " 1 Pi.' 7? VVV 000010425 i ;x 0-61-6 ' b: AS